Last Updated on August 29, 2026 by Craig Allen Keefner

Table of Contents

And the One You Can Build To Right Now

The Access Board’s self-service kiosk rule was pulled from OMB in January 2025. Here is why that changes less than you think, and what to specify in the meantime.

The Industry Group | Summer 2026 | kioskindustry.org

Every kiosk RFP that has crossed my desk in the last eighteen months contains some version of the same sentence: “Supplier shall comply with all applicable ADA requirements.”

That sentence is doing no work at all. There is no kiosk-specific ADA technical standard. There was very nearly one. Then it stopped.

Here is where things actually stand, and — more usefully — what to specify instead. The reason I ask is we have meeting with the US Access Board September 15. Send your thoughts for me to share to craigkeefner@pm.me

What happened to the SSTM rule

On September 21, 2022, the U.S. Access Board issued an Advance Notice of Proposed Rulemaking to supplement the ADA and ABA Accessibility Guidelines with scoping and technical requirements for self-service transaction machines and self-service kiosks. The scope was broad and recognizable: retail and grocery self-checkout, point-of-sale terminals, airport and hotel check-in, restaurant ordering touchscreens, healthcare check-in, DMV terminals, automated parcel lockers, and video-display vending machines with touchscreen navigation.

Roughly 80 comments came in. Board staff analyzed them, drafted a Notice of Proposed Rulemaking, produced a Preliminary Regulatory Impact Analysis and an Initial Regulatory Impact Analysis, and sent the package to the Office of Management and Budget for interagency coordination under Executive Order 12866.

Then, per the Board’s own FY 2027 Budget Justification: the draft NPRM was withdrawn from OMB in January 2025, shortly after the change of administration. The SSTM rulemaking does not appear in the Board’s FY 2026 or FY 2027 rulemaking plans. There is no projected date for resubmission, proposal, or final rule.

It was not singled out. The Board moved its electric vehicle charging station rulemaking, its rail vehicle rulemaking, and its passenger vessel rulemaking to inactive status on September 4, 2025. Separately, on September 11, 2025, DOJ announced it would not pursue 54 pending regulatory actions, including the ADA rulemakings on accessible equipment and furniture and on accessible routes in public areas, citing the fiscal-year regulatory cap in Executive Order 14192.

So the practical situation for anyone deploying kiosks: the rule that would have given you a safe harbor is gone, and nobody can tell you when or whether it comes back.

Why that is not the relief some vendors think it is

I have heard “the rule got killed, so we’re fine” more than once this year. That reading is backwards.

A technical standard is not primarily a burden on a deployer. It is a defense. It tells you exactly what to build, and when you build it, you have a documented, citable basis for saying you did the right thing.

Remove the standard and the underlying obligation does not go anywhere. ADA Title III still requires reasonable modifications to policies and procedures where necessary to afford access. Title II still requires that programs, services and activities be accessible. Courts have found liability for inaccessible equipment where no regulation specified anything about that equipment’s dimensions — the well-known example being a hotel bed-height case that survived a motion to dismiss on the reasonable-modification provision alone, with DOJ filing a Statement of Interest supporting the plaintiff.

And in healthcare, there is already an operative kiosk regulation that most of the industry has not fully absorbed. HHS finalized its Section 504 rule on May 9, 2024, effective July 8, 2024. Its kiosk provision, 45 CFR 84.83, reads: no qualified individual with a disability shall, on the basis of disability, be excluded from participation in, be denied the benefits of, or otherwise be subjected to discrimination under any program or activity of a recipient provided through kiosks.

Note what that provision does and does not do. It imposes a duty. It specifies no reach range, no character height, no speech output requirement, no test method. It is purely outcome-based. Which means the operator carries the entire burden of demonstrating that its kiosks actually deliver access — with no spec to point to.

That is a worse position for a vendor than a prescriptive rule, not a better one.

The thing hiding in plain sight

Here is the part I think the industry has underused.

In the 2022 ANPRM, the Board did not just ask questions. It stated, on the record, the technical approach it intended to take. The proposed requirements would be based on the technical requirements for ATMs and fare machines in the ADA and ABA Accessibility Guidelines, combined with the hardware provisions of the Revised Section 508 Standards, particularly those for hardware with “closed functionality.” And the Board noted this approach was similar to the approach taken by the Department of Transportation in its rule on airport self-service kiosks.

The Board also published, in the docket, a side-by-side comparison matrix of the ADA and ABA Guidelines, the Revised 508 Standards, and the DOT airport kiosk rule.

