Quarterly Review of Legal Decisions Regarding Accessibility – 2023

ADA Kiosks Legal Action Kiosks

This page on legal actions in self-service and related is a running log with personal commentary on legal, privacy and patent situations which impact unattended self-service.  We keep track of legal news that affects the unattended self-service market.  One of the best articles to monitor is Kiosk Accessibility: The Law is Paying Attention by Lainey Feingold. Another great source is Understanding The ADA blog by William Goren.

Legal actions can also be HIPAA violations of privacy data and also web accessibility (WCAG usually), which have financial and legal consequences.  If you have news of note send us an email at [email protected]

Notable Legal Actions and Related In Brief:

  • Apr 2023
    • Biometrics and Illinois – Christian Dior’s virtual “try on” glasses wins in Illinois under BIPA and facial recognition. Link
    • ADA Tester of Hotels SCOTUS to rule on — In the court papers, Acheson’s lawyers claimed that Laufer had filed over 600 lawsuits since 2018 targeting small hotels and bed and breakfasts and that the cost of litigating a case might put defendants into bankruptcy. “A cottage industry has arisen in which uninjured plaintiffs lob ADA lawsuits of questionable merit while using the threat of attorney’s fees to extract settlement payments,” Acheson’s lawyers said.
  • Mar 2023
  • Feb 2023
    • CVS and Dalton –– CVS class action claims blind, low-vision customers cannot independently use HealthHub kiosks. CVS Health Corporation failed to make its CVS HealthHub self-service kiosks independently usable for individuals who are blind or visually impaired, a new class action lawsuit alleges.  Dalton vs. CVS Lawsuit Brief — Here are some pictures of Healthhub kiosks which are basically cheap mounted tablets. LINK
    • Biometrics and Maryland — link on Biometric Update – State of Maryland legislators are debating five bills (four cross-filed and one separate) addressing biometric and other private data collected by private organizations as part of doing business. Members of the Computer & Communications Industry Association issued a statement saying any legislation needs to be narrowly written to protect “high-risk practices,” although without spelling out what that means.
    • Employees, Biometrics & Fingerprints — White Castle facing a fine of $17B for violating privacy of employees with fingerprint scanner. On February 17, 2023, the Illinois Supreme Court held that each scan or transmission of a person’s biometric identifiers is a separate violation of Illinois’ Biometric Information Privacy Act (BIPA). In Cothron v. White Castle System, Inc., 2023 IL 128004, the plaintiff was an employee at a White Castle restaurant. She alleged that White Castle, without obtaining the statutorily mandated consent, required her to scan her fingerprint multiple times each day to access company systems. The plaintiff argued that each scan since BIPA’s enactment in 2008 was a separate violation. White Castle argued that if any violation occurred, it was a single violation in 2008, when it first collected her fingerprints without obtaining proper consent. Thereafter, White Castle argued, each new scan was not a new “collection” of her fingerprints. By a 4-3 majority, the court agreed with the plaintiff that each scan was a separate violation. National Law ReviewWhite Castle could face multibillion-dollar judgment in Illinois privacy lawsuit,
    • Related:  Repeated Violations Doctrine
    • Nearly 2,000 lawsuits alleging violations of BIPA have been filed since 2017, yielding a series of massive settlements and judgments. Amazon, Facebook and others.
  • January 2023
    • Voice Recognition — Whole Foods Reaches $300k BIPA Settlement Over Voice Recognition Lawsuit — Whole Foods has reached a $297,000 settlement in a lawsuit filed under Illinois’s Biometric Information Privacy Act (BIPA). The lawsuit alleged that Whole Foods enrolled distribution center workers in a voice recognition system without properly obtaining consent and providing the necessary disclosures as required under BIPA. The settlement, which has received early approval from a state court judge, would see $545 paid out to each of the class action’s 330 workers.

ADA – Whole Foods SCO Review

Amazon Whole Foods Self-Service

We shop at Whole Foods from time to time. Part of our Costco-WholeFoods equation.

