Kiosk accessibility: the ADA and guests who cannot tap | Maple Blog

Kiosk accessibility: the ADA and guests who cannot tap

By Maple Team · Published

What the ADA and federal agencies say about restaurant ordering kiosks, the ATM rules used as a benchmark, and a checklist for guests who cannot use a touchscreen.

No federal rule yet sets technical specifications for restaurant ordering kiosks. The ADA still applies: a restaurant is a public accommodation, and it must communicate effectively with guests who have disabilities, including through its kiosks. The nearest published benchmarks are the ADA's rules for ATMs, and a staffed way to order gives any guest who cannot use the screen another route. Ask a lawyer what applies to you.

This page is not legal advice. It sets out what federal agencies and the W3C have published, to help you question vendors and brief your lawyer.

What does the ADA require of a restaurant kiosk?

Title III of the ADA covers places of public accommodation, and the Justice Department's Title III regulations list "a restaurant, bar, or other establishment serving food or drink" among them. The same regulations (28 CFR 36.303) require a public accommodation to provide auxiliary aids and services where needed to communicate effectively with people who have disabilities. They say those aids must be provided in accessible formats, in a timely manner, and in a way that protects the person's privacy and independence.

ADA.gov's effective communication guide gives a restaurant example: reading the menu to a person who is blind lets that person decide what to order. It also says businesses are encouraged to consult the guest about which aid will work.

When the Justice Department updated these rules in 2010, it chose not to add specific requirements for equipment. Its published explanation says other parts of the regulation, including reasonable modifications, barrier removal and effective communication, "will require the provision of accessible equipment in appropriate circumstances."

In September 2021 the Department filed a statement of interest in a lawsuit over check-in kiosks at Quest Diagnostics testing centers. It argued that Title III bars treating people with disabilities differently because auxiliary aids and services are missing, including for services offered through self-service kiosks. The case involved health care, and the filing states the Department's position in one case.

Is there a technical standard for ordering kiosks?

Not yet for restaurants. The 2010 ADA Standards for Accessible Design have detailed rules (section 707) for automatic teller machines and fare machines only.

On September 21, 2022, the U.S. Access Board published an advance notice of proposed rulemaking on self-service kiosks. It names restaurant ordering touchscreens and says the Board plans to base future rules on the ATM and fare machine rules plus the hardware rules in the federal Section 508 standards. It would cover kiosks that are fixed or built in, because the Board's authority stops there. The Board's guidelines are the basis for the enforceable standards that the Justice Department and the Department of Transportation issue. Comments closed in November 2022, and the Board's kiosk rulemaking page lists its next steps as analysing comments and preparing impact analyses.

The Justice Department has twice dropped plans for equipment rules. In December 2017 it withdrew its 2010 notice on equipment and furniture, noting that no ADA regulation set standards for equipment that is not fixed. In September 2025 it withdrew a planned equipment and furniture rulemaking that it had not published.

Does the Justice Department's 2024 web rule cover my kiosk?

Not if you run a private restaurant. The April 2024 rule applies to state and local governments under Title II, and it covers their web content and mobile apps. ADA.gov's fact sheet on the rule names WCAG 2.1 Level AA as the standard. An interim final rule in April 2026 moved the compliance dates to April 26, 2027 for governments serving 50,000 people or more, and April 26, 2028 for smaller ones and special districts.

If your guests order on a web page, such as a QR code menu or online ordering, the Department's March 2022 guidance on web accessibility is the closer fit. It says businesses open to the public must make what they offer online accessible, have flexibility in how they do it, and can look to WCAG and the Section 508 standards for help.

What does an accessible kiosk look like?

With no kiosk rule in force, the ATM rules in the 2010 Standards and the W3C's WCAG guidelines are the nearest published benchmarks. No rule makes them mandatory for a restaurant kiosk. Use the table as a buying and setup checklist.

