This report covers the accessibility of your kiosk's software interface: screen layout, navigation flow, touch interaction patterns, text rendering, contrast, alternative input modes and assistive technology compatibility. The physical hardware requirements of Annex I Section I of Directive 2019/882 — such as reach ranges, physical controls, Braille markings and audio output jacks — require a separate hardware accessibility assessment that EAA-Report does not provide.
The regulatory pressure your European client is passing to you
Self-service terminals are explicitly listed in Article 2.1(b) of Directive 2019/882. The Directive covers payment terminals, ATMs, check-in machines, information kiosks, interactive displays and ticketing machines. Since 28 June 2025, every new terminal placed on the EU market must meet the accessibility requirements of Annex I. In Germany, the BFSG enforces this with fines up to €100,000 per violation.
Your European client — the operator or deployer of the kiosk — is the entity legally responsible under the Directive. But the first thing they do is turn to their software vendor and say: prove that the interface meets the standard. That vendor is you.
What the EAA requires from kiosk software interfaces
Perceivable content
All information must be presentable in at least two sensory channels. Text alternatives for non-text content, sufficient colour contrast (minimum 4.5:1), content not relying solely on colour.
Operable interface
All functions must be operable without fine motor precision. Single-pointer input, keyboard-equivalent navigation. EN 301 549 adds requirements for timed interactions.
Understandable flow
Form fields must have visible labels, error messages must identify the field and suggest correction, navigation must be consistent across screens.
Robust compatibility
Software must expose UI elements through accessibility APIs. Screen readers, switch devices and refreshable Braille displays must be able to interact with the interface.
What you receive: the structured accessibility self-assessment
Cover page
Global compliance score, verification reference, date of assessment.
Service identification and evaluation scope
Software product, deployment context, evaluation method, applicable legal framework.
Criterion-by-criterion evaluation
17 WCAG 2.1 AA criteria evaluated across four principles: Perceivable, Operable, Understandable, Robust.
W3C remediation guidance
Actionable fixes per failed criterion from W3C Understanding WCAG 2.1.
Accessibility statement
Structured declaration following Annex V of Directive 2019/882.
Legal basis and scope disclaimer
Cites Directive 2019/882, EN 301 549 V3.2.1 and applicable national transposition law.
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What it costs
Three common mistakes kiosk software developers make
"That's the hardware vendor's problem, not ours"
Under the Directive, the operator is responsible for the complete terminal. But your client's first move is to demand proof from each vendor. If you cannot produce a documented assessment, your client will either delay deployment, switch vendors, or hold you contractually liable.
Kiosk software tested exclusively with touchscreen interaction
WCAG 2.1.1 requires that all functionality be operable through a keyboard interface. Many kiosks support external keyboards or switch devices via USB or Bluetooth. If your software cannot be navigated without touch, it fails the operable principle entirely.
Adding an accessibility overlay widget instead of documenting compliance
Overlays do not constitute a documented assessment. EN 301 549 requires a structured evaluation against specific success criteria — not a JavaScript widget. Your European client's compliance team knows the difference.
Enforcement reality
The fines below apply to your European client. Your client will pass the consequence upstream to you through contract liability or vendor replacement.
BFSG. Up to €100,000 per individual infringement.
Law 11/2023. Very serious infractions from €90,001.
Ordonnance 2023-859.
Implementatiewet. Up to €900,000 or 1-10% of annual turnover.
What EAA-Report guarantees and what it doesn't
EAA-Report generates a document structured under Art. 13.2 of Directive (EU) 2019/882 based on the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as the service provider or software vendor.
We guarantee that the document structure follows Art. 13.2 of Directive (EU) 2019/882 and that the legal references cited are correct as of the latest verification date. We do not guarantee that a specific document will be accepted by a market surveillance authority in a specific case, nor by a commercial buyer in a procurement process.
EAA-Report is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.
Frequently asked questions — kiosk software developers
Does this report cover the hardware accessibility requirements too?
My client is in Germany. Does this report satisfy the BFSG?
I'm based outside the EU. Am I directly obligated?
Can I generate one report for all deployments?
How long does it take?
Is this a certified audit?
⚠️ Important notice: EAA-Report is a self-assessment documentation tool, not legal advice and not a third-party audit. The document is generated from your input data. You are responsible for the accuracy of the data you provide. EAA-Report does not replace a qualified professional assessment.
Official legal sources
- Directive (EU) 2019/882 — European Accessibility Act — full text