Seemed like a good time to “check out” the SCO there and the return lockers.

Notes on the SCO

  • Modified unit from NCR (same as Walmart)
  • No cash (unlike Walmart)
  • We didn’t have a chance to test while in wheelchair and do the measurements.
  • They have an “Accessibility Mode” which you can select but other than bring up the diamond navigation there is no audio. Perhaps there is a headphone jack we missed.
  • The diamond nav does tab between interface options but there was no audio. There is an audio button and we made sure volume all the way up but nothing.
  • Additional Comments by TaylorPOS —
    • The measurements matter but reach and range (only) are what have been the very problems forever.   Those NCR’s POS readers are way out of use for wheelchairs and highly probable for a lot of little people.
    • It also does not comply with PCI-POI (“must be able to PIN shield using the body”.  As well as ADA 302.8 limited reach and strength and 508 (ICT) 302.2 aka: ADA Visual Accommodation.
    • Seriously, these mfg’s and businesses including IT dept are just clueless to accessibility being correctly provided.
    • The reasons for ADA 309 and 309.4 are in place for very good reasons.
  • Comments from accessibility expert
    • That NCR SCO is a really poor example of how to tackle accessibility isn’t it??! If I had a ‘rogues gallery’ of horribly designed SCOs, I’d be adding that to it. I saw KIS’s returns kiosk at the NRF Show and it looked really slick, I must start looking out for them. I haven’t been to a Whole Foods for a while, but maybe I’ll stop by one when I’m out and about at the weekend.
  • Comments from NCR
  • Comments from Whole Foods


Whole Food Self-Check Out SCO

Whole Food Self-Check Out SCO



The Drop Off Return Locker

  • Nice unit and it was very busy.
  • Returning multiple items took very few minutes.
  • Seemed like some customers tried to open locker before time
  • We watched multiple customers and given the “Pick you Satisfaction” level review at the end they all opted for Very Satisfied.
  • Eventually the locker ran out of space and took itself offline.
  • Definitely free’s up the customer service people to deal with other issues
  • See full post on Amazon Dropoff and Return Lockers
amazon drop off locker

click for full size – amazon drop off locker

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VISA Swipe Fees up 180% – Advocate for Reform

NRF Swipe Fee Reform

Small business is by far the hardest hit since they are the lowest volume. Rates went up 26% in the last 12 months and 180% over the last decade.  Monopolies do not exist for the benefit of consumers and lower inflation. Visa and Mastercard, which control 80 percent of the U.S. credit card market, centrally price-fix the swipe fees charged by banks that issue their cards even though many legal experts say the practice violates federal antitrust law.

Example case

“As the use of credit cards has become more and more prevalent, the credit card companies are making more and more money from merchants. When we first opened our business, credit card transactions accounted for approximately 40 percent of our business. Now the credit card share is about 80 percent of transactions. At the same time, fees have risen and the time taken before funds appear in our accounts gets longer. This is one more burden for merchants.”
John Morman, owner of Celtic Tides gift shop, Lexington, Va.

2023 NRF Small Business Fly-in
July 11-12, 2023
Grand Hyatt, Washington, D.C.

The National Retail Federation is convening 50 small retailers in Washington, D.C., at the 2023 Small Business Fly-in on July 11-12, 2023. Attendees will focus on improving competition in the credit card payments system for retailers. They will learn about legislation and regulatory processes to address payments competition and share their stories directly with lawmakers. Attendees will be able to connect with fellow small retailers from across the country.

We encourage small businesses to sign up to advocate with us. NRF is pleased to be able to provide a limited number of travel scholarships to cover transportation and lodging for selected small business owners. Apply today using our application linkThe application closes April 28, 2023.

Why attend?