Guest needPublished benchmarkCheck on your kiosk
Room for a wheelchairClear floor space of at least 30 by 48 inches (2010 Standards, 305)Nothing blocks the space in front: no rope line, trash can or high-top table
Reach from a seated positionControls between 15 and 48 inches above the floor for an unobstructed reach (308, 309)Measure the card reader, the screen's lowest and highest buttons and any printer slot
Limited hand strengthOperable with one hand, no tight grasping, pinching or twisting of the wrist, 5 pounds of force at most (309.4)A guest can tap, insert a card and take a receipt with one hand
Guests who cannot see the screenSpeech output for all displayed information, which the user can repeat, interrupt and adjust in volume, delivered through a mechanism all users can reach, such as an industry standard connector (707.5)Plug in headphones and complete an order without looking
Finding the controls by touchAt least one tactile control for each function (707.6) and braille instructions for starting speech (707.8)A tactile keypad or buttons, marked in braille
Reading from a wheelchairScreen visible from 40 inches above the floor; sans serif characters at least 3/16 inch high with strong contrast (707.7)Sit in front of it and read the smallest price
PrivacyThe same privacy of input and output that other users get (707.4)Speech goes to headphones, and no guest has to say a PIN aloud
More timeLet users turn off, adjust or extend time limits, with a warning and at least 20 seconds to extend (WCAG 2.2.1)Leave a half-built cart alone and see whether the kiosk warns before clearing it
Larger tap areasTargets at least 24 by 24 CSS pixels, with 44 by 44 at the enhanced level (WCAG 2.5.8 and 2.5.5)Modifier checkboxes and plus/minus buttons are easy to hit

Sources: the 2010 ADA Standards and WCAG's Timing Adjustable, Target Size (Minimum) and Target Size (Enhanced) pages.

The W3C's WCAG2ICT note, which applies WCAG to software outside the web, lists self-service kiosks and point-of-sale terminals as examples of "closed functionality," where a guest cannot plug in their own screen reader. It says WCAG alone is not enough for such devices, which is why speech output and tactile controls are in the table.

Plain item names, clear modifier groups and large buttons help every guest; our kiosk menu design guide covers them.

How many of my kiosks need these features?

No rule answers this for restaurant kiosks. For ATMs and fare machines, the 2010 Standards (section 220) require at least one of each type at each location to comply. In its 2022 notice, the Access Board asked whether its kiosk rule should instead require every fixed kiosk to be accessible, and noted that guests who are blind can struggle to find which machine is the accessible one. If only some units are accessible, mark them clearly.

Does a voice kiosk solve accessibility?

It helps some guests. A guest who cannot reach or see the screen well may find it easier to say the order. A guest who is deaf, hard of hearing or has a speech disability may not be able to order by voice at all, and a guest who is blind still needs to hear the cart and total read back.

Maple's voice ordering kiosk, in early access with a small number of restaurants, lets guests speak the order while the cart builds on screen. Every screen has a staff-help button, and the restaurant can turn Maple off on any kiosk with one tap. Ask Maple, or any voice kiosk vendor, to show how a guest who is blind, deaf or unable to speak would finish and pay. Our voice kiosk guide has a test plan.

What should you do before you install kiosks?

  1. Ask each vendor, in writing, which benchmarks in the table the kiosk meets, and have them show speech output and tactile controls working.
  2. Decide who helps a guest, and how a guest asks without using the screen. Time how fast staff arrive.
  3. Keep a staffed way to order open whenever the kiosks are on, with the same menu, prices and offers, so no guest pays more or waits longer because they cannot use a kiosk.
  4. Train staff to read the menu and order back on request, and to let guests enter a PIN themselves.
  5. Measure the clear floor space and reach range where the kiosk will stand.
  6. Ask guests with disabilities, or a local disability group, to try an order and tell you where it failed.
  7. Check that your QR code or online ordering pages work with a screen reader, if you use them.
  8. Take the table and the vendor's answers to an ADA lawyer. The Access Board notes that some states have their own kiosk rules.

For the wider buying decision, see our self-service kiosk buyer's guide.

Published by Maple, which sells an early-access voice ordering kiosk. This AI-assisted guide combines Justice Department regulations, guidance, notices and court filings, U.S. Access Board rulemaking documents and W3C accessibility guidelines with an original benchmark table and checklist. It is not legal advice, does not say that any kiosk, including Maple's, meets the law, and does not report any accessibility test.