The EAA Is Coming: 5 Steps to Prepare Your Self-Service Terminals

Let’s set the record straight: the EAA isn’t a checkbox. It’s not a one-time task to complete and move on from. Conformance with the EAA means meeting and maintaining accessibility standards throughout the life of your devices.

The EAA is a legal requirement that covers essential products and services, including the kiosks and self-service devices people use every day — ATMs, check-in terminals, ticketing machines, information points, POS systems, and so much more.

As of June 28, 2025, any new kiosks introduced into the market must meet the EAA’s accessibility requirements.

If you operate kiosks in banking, transportation, retail, or public services, this law applies to you. This includes common self-service terminals such as ATMs, check-in machines, ticketing kiosks, and interactive information screens that provide consumer services.

Kiosks already in use before this deadline may continue operating for up to 20 years or until they reach the end of their useful life. But anything new — from hardware design to software interface — must be accessible to people with disabilities from day one.
Compliance requires a long-term strategy — one that spans procurement, design, testing, deployment, and ongoing updates. Treating accessibility like a short-term project risks noncompliance down the line.

To stay ahead of the deadline and avoid a last-minute scramble to fill gaps:

• Assess your current kiosk strategy for meeting accessibility requirements, before hardware is ordered or contracts are signed.
• Adopt conformance with EN 301 549 as a way to meet accessibility requirements, the European standard most closely tied to EAA requirements. (Learn the difference between the EAA and EN 301 549.)
• Document your approach to meeting and maintaining conformance, so you’re ready if an EU monitoring authority requests evidence of compliance.

Don’t assume vendors have this covered — it’s your responsibility to set accessibility expectations from the start. The rest of this roadmap outlines how to do that at every stage, from procurement to deployment.

The surest way to miss the deadline for compliance? Choose a kiosk vendor who treats accessibility as an afterthought.

Under the EAA, accessibility isn’t something you add later. It must be built into the kiosk from the beginning — which means your procurement process needs to demand it upfront from your supply chain.
Whether you’re issuing an RFP or working through preferred vendors, make accessibility a core requirement alongside functionality, security, and cost.

That includes:

• Hardware conformance with EN 301 549 (e.g., tactile controls, reachability, audio output)
• Software that meets EN 301 549 and WCAG 2.1 AA (at a minimum) requirements
• Support for assistive tech like screen readers and tactile navigation
• Physical accessibility features like adjustable height, instructions for using the kiosk, and headphone jacks

Your RFP should also request:

• A statement of accessibility conformance including details of any areas of nonconformance
• Documentation of how accessibility was tested
• Plans for addressing accessibility issues post-deployment

Setting these expectations early makes it easier to hold vendors accountable — and ensures your kiosks are on track for full compliance by June 2025. Explore how to craft an accessible kiosk RFP that helps you meet EAA requirements.

Accessible kiosks aren’t just about what’s on the screen. They’re about how someone approaches, interacts with, and completes a task — physically and digitally.

To meet EAA requirements, both the hardware and the software must support a wide range of user needs. That includes people with mobility, vision, hearing, or cognitive disabilities.

Here’s what to prioritize in your design phase:

Hardware Considerations

• All interactive elements must be within reach for seated users
• Controls should be operable without tight grasping, pinching, or twisting
• Audio output and headphone jacks must be available and clearly marked
• Tactile feedback (e.g., Braille or raised symbols) should identify key input and output components

Software Interface Requirements

• Must be compatible with screen readers and alternative input devices
• Visual elements should meet contrast and text-size guidelines
• Navigation should be consistent, predictable, and keyboard-operable
• Multimedia content must include captions and visual equivalents for audio

For screen reader compatibility, consider JAWS for Kiosk, a version of the globally popular and widely used screen reader, JAWS, which has been adapted for public and private self-service environments. It can be activated automatically when headphones are plugged in and provides a private and seamless nonvisual experience, which is critical for blind and low-vision users.

This kind of intentional, user-centered design is already reshaping high-traffic environments. In the aviation sector, for example, accessible digital kiosks are transforming airport experiences by improving wayfinding, reducing wait times, and helping travelers with disabilities navigate services independently. These real-world examples show what’s possible when accessibility is integrated from the start.

Design decisions made early on will determine whether your kiosks are compliant — and whether they work for all your customers including people with disabilities.

Validating accessibility through real user interaction should be a core part of your development process — especially with a diverse group of users who reflect a range of disabilities and interaction needs.

The EAA calls for products and services to be usable by people with disabilities, not just technically compliant. That’s why usability testing is one of the most important steps in this process.

Involve users with a variety of access needs in research and testing before deployment. Their feedback will help identify what’s working well and also friction points that internal teams often miss. Prioritize input from:

• Screen reader users
• Keyboard-only or switch device users
• People with low vision or reduced color perception
• Wheelchair users and people of shorter stature

Evaluation with users can uncover barriers to successful task completion that may not be easy or possible to spot through manual or automated testing.

You may also discover ways to refine user journeys, making kiosks more intuitive and efficient for everyone, including people with disabilities. And when compliance agencies ask how you validated accessibility, inclusive testing provides the evidence.

Not sure how to begin? Here’s a deeper look at what usability testing is and why it matters, including how it helps the process of creating accessible, user-friendly experiences.

Meeting the EAA deadline is important — but staying compliant over time is what protects your investment.
As kiosks age, software updates roll out, and hardware components wear down, accessibility can drift. The EAA requires that products and services continue to meet accessibility requirements throughout their life cycle, which means you’ll need a long-term strategy.

That strategy should include:

• Regular testing, including with people with disabilities, to ensure that all accessibility features work as expected and to identify any regressions.
• Accessibility reviews of software interface updates before launch, to identify emerging issues, giving you an opportunity to address them before they’re pushed to the kiosks.
• Documented procedures for seeking and acting on accessibility feedback, and for monitoring and addressing changes in accessibility requirements.
• Vendor accountability for maintaining accessibility through patches or hardware replacements. If your kiosks are modular or software-driven, ensure your vendors have the capacity to adapt to new accessibility standards, such as updated versions of EN 301 549 or WCAG.
• Communication channels, to receive and process accessibility feedback, including from users with disabilities.
• Staff training to support accessible development and troubleshooting on-site.

You may wish to seek an external partner to support you in your efforts. And remember: the EAA also requires that organizations maintain evidence of conformance efforts and provide this information upon request. Keeping good documentation isn’t just smart — it’s required.

Don’t Just Meet the Deadline — Lead Through It

The European Accessibility Act gives your organization the chance to improve your customers, or patients, experience when interacting with self-service kiosks — ones that serve more people, reduce friction, and reflect the values of a modern, inclusive business.
By starting early, setting clear expectations, and designing with accessibility from day one, you can avoid costly retrofits and last-minute scrambles. More importantly, you’ll create self-service experiences that actually work for the people who use them.

The path to compliance is clear. The time to act is now.
Whether you’re just beginning to assess your kiosk fleet or actively sourcing new hardware, both imageHOLDERS and TPGi are here to help. Together, we bring deep expertise in accessibility strategy and hardware innovation to guide your journey.

Want to learn more about the EAA and its impact on your self-service kiosk terminals? Download TPGi’s EAA Kiosk Fact Sheet to learn more.