Attendees will advocate for swipe fee reform and encourage Congress to support the Credit Card Competition Act (CCCA). This bipartisan bill will address the broken and unfair credit card market that’s currently dominated by two major players that set the fees and terms with which all merchants must comply. Lack of competition means credit card swipe fees continue to rise year after year, soaring 25% last year alone.

The bipartisan Credit Card Competition Act would infuse competition into the marketplace by simply requiring there be at least two competing processing networks enabled on each credit card. These reforms have the potential to save American businesses and consumers an estimated $11 billion per year.

We are convening small retailers to share their stories on how excessive swipe fees stifle growth and expansion for small businesses and make it difficult to invest in their companies by hiring more staff, buying more inventory, competing on price and even keeping their doors open in today’s uncertain and inflationary economic climate.

 I hope you’ll consider applying today. If you have any questions, don’t hesitate to contact me.


Meghan Cruz
Senior Director, Grassroots Advocacy
National Retail Federation
Direct: 202-626-8151
Cell: 937-474-3824

NRF forecasts 2023 retail sales will grow between 4% and 6% reaching more than $5.13 trillion. Learn more.

ANSI Roadmap for Electric Vehicles Released for Comment

ANSI EV Standards and Codes Draft Released

New York, March 31, 2023: The American National Standards Institute (ANSI) released today for public review and comment a draft of the Roadmap of Standards and Codes for Electric Vehicles at Scale developed by the Institute’s Electric Vehicles Standards Panel (EVSP). The roadmap identifies key safety, performance, and interoperability issues; notes relevant published and in-development standards; and makes recommendations to address gaps in codes and standards. This includes recommending pre-standardization research and development (R&D) where needed. It also proposes prioritized timeframes for when standardization work should occur and standards developing organizations (SDOs) or others that may be able to lead such work. Working groups have been developing the draft roadmap since a kickoff event held in June 2022.

Comments Invited by May 1, 2023

The request for comment specifically invites comments that represent critical revisions and needed clarifications on the roadmap content. Comments on the draft roadmap may be submitted to [email protected] by close of business on Monday, May 1, 2023. Use of the comment form (see below) is required to better manage and review comments. The EVSP working groups are currently on hiatus and will reconvene in May to address the comments submitted and finalize the document for publication by the end of June 2023. While all comments are welcome, the EVSP reserves the right to hold disposition of comments in reserve for a future iteration of the document if they cannot be addressed within the time available. This might include, for example, comments on the document’s organization, or issues not addressed.

The draft roadmap and related materials may be downloaded as follows:

Building on ANSI EVSP roadmaps developed in the 2011-14 timeframe, the draft document seeks to describe the current and desired future standardization landscape that will support and facilitate EVs at scale. The roadmap’s primary focus is on light duty, on-road plug-in electric vehicles (PEVs) that are recharged via a connection to the electrical grid, as well as the supporting charging infrastructure needed to power them. Medium and heavy-duty EVs are also covered. Topics covered include standards to address high power DC charging, storage (i.e., microgrid, distributed energy resource management systems) integrated with DC charging, vehicle grid integration, high power scalable/interoperable wireless charging, and vehicle-oriented systems. The broad target audience includes vehicle manufacturers, entities that will be installing and operating charging infrastructure; SDOs; U.S. federal, state, and municipal government agencies; electric utilities; and others.

To advance the Biden Administration’s goal for a clean energy future, the U.S. Department of Energy (DOE) Office of Energy Efficiency & Renewable Energy (EERE) Vehicle Technologies Office (VTO) issued a June 2021 lab call funding opportunity announcement. The lab call included a pillar on codes and standards with the goal to “identify and address challenges and barriers to the integration of [email protected] charging with the grid created by uncoordinated development of codes and standards and the rapid advances in vehicle and charging technologies.” An [email protected] lab consortium was formed in response with Argonne National Laboratory (ANL) as the lead lab for the codes and standards pillar supported by other national labs. The consortium committed to develop a 2022 roadmap like earlier roadmaps developed by the ANSI EVSP.