Read that again. The agency told us its destination was, in substance, the DOT airport kiosk rule generalized beyond airports.

That rule — 14 CFR 382.57(c) — is already binding federal law. It went through notice and comment. It has been in force for airport kiosks for over a decade. Vendors already build product lines to it. Test methods for it already exist.

The rule that got shelved is, to a first approximation, sitting on the books in another title of the CFR.

What to specify in the meantime

My recommendation, which The Industry Group is publishing as an interim reference: treat 14 CFR 382.57(c) as the default technical specification for any fixed or built-in self-service kiosk, in any sector.

The headline requirements, all of them already law somewhere:

Physical

Operable without the user attaching assistive technology, except personal headsets and audio loops
Clear floor space per ADA §305 — generally 30 in by 48 in minimum, measured as installed, including queue rails and bagging shelves
All transaction-critical controls, card reader, printer, scanner and dispensing slots within ADA §308 reach ranges
One-hand operation, no tight grasping, pinching or twisting, 5 lbf maximum activation force per ADA §309.4

Controls

Operable parts tactilely discernible without activation; at least one tactile control per function
QWERTY layout with tactilely distinct “F” and “J”; 12-key numeric layout with tactilely distinct “5”
The five function-key tactile symbols: raised circle for Enter, left arrow for Clear, letter “x” for Cancel, plus sign for Add Value, minus sign for Decrease Value
Status indicators discernible visually and by touch or sound
Timed responses: non-visual alert plus a way to request more time
Color never the sole means of conveying information — and neither are audio cues
Biometrics never the sole means of identification unless two options using different biological characteristics are offered

Speech

Speech output covering instructions, orientation, prompts, input verification, error messages, and everything needed for full use
Delivered through an industry-standard connector or handset
Masking characters spoken as “asterisk,” not as beep tones
Pausable, repeatable, and auto-interrupted when a new transaction is selected
Receipt and ticket content spoken where needed to complete or verify the transaction
Braille instructions for initiating speech mode, per ADA §703.3, in contracted braille

Volume

User volume control with automatic reset to default after every use
Speaker output amplifiable to at least 65 dB SPL, with at least 20 dB above ambient user-selectable where ambient exceeds 45 dB SPL

Worth a footnote for the specification writers: the Board removed those decibel figures from the Revised 508 final rule and kept only the auto-reset requirement. They survive in the DOT rule. Keep them. They are the only quantified volume targets in any kiosk regulation, and quantified means testable.

Display

Screen visible from a point 40 in above the center of the clear floor space — test this seated, not standing
3/16 in minimum cap height, sans serif, 3:1 minimum contrast, verified under the site’s real ambient and glare conditions
Captioning for multimedia whose audio is necessary to comprehension
Screen tilt is not required. The Board considered adjustable viewing angles and declined after eight commenters objected on prescriptiveness, maintenance and cost grounds. Treat tilt as one way to pass the 40-inch test, not an obligation

Privacy and outputs

Equal privacy of input and output; where screen blanking is offered in speech mode, it blanks on user command, never automatically
Tactilely discernible orientation for tickets, passes, fare cards and keycards

Payment

The Board asked whether card-accepting kiosks should be required to support contactless. It never answered. Support it anyway, and never make card insertion and orientation, touchscreen signature, or screen-only PIN entry the sole payment path

On scoping, briefly

The Board asked how many units at a location should be accessible. It never answered that either.

The industry position I would advocate: all fixed or built-in units.

Percentage-based scoping fails for kiosks in ways it does not fail for parking spaces. Queue routing, load balancing, peak-hour closures and unit-level outages mean the designated accessible unit is very often the one that is roped off or down. And the economics cut the same direction — accessibility is designed into a platform, not bolted onto a unit, so maintaining two SKUs, two software builds, two service procedures and two training programs costs more than building one accessible fleet.

Where an existing estate cannot get there immediately: at least one accessible unit per bank per function, never the first unit taken out of service, included in uptime SLAs, staff assistance documented as a backstop rather than a substitute, and a published remediation schedule tied to the normal refresh cycle.

The clause to put in your next RFP

Supplier warrants that each fixed or built-in self-service unit delivered under this agreement conforms to the technical accessibility specifications of 14 CFR 382.57(c), to sections 305, 308, 309 and 703.3 of the 2010 ADA Standards for Accessible Design, and to the hardware provisions of the Revised Section 508 Standards at 36 CFR part 1194, appendix C, chapter 4, including the provisions for hardware with closed functionality. Supplier shall deliver, prior to acceptance, an accessibility conformance report identifying each provision, its conformance level, and the test method used. Supplier shall maintain conformance across software updates for the term of the agreement and shall not remove or degrade an accessibility feature in a software release without prior written notice and an agreed remediation plan.

