The CUSS Handbook / Airport self-service terminals and the European Accessibility Act
Airport self-service terminals and the European Accessibility Act
The European Accessibility Act covers selected products and services, including banking services and electronic communications. Airport check-in machines are among the products listed in the European Commission's accessibility guidance.
Application from June 2025
The Act entered into application in the EU on 28 June 2025. The European Commission's announcement, published on 27 June 2025, states that covered products and services must be accessible to people with disabilities from that date.
The Commission gives examples of accessibility requirements ranging from adequate font size to text-to-speech features in self-service payment terminals, e-readers and smartphones. Phones, computers and e-books are also among the products identified in the announcement.
The Act sets common accessibility requirements across the EU. The Commission says this will simplify rules for economic operators that previously faced divergent and often contradictory accessibility requirements across borders. It supports Member States through regular meetings with national contact points, including work on country-specific issues.
Check-in and bag-drop terminals
The Irish Aviation Authority expressly includes self-service terminals for check-in and bag drop in its account of airline accessibility obligations. It states that these terminals and kiosks must meet accessibility requirements, including tactile input and audio feedback where necessary.
The IAA identifies interactive self-service systems as a focus of airline accessibility obligations, alongside digital services, accessible information and training. Airlines must ensure that their services meet the accessibility requirements in the legislation so that people with disabilities can use them.
The Commission's general accessibility guidance recommends that products and services be suitable for people with cognitive disabilities and work with assistive technologies, including voice control and screen readers. These recommendations also apply to accompanying customer support tools and instruction manuals.
The guidance calls for different input and output options, such as keyboard, voice and touch. It recommends a consistent layout and logical navigation, with enough time for users to complete tasks. It also recommends avoiding visuals that could induce seizures, such as flashing content. Additional specific accessibility rules may apply depending on the product or service.
Product conformity evidence
The Commission's guidance on accessibility requirements for products and services calls for a declaration to the authorities confirming that products conform to EU accessibility requirements. The same product list includes ATMs and card payment terminals.
The guidance also calls for a description of the product or service explaining how it meets the requirements. The technical and design procedures used at the manufacturing or production stage must be described too.
Airline responsibilities in Ireland
The Irish Aviation Authority identifies itself as the compliance authority for airlines operating within Ireland under the European Accessibility Act. It is responsible for ensuring that air passenger transport services comply with the Act's accessibility requirements.
When accessibility issues are identified, the IAA verifies whether airlines have taken the necessary corrective actions.