The [email protected] effort supports funding initiatives associated with deploying a nationwide EV charging infrastructure, including the National Electric Vehicle Infrastructure (NEVI) Formula Program, which provides $5 billion in Federal money to that end. As part of the Bipartisan Infrastructure Law, the Federal Highway Administration was directed to release a set of minimum standards and requirements for the implementation of the NEVI program. The NEVI Final Rule was issued on February 28, 2023, and appropriate references are included in the EVSP roadmap.

ANSI serves as administrator and coordinator of the U.S. private-sector voluntary standardization system. As a neutral facilitator, the Institute has a successful track record of convening stakeholders from the public and private sectors to define standardization needs for emerging technologies and to address national and global priorities. The ANSI EVSP is a cross-sector coordinating body whose objective is to foster coordination and collaboration on standardization matters among public- and private-sector stakeholders to enable the safe, mass deployment of electric vehicles and associated infrastructure in the United States with international coordination, adaptability, and engagement.

The ANSI EVSP does not develop standards. Rather, it serves as a forum for facilitating coordination among SDOs and others. ANSI’s facilitation of the EVSP is partly supported by VTO/ANL and UL Standards & Engagement.

“Standards and related conformity assessment programs have an important role to play in advancing electric vehicle technologies. ANSI invites all affected stakeholders, regardless of geographic location, to review the draft roadmap and make their views known,” said S. Joe Bhatia, ANSI president and CEO.

For more information, visit the EVSP webpage www.ansi.org/evsp or reach out to ANSI staff: Jim McCabe, senior director, standards facilitation ([email protected]; 212-642-8921), or Christine Bernat, associate director, standards facilitation ([email protected]; 212-642-8919).

About ANSI

The American National Standards Institute (ANSI) is a private non-profit organization whose mission is to enhance both the global competitiveness of U.S. business and the U.S. quality of life by promoting and facilitating voluntary consensus standards and conformity assessment systems, and safeguarding their integrity. Its membership is comprised of businesses, professional societies and trade associations, standards developers, government agencies, and consumer and labor organizations.

The Institute represents and serves the diverse interests of more than 270,000 companies and organizations and 30 million professionals worldwide. ANSI is the official U.S. representative to the International Organization for Standardization (ISO) and, via the U.S. National Committee, the International Electrotechnical Commission (IEC). For more information, visit www.ansi.org.


Kiosk Industry participates in three of the EV working groups and has assisted in development.

The KMA Kiosk Manufacturer Association is an Associate Sponsor of the ANSI EV Committee

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Section 508 Report to Congress and President

section 508

Section 508 Report 2023

This report looks at CFO Act Agencies and their progress or lack of in web conformance.

In Brief Summary

  • PDFs are still a problem with only 30% of pdfs accessible
  • 14% of agencies do not test intranet pages
  • Only 2 agencies consider themselves “Measured” in all five maturity areas (e.g. FCC and SEC)
  • Conforming pages increased 0.6%
  • Non-conforming increased 13%
  • 90% (58 agencies) have an accessibility statement
  • Among the “top 10 downloads,” 77% were PDFs
  • Among the PDF documents, 20% were conformant
  • Among the 57% non-conformant PDFs*
    27% were found to contain at least one issue
    73% of the PDF documents were untagged
section 508 program maturity

section 508 program maturity


Section 508 Report to the President and Congress: Accessibility of Federal Electronic and Information Technology

The Department of Justice and the General Services Administration submit this Section 508 Report to the President and Congress: Accessibility of Federal Electronic and Information Technology to Congress and the President pursuant to the reporting requirement in 29 U.S.C. §794d(d)(2).

Section 508 of the Rehabilitation Act requires federal agencies to ensure that their information and communication technology (ICT) is accessible to people with disabilities unless certain exceptions apply. Specifically, Section 508 requires federal agencies to ensure that ICT they develop, procure, maintain, or use allows employees with disabilities and individuals with disabilities who are members of the public to have access to and use of information and data.