Two things that clause is deliberately doing.

First, software regression protection. In the field, the common failure is not a kiosk that shipped without speech output. It is a kiosk that had working speech output until a UI refresh broke it. Tie conformance to ongoing maintenance, not just acceptance.

Second, third-party layers. Payment applications, loyalty modules, age verification and advertising overlays usually come from someone other than the kiosk OEM, and that is usually where accessibility ends. Require the same conformance from every layer the customer touches.

The thirteenth test

We publish a thirteen-point field acceptance checklist alongside this piece. Twelve of the items are measurements.

The thirteenth is this: have one tester complete a full transaction with the screen covered.

That single test finds more defects than the other twelve combined, and it costs nothing.

What is still open

The unresolved issue nobody has solved, and which the shelved rule would not have solved either: the standard governs hardware, and the barrier is increasingly software. The Board’s own record treats closed functionality as a hardware question. A kiosk that is dimensionally perfect and runs an inaccessible ordering app is an inaccessible kiosk. Any credible industry position has to say so out loud.

Channels that remain open while rulemaking is paused:

The Board’s technical assistance helpline, 202-272-0080, and ta@access-board.gov, weekdays 10:00 a.m. to 4:00 p.m. ET. ICT questions to 508@access-board.gov. Assistance is confidential. The limit is real: staff can interpret standards that exist, not supply the contents of a withdrawn draft
Technical guides covering Chapter 7: Communication Elements and Features — including ATMs and fare machines — are being finalized for release in FY 2026, with Chapter 9 guides covering check-out aisles and sales and service counters beginning development. This is the nearest thing to new federal kiosk-adjacent guidance in the pipeline, and worth watching closely
Quarterly Board meetings with public sessions: virtual October 26–28, 2026; virtual January 25–27, 2027; Nashville April 13–15, 2027; Washington, DC July 26–28, 2027
Consensus standards, which are the most productive route right now. ICC A117.1-2026 already added provisions for self-service checkout counters. The Access Board holds voting membership on the A117.1 committee, and comments and proposals are accepted continually. A consensus standard is not a federal regulation and is not subject to the regulatory cap
Petitions for rulemaking under the Administrative Procedure Act, 5 U.S.C. §553(e). Any interested person may petition an agency to issue, amend or repeal a rule. A petition creates a docketed record even where it does not produce a rule

TIG Intel Insight: The Shelved SSTM Rule

Author: Craig Allen Keefner

Extract: The Access Board’s withdrawn kiosk rule was explicitly modeled on 14 CFR 382.57, which means the industry can adopt the substance of the shelved standard today using text that is already binding federal law.

Field basis: I have tracked this docket since the May 2021 public forum, filed and read comments in ATBCB-2022-0004, and work directly with Access Board staff.

Commentary: The reflex in this industry is to treat a dead rulemaking as a reprieve. It is the opposite. What died was the safe harbor, not the liability — and in healthcare, 45 CFR 84.83 already imposes a kiosk duty with no spec attached, which is the worst of both worlds for a deployer. The opportunity here is unusually clean: the agency published its intended approach and pointed at an existing regulation as the model. Voluntary alignment with 382.57(c) is not guesswork. It is the closest thing to compliance-by-anticipation available, and vendors who do it now will be closer to conformance than competitors who waited, whatever eventually issues. The remaining hard problem is that the whole framework is hardware-shaped while the failures are increasingly in the application layer. That gap is ours to close, and no rulemaking pause prevents us from closing it.

Topics: U.S. Access Board, self-service transaction machines, SSTM, ADA kiosk compliance, 14 CFR 382.57, Revised Section 508 Standards, closed functionality, 45 CFR 84.83, ICC A117.1-2026, ATBCB-2022-0004, Executive Order 14192, self-checkout accessibility, unattended retail

Addendum – Voice, Drive Thru and AI

Voice must never be the only way to complete a transaction. That isn’t new — it’s the generalization of rules already in force: color not the sole means, audible cues not the sole means (Revised 508 §411), biometrics not the sole means unless two different biological characteristics are offered. Voice is a channel. Same rule.access-board

Europe already wrote it down. EN 301 549 v4.1.0 has clause 6.4, “Alternatives to voice-based services”. There is no U.S. counterpart for kiosks.cdn.standards.iteh

