ADA Kiosk Accessibility Multi-Point Checklist – Draft 2024

ADA Kiosk Multi-Point Checklist

With the new regulations coming soon this year, KMA has issued a draft revision of its 17 point ADA checklist. Best advice in plain english.

1. Begin your project updates or initial design phase with accessibility in mind – a developer’s proverb says that you can spend time planning at the beginning or fixing at the end. While you may perform a cost/benefit analysis to guide you, the liability of being inaccessible at this time in history is too great.
2. Separate the ADA considerations into three parts
   1. Hardware Terminal
   2. Application/Interface
   3. Installation

Hardware: ADA Standards for Accessible Design and ICT Accessibility 508 and 255 Guidelines outline specific requirements for ensuring that kiosks are accessible to people with disabilities.

3. Reach Ranges – ensure a sitting or standing persons can access the kiosk.
4. Alternative Navigation and Inputs – operable controls must be tactilely discernible, ex. navigation pad, arrow keys, and other touchscreen alternatives.
5. Audio Jack – plugging in headphones is the standard action that triggers a speech output mode for users who are blind.

Software: accessibility principles for software state that it must be perceivable, operable, understandable, and robust.

6. UI/UIX Design – while WCAG 2.2 is the current standard for web accessibility, many of the guidelines can be applied to kiosk software development, paying particular attention to contrast, errors, focus, labels, and target size.
7. Speech Output Enabled – speech output is required for people with visual impairments, but it also provides ways to support people with other print barriers like dyslexia, low literacy, and language learners.
8. Mobile Proxy – if leveraging a mobile application as an additional means for making self-service accessible, ensure your app meets WCAG 2.2 guidelines.

Added Hardware Devices: kiosks are integrated solutions, meaning there are often many hardware components working together to create the total self-service experience.

9. Devices and Components– can the kiosk user complete every task independently? This includes biometric or other authentications, scanning, transactions, cash in and out, etc.
10. Privacy and Security – confirm a user’s personal information safe when using the kiosk.

Installation: logistical considerations should be made prior to installation

11. Spacing – depth, clearance, maneuverability, protruding objects.
12. Light – the position has been assessed in daylight ensuring the screen can be read and also after dark to assess screen lighting.
13. Sound – can speech output be heard against ambient noise in the location and environment.
14. Temperature – if the kiosk is in direct sunlight are the controls cool enough to touch.

Testing: Conformance and usability testing are paramount to the success of any kiosk project

15. Conformance Testing: should be done by independent accessibility experts – there are many organizations, public and private who perform conformance testing.
16. User Testing – have users with and without disabilities (including deaf and hard of hearing, blind and visually impaired, those with physical disabilities and neurodiversity).

Compliance:

17. Accessibility Audit Log & Development Milestones– KMA recommends companies agree to a full accessibility audit of their software at concept phase of a kiosk development project. In addition to being able to fix known accessibility issues that will create a barrier for accessibility software, organizations who provide accessibility audits will provide you with a log of your accessibility testing outcomes and development targets to provide as proof of intent to comply with accessibility laws to authorities in the case of litigation.

ADA Kiosk Checklist Draft_2024

More Resources

• HHS Section 504 Final Rule Published May 9, 2024 — ADA HHS Section 504 Final Rule 2024-09237-compressed – Excerpt — The comments received covered a wide range of responses on definitions for kiosks. We note that the Access Board is currently engaged in the early stages of rulemaking around self-service transaction machines  and self-service kiosks.128 In part because of the wide range of responses that generally do not agree on a single definition, the Department does not believe it is appropriate to make changes to the definition of kiosks in this rulemaking. A broader definition of kiosks runs the risk of overclassifying devices used in a health or human services setting as a kiosk, while identifying specific types of physical devices could leave out devices that otherwise perform all of the functions normally attributed to kiosks. Because of the range of comments received, and because the Access Board is currently working towards addressing this issue in its own rulemaking, the Department will finalize its definition of kiosks in this rule without change from the proposed rule. Once the Access Board has finalized its rulemaking, the
  Department may consider addressing any additional issues raised with the Access Board’s guidelines.
• ADA Regulations Coming – ADA Accessibility Guidelines
• ADA News – DOJ Title II final rule – Kiosk Industry
• ADA Accessibility Update – U.S. Access Board Timelines
• TPGi ADA ADA
• Dolphin ADA
• Tech For All