This access should be comparable to that available to employees and members of the public without disabilities.1

Section 508 requires the Attorney General to submit to the President and Congress reports containing information on and recommendations regarding the state of federal department and agency compliance with Section 508.2 The last such report was submitted by the Department of Justice in 2012. Since 2013, however, the Office of Management and Budget (OMB) and the
General Services Administration (GSA) have led a program to track federal agency efforts to maintain accessible ICT and improve management of Section 508 programs. Beginning in December 2013 and continuing every six months thereafter, GSA has collected and analyzed data provided by all 24 Chief Financial Officers (CFO) Act federal agencies, which are required to participate, as well as additional agencies that choose to participate, concerning the accessibility of their ICT.3 The Department of Justice and GSA have worked together to submit this report based on data from February, 2021 through August, 2022 that was collected and analyzed by GSA.

Here is the download link for full document

2023 section_508_report_to_the_president_and_congress_2023-compressed

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WCAG 2.2 Checklist – Draft

WCAG Standard image

WCAG 2.2 Checklist

Noted on W3C website – What’s New in WCAG 2.2 – Interesting inputs from “personas” and navigating a website. Typical “disabilities” include repetitive stress injury, low contrast for seniors. Repetitive stress injury persona using speech recognition software, hand tremors, supermarket user with cognitive disorder. Thanks to William Goren.

For an introduction to Web Content Accessibility Guidelines (WCAG) and more about versions 2.0, 2.1, and 2.2, see the WCAG Overview.

WCAG 2.2 is scheduled to be completed and published in April 2023. Current versions:

Changes from WCAG 2.1 to WCAG 2.2.

  • 2.4.7 Focus Visible is changed from Level AA in WCAG 2.1 to Level A in WCAG 2.2.
  • 4.1.1 Parsing is obsolete and removed from WCAG 2.2. More information is in the WCAG 2 FAQ.
  • The WCAG 2.2 Draft provides 9 additional success criteria from WCAG 2.1. They are included on this page.
Page Contents

ADA Canada – CSA Standards for Interactive Devices Updated

ADA Canada

Accessible design for self-service interactive devices including automated banking machines

CSA of Canada released their updated B651 standards in December for Canada. It applies to self-service interactive devices including ABMs and ATMs.  It is aimed at banks and is a close representation of what the modern ABMs in Canada incorporate (compared to 2009). Updating the standards to reflect better what is deployed. The 2009 set of standards had IBM as the chair. 2022 has Diebold as Chair.  Not often you see Swipe readers in banking these days.

The title seems inverted. Maybe should be — Accessible design for ABMs and including self-service interactive device


  • The standards are free to download. Here is the link
  • For reference ATMIA has an ADA document for accessibility. Last updated in 2017 and accessible for members only.
  • The ADAtile site has good references to ADA Canada, and we almost used their graphic.

Summary Points

  • Committees have one industry person (non-voting) for ATMs who also serves as Chair for Subcommittee.
  • A couple of banks are represented
  • Word Counts
    • 75 – Key (includes keypad, key, keyboard, etc)
    • 35 – Audio
    • 31 – Self-Service
    • 30 – Reader (swipe, dip, barcode, etc)
    • 28 – Voice
    • 22 – Tactile
    • 15 – Touch
    • 9 – Privacy
    • 9 – Contactless
    • 8 – Braille
    • 7 – ABM & ATM
    • 6 – Biometrics
    • 1 – kiosk
    • 1 – enclosure (stability)
    • 1 – WCAG (Contrast Requirements)
    • 1 – Screen Reader
    • 1 – Mobile
    • 0 — Bitcoin
    • 0 – *attended*. We were looking for definitions of self-service and “unattended”. Europe adds “semi-attended” to attended and unattended self-service for example
    • 2 – recommend* – just knee and toe space for ABM


More than one in five Canadians aged 15 and over — an estimated 6.2 million people, or 22% of the adult population — has one or more disabilities (S. Morris, G. Fawcett, L. Brisebois and J. Hughes. November 2018). The highest rate of disability occurs in the age group 75 and over, where almost one-half of men and women report a disability.