The strongest single argument

The EU has regulated self-service terminals since June 28, 2025 — the EAA names payment terminals, ATMs, ticketing machines, check-in machines and interactive information terminals explicitly (Accessible.org, Axess Lab). Article 32 gives services until 28 June 2030 and grandfathers existing terminals to end of economic life, max 20 years (Includio).accessible

So every manufacturer selling into Europe is already building to EN 301 549. Its kiosk clauses (5.1 closed functionality, 8.3 stationary ICT reach, 8.4 operable parts, 8.5 tactile indication of speech mode) overlap heavily with 382.57(c) because both descend from the same work. One build satisfies both regimes. “There’s no U.S. kiosk standard so we’re waiting” is a procurement position, not an engineering constraint.

Drive-thru — where I’d be candid rather than reassuring

U.S. case law currently favors operators. In Szwanek v. Jack in the Box the Ninth Circuit held drive-thru-only service doesn’t violate the ADA even where it stops blind people ordering independently, because non-drivers without disabilities face the same barrier; Judge Watford dissented.adatitleiii

But those cases turned on policy. An AI voice agent in the lane is a product — a fixed unattended interface that conducts a transaction, which is nearly the ANPRM’s own definition of a covered device. Products are far harder to defend as facially neutral when the interface itself is the barrier. That shift is the real exposure, and it’s worth saying before someone else says it.

Multilingual — the quiet failure

The Board declined to specify languages in the 508 record but held that if the interface is in another language, speech output must be too, and changed “QWERTY” to “QWERTY-based” for non-English settings. Working rule: parity. Six languages on screen with English-only speech is one accessible language and five inaccessible ones. Two traps to name — a visual-only language menu locks a blind user out before they can choose, and silent fallback to English TTS should be treated as an outage and alarmed on.federalregister

What changed in the files

Guidance doc gained Section 4 (old 4–9 renumbered 5–10), five lettered add-on acceptance tests (A–E), an extended RFP clause requiring disclosure of measured recognition rates for atypical speech plus an EN 301 549 conformance statement, and 11 new sources. Also added: Ontario’s O. Reg. 191/11 s.6, which has required kiosk accessibility for over a decade with a definition broad enough to cover POS devices, Canada’s adoption of EN 301 549 as its ICT Standard (SOR/2021-241), and the DOJ Title II web-rule dates as extended by the April 20, 2026 interim final rule — now April 26, 2027 and April 26, 2028.

Sources

U.S. Access Board, Self-Service Transaction Machines — https://www.access-board.gov/sstm/
U.S. Access Board, FY 2027 Budget Justification and Agency Performance Plan — https://www.access-board.gov/about/cj2027.html
U.S. Access Board, ADA Accessibility Standards — https://www.access-board.gov/ada/
U.S. Access Board, Revised 508 Standards and 255 Guidelines — https://www.access-board.gov/ict/
U.S. Access Board, Technical Assistance — https://www.access-board.gov/ta/
U.S. Access Board, Meetings — https://www.access-board.gov/about/meetings.html
SSTM Advance Notice of Proposed Rulemaking, 87 FR (September 21, 2022) — https://www.govinfo.gov/content/pkg/FR-2022-09-21/pdf/2022-20470.pdf
14 CFR 382.57, automated airport kiosks — https://www.law.cornell.edu/cfr/text/14/382.57
45 CFR part 84, including §84.83 Accessibility of kiosks — https://www.govinfo.gov/content/pkg/CFR-2025-title45-vol1/pdf/CFR-2025-title45-vol1-part84.pdf
Seyfarth Shaw, “Trump Administration Puts the Kibosh on Two Pending ADA Rulemakings,” September 16, 2025 — https://www.adatitleiii.com/2025/09/trump-administration-puts-the-kibosh-on-two-pending-ada-rulemakings/
ICC A117.1-2026 Accessibility Standard, foreword and table of contents — https://shop.iccsafe.org/media/wysiwyg/material/9033S26-TOC.pdf
Congressional Research Service, “Petitions for Rulemaking: An Overview,” R46190 — https://www.congress.gov/crs-product/R46190

This article is industry commentary, not legal advice, and is not guidance from the U.S. Access Board or any federal agency. Requirements cited are existing law; recommendations are labeled as such.

About the Editor

Craig Allen Keefner is editor of kioskindustry.org and manages The Industry Group’s network of self-service, kiosk, digital signage and unattended retail publications. He has tracked ADA and Section 508 accessibility rulemaking for the self-service sector for over two decades. Connect on LinkedIn.

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