EAA Regulation Timelines
There has been some information which appears to say new self service kiosk terminals have until 2030 to be EAA-compliant. From what we can gather that conclusion is not correct. New terminals are subject. Existing terminals have been grandfathered and allowed to operate for an additional 5 years. As usual ATMs in existing deployments get a pass. Probably the banks arranged that.
‘While the deadline to make websites and apps accessible is 2025, the EU has recognised that making self-service terminals accessible to all is a much harder, more complex task, with requirements on both the providers of kiosk hardware, and the software that runs on them. So, deadlines for the accessibility of new terminals are for June 2030.’ — https://kdseurope.com/european-accessibility-act-what-will-it-mean-for-kiosks-and-atms/
We are checking with the governing entity in Europe but we also asked Matt Ater and TPGi for their take. Thanks Matt!
I took another look at Article 32 of the EAA, which covers transitional measures, affecting kiosks/self-service terminals and the services they provide.
Here’s what the article says (I’ve bolded the relevant text for our discussion):
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- Without prejudice to paragraph 2 of this Article, Member States shall provide for a transitional period ending on 28 June 2030 during which service providers may continue to provide their services using products which were lawfully used by them to provide similar services before that date. Service contracts agreed before 28 June 2025 may continue without alteration until they expire, but no longer than five years from that date.
- Member States may provide that self-service terminals lawfully used by service providers for the provision of services before 28 June 2025 may continue to be used in the provision of similar services until the end of their economically useful life, but no longer than 20 years after their entry into use.
In other words, there is an exception for qualifying existing machines used to provide services, whereby they can continue to be used beyond the June 2025 deadline even if they don’t meet EAA requirements.
Per Article 2) of EAA, self-service terminals covered by EAA include:
(b) the following self-service terminals:
(i) payment terminals;
(ii) the following self-service terminals dedicated to the provision of services covered by this Directive:
— automated teller machines;
— ticketing machines;
— check-in machines;
— interactive self-service terminals providing information, excluding terminals installed as integrated parts of vehicles, aircrafts, ships or rolling stock.
But beyond discussing interpretation of the official definition of “placing on the market”, I don’t see anything that provides an extension or exception to EAA requirements for self-service terminals placed on the market after June 28 2025. This recent article by Axess Lab on EAA and kiosks supports that view: https://axesslab.com/ict-a11y-eu/
Hope that helps – and I’d be keen to see any sources that the KDS article might have relied on for their conclusion. It’s possible that there has been lobbying at member state level to reduce the requirements for self service terminals during the transposition process, but I would expect it would be legally impossible to dilute the requirements of an EU directive.
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Matt Ater
Vispero™ | Vice President
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