Statistics Canada reports that the median age of Canada’s population continues to climb, with the average age of Canadians reaching 41.7 years (Statistics Canada, 2021), the median age is one of many indicators that signifies the December 2022 population is aging. It is expected that the proportion of people aged 65 and over will continue to increase, with the advancing age of the large baby boomer cohort. Shifts in population size within various age groups have far-reaching social,  economic, and policy impacts. The number of individuals within an age group has a profound effect on the demand for products and services. People with disabilities and older people are coalescing as an economic and social force and constitute a significant portion of the consumer market. Therefore, it makes good business sense to increase access for all customers.


Accessibility is an important consideration in the design of products, systems, environments, and facilities because it affects usability for people with the widest possible range of capabilities. Many accessibility features benefit those who do not have a disability by enhancing usability and providing possibilities for customized design. For example, taking into account the needs of people who are partially sighted helps all users trying to read a display in poor lighting conditions or without their reading glasses. Involving users with a range of abilities during the design and development phase can reduce development time and costs and ensure the early detection of problems, thus avoiding expensive redesign. Improvements implemented during the design phase are less costly than those implemented after production.

Accessible design also helps organizations and businesses develop or maintain global markets by making their products compliant with legal accessibility requirements in force in other countries. For example, accessible design is a requirement for acceptance into the U.S. market (e.g., under the Americans with Disabilities Act of 1990 and Section 508 of the Rehabilitation Act of 1973). Accessible design is also covered by European Commission Mandates M/273 and M/283.


This Standard specifies technical requirements applicable to the design, manufacture, site preparation, and installation of self-service interactive devices.

This Standard does not cover
a) physical environment of drive-through self-service interactive devices; and
b) websites and web applications that are beyond the control of the service provider and accessed from public devices.

About this edition

This is the first edition of CSA/ASC B651.2, Accessible design for self-service interactive devices including automated banking machines. It supersedes the second edition of CSA B651.1, published in 2009 under the title Accessible design for automated bank machines, and the first edition of CSA B651.2, published in 2007 under the title Accessible design for self service interactive devices. This new edition of CSA/ASC B651.2 includes the following major changes:
a) consolidation of CSA B651.1 and CSA B651.2, as noted above, into one new standard;
b) updates to the contents of both standards noted above; and
c) improvements to the standard on access to devices.
This Standard is intended to be used in conjunction with CAN/CSA-B651.

Here is the outline for the doc. Begins on page 10 of 80


CSA Technical Committee on Accessibility
CSA Subcommittee on Accessible Design for Self-Service
Interactive Devices and ABMs 11
0 Introduction 16
0.1 Legislation 16
0.2 Demographics 16
0.3 Benefits 17
0.4 Copyright permissions
1 Scope 18
1.1 Purpose 18
1.2 Application 18
1.3 Limitations 19
1.4 Terminology 19
1.5 Alt text 19
2 Reference publications
3 Definitions
4 Design requirements 25
4.1 General 25
4.1.1 Design requirements compliance 25
4.1.2 Language 25
4.2 Functional performance of interactive devices
4.2.1 Instructions 26
4.2.2 Output 26
4.2.3 Important notifications 26
4.2.4 Customization 26
4.2.5 Input 26
4.2.6 Simultaneous access 26
4.2.7 Physical operation of controls 27

