Availability of products and services for people with special needs

We advised Global operators of POS terminals and ATMs in:

Compliance of POS terminals and ATMs
with regulations on accessibility of equipment
for people with special needs

On June 28, 2025, the Law on Ensuring that Business Entities Meet Accessibility Requirements for Certain Products and Services, which implements Directive (EU) 2019/882 of the European Parliament and of the Council of April 17, 2019 on accessibility requirements for products and services, enters into force. The law ensures that people with special needs can use products and services on an equal footing with others. This includes, among other things, the need to equip self-service terminals with voice messaging modules and wired stereo headset modules, as well as a wireless connection to audio-enhancing assistive tools, the availability of more than one sensory channel (alternatives to visual, audio, speech and tactile elements). In view of services, among other things, an obligation to ensure uniformity of websites and mobile applications is envisaged.

DLK’s advisory included:

• Determine the role of POS and ATM operators vis-à-vis the devices in terms of whether they have obligations to the devices (legal qualification of the operator as a supplier, importer, distributor or other entity)
• Determining the role of POS and ATM operators in the context of user services available on these devices
• Determining whether a device is a terminal or another product within the meaning of the regulations
• Determining the applicability of the transition period