5 External and internal access 27
5.1 Parking 27
5.2 Signage 27
5.2.1 International Pictogram of Access
5.2.2 Signs 28
5.2.3 Tactile signs 28
5.3 Exterior route 28
5.4 Interior route 28
6 Lighting 28
6.1 General 28
6.2 User space 29
6.3 Interface panel 29
7 Doors 29
7.1 General 29
7.2 Security access for door entry
8 User space 30
8.1 General 30
8.1.1 Headroom and protruding objects
8.1.2 User operating space 30
8.2 Floor surfaces 30
8.3 Lineup guides 30
8.4 Ambient noise 30
8.5 Waste receptacle 31
9 Installation 31
9.1 Approach and reach 31
9.1.1 General 31
9.1.2 Forward approach clearances
9.1.3 Reach distances 31
9.2 Protruding objects 32
9.2.1 General 32
9.2.2 Protrusion distance 32
9.3 Grab bar 32
9.4 Shelf 32
December 2022

Site installation manuals
10 Hardware components 33
10.1 General 33
10.1.1 Interface 33
10.1.2 Height of controls 33
10.1.3 Biometrics 33
10.2 Enclosure stability 34
10.3 Displays 34
10.3.1 Position of monitors 34
10.3.2 Touch screen displays 34
10.3.3 Privacy filter 34
10.4 Insertion slots 35
10.4.1 Slot location assistance 35
10.4.2 Media insertion orientation 35
10.4.3 Tapering 35
10.5 Card reader 35
10.5.1 General 35
10.5.2 Motorized readers 36
10.5.3 Flatbed document scanners 36
10.5.4 Barcode scanners 36
10.5.5 Swipe readers 37
10.5.6 Dip readers 37
10.6 Dispensers 37
10.6.1 Identification 37
10.6.2 Slot dispenser 37
10.6.3 Tray, pocket, or bin dispensers 38
10.7 Data entry devices 38
10.7.1 General 38
10.7.2 Keys for keypads and keyboards 38
10.7.3 Function keys 40
10.7.4 Audio interface 41
10.8 Contactless identification and authentication
10.8.1 Card or device clearance 41
10.8.2 Indication of location 42
11 Software42
11.1 General 42
11.2 Colour contrast 42
11.2.1 Contrast requirements 42
11.2.2 Colour coding 42
11.3 Input/control devices and input feedback
11.3.1 Accidental activation 42
11.3.2 Adjustable time 42
11.3.3 Feedback 43
11.3.4 Confirmation 43
11.3.5 Warning tones 43
11.3.6 Warning information 43
11.4 User options 43
11.5 Audio output sequence 43
11.6 Dynamic display of information 44
11.6.1 Long text 44
11.6.2 Background 44
11.6.3 Advertising 44
11.6.4 Font 44
11.6.5 Written text and instructions 45
11.6.6 Graphics and video 45
11.7 Audio 46
11.7.1 Automatic initiation 46
11.7.2 Order of instructions 46
11.7.3 Frequency 46
11.7.4 Voices 47
11.7.5 Abbreviations 47
11.7.6 Numbers 47
11.7.7 Coordination of information 47
11.7.8 Repeated instructions 47
11.7.9 Advertising 47
11.7.10 Audio interruption 47
11.8 Printed output 47


CSA/ASC B651.2:22
National Standard of Canada

Title: Accessible design for self-service interactive devices including automated banking machines. To register for e-mail notification about any updates to this publication
• go to www.csagroup.org/store/
• click on Product Updates

The List ID that you will need to register for updates to this publication is 2430258. If you require assistance, please e-mail [email protected] or call 416-747-2233. Visit CSA Group’s policy on privacy at www.csagroup.org/ legal to find out how we protect your personal information.

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ADA For Restaurants – Accessible Retail Spaces Webinar

US Access Board Logo


Retail ADA Guidelines

U.S. Access Board Retail ADA Webinar

U.S. Access Board Retail ADA Webinar

The holidays may have passed, but shopping and dining out in the new year continue for many people, including those with disabilities. The Americans with Disabilities Act (ADA) and Architectural Barriers Act (ABA) Accessibility Standards require retail spaces and restaurants to be accessible, from the accessible route at a site arrival point to public entrances to interior spaces of establishments. The next webinar in the U.S. Access Board‘s free monthly series will take place February 2 from 2:30 – 4:00 (ET) and provide an overview of the ADA and ABA accessibility requirements for parking, entrances, queues and waiting lines, food service lines, dressing and fitting rooms, fixed dining surfaces, including bar seating, sales and service counters, and checkout aisles at retail spaces and restaurants. Additionally, Access Board Accessibility Specialists will address frequently asked questions about these spaces and their elements.

Visit Great Lakes ADA Center’s Accessible Retail Spaces and Restaurants webinar webpage for more information or to register. All webinars include video remote interpreting (VRI) and real-time captioning. Questions can be submitted in advance of the session or can be posed during the live webinar. Webinar attendees can earn continuing education credits. The webinar series is hosted by the ADA National Network in cooperation with the BoardArchived copies of previous Board webinars are available on the site.

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KMA at NRF 2023 – Visit 1602

kiosk association kma logo

The Kiosk Association is again exhibiting at NRF 2023 in New York. Here are some preliminary items.


Show Specials

Press Releases


ADA News – Duckworth & Sarbanes Proposal Web Accessibility

web accessibility

Website Accessibility Legislation

A new bill has been introduced regarding website accessibility.  In this article by William Goren from Understanding The ADA he reviews what the bill says and comments as appropriate.


  • Findings: a physical location is no longer required. Therefore, this legislation adopts the approach of the cases saying that title III websites must be accessible to persons with disabilities if what is going on is of the type in 42 U.S.C. §12181(7).
  • Definitions: WCAG is not mentioned but the principles of WCAG underpin the definition of accessible and accessibility.
  • Definitions: the Architectural Accessibility Board has issued a notice of proposed rulemaking regarding kiosks. It is not clear how this legislation affects that rulemaking. Of course, there is no guarantee that this legislation will ever turn itself into law or what the final legislation may look like.
  • Definitions: §3(5) notably does not use the term, “place of public accommodation.” It is quite clear that §3(5) is talking about entities covered by title I, title II, title III, and §309 of the ADA.
  • Access to Websites and Applications: §4(1) is a clear reference to the DOJ title II and title III effective communication rules. It remains to be seen whether the title III approach, interactive process with the entity making the final call, or the title II approach, primary consideration rule, is what the regulators push.
  • Enforcement: interesting question as to whether compensatory damages would include emotional distress, especially after Cummings. It would appear from this legislation that the intent is that emotional distress damages are available.
  • Recommendations: it is unclear, from a literal review of the Act, whether there are two separate advisory committees or just one. Logically, you would think there would be two separate committees but that is far from clear. See §8(5) below.
  • Rules of Construction: not sure why §501 of the Rehabilitation Act is missing from §11(1).
  • Effective Date: elections are coming up shortly. Regardless of your political persuasion and beliefs, go out and vote. Very unclear as to how this bill will proceed regardless of who takes the majority in each house of Congress because disability is not a partisan issue. Also, many constituencies are not at all happy with the wild West of Internet litigation that currently exists. All of this makes it very interesting to follow the course of this bill in the future.
  • Here is the full article
  • Editors Note:  includes computers and peripheral equipment, information kiosks and transaction machines, telecommunications equipment, customer premises equipment, multifunction office machines, software, applications, websites, videos, and electronic documents.
  • Editors Note: The term “application” means software that is designed to run on a device, including a smartphone, tablet, self-service kiosk, wearable technology item, or laptop or desktop computer or another device, including a device devised after the date of enactment of this Act, and that is designed to perform, or to help the user perform, a specific task.
  • Editors Note: employee guidelines focus on job application, not normal operation of devices needed to perform job.

Photo of William GorenWilliam Goren

William Goren is one of the country’s foremost authorities on the American with Disabilities Act (ADA) and the Rehabilitation Act of 1973. Since 1990, he has been advising on ADA compliance as both an attorney and professor—of which during his time as a…

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