The European Accessibility Act and your kiosk: what applies in Iceland today

If you are choosing a self-service kiosk, QR ordering or an online shop, you may have read about the European Accessibility Act (EAA). It has applied in the EU since 28 June 2025, and it covers some self-service machines and online shops.

The short answer for Iceland: as of October 2026, the EAA is not in force here.

What the EAA covers in the EU

The EAA is Directive (EU) 2019/882. EU countries had to apply their national rules from 28 June 2025.² The directive covers a list of products and a list of services. It is not a general rule for every business.

These products are covered when they are placed on the market after 28 June 2025:²

• payment terminals
• automated teller machines (ATMs), ticketing machines and check-in machines
• interactive self-service terminals that give information
• computers, phones, tablets and e-readers for consumers

The ATMs, ticketing machines, check-in machines and information terminals are covered when they are used for a service that the directive covers.² Among the services, the one that matters most for restaurants is e-commerce. The directive defines it as services provided at a distance, through websites and mobile apps, at the request of a consumer, to make a consumer contract.²

Where a restaurant kiosk fits

The directive names payment terminals directly. So the card reader in a kiosk is a covered product in the EU.²

A screen where guests order food is not named in the list. It is not an ATM, a ticketing machine or a check-in machine. Food ordering is also not one of the services that the directive lists for those machines. Whether a food-ordering kiosk is in scope is therefore a question of interpretation, and we have not found an official answer. If you run a restaurant in an EU country, ask the authority in that country or a lawyer.

Online ordering on your website or in an app fits the e-commerce definition more clearly, because the guest orders at a distance.² QR ordering at the table is less clear. The guest uses a phone and a website, but sits in the restaurant. We could not find an official answer to this either.

The exemption for microenterprises

Microenterprises that provide services do not have to meet the accessibility requirements for those services.² A microenterprise has fewer than 10 people and an annual turnover or balance sheet of EUR 2 million or less.² Many single restaurants are in this group.

The exemption is for services. Depending on the case, the directive puts its obligations on manufacturers, importers, distributors or the authorities.³

There are also transition periods. Self-service terminals that a business used lawfully before 28 June 2025 can stay in use until the end of their economic life, but no longer than 20 years after they were first used, if the country allows this.²

The status in Iceland

The EAA is marked as relevant to the European Economic Area (EEA). On the EFTA register, its status is “under scrutiny for incorporation into the EEA Agreement” by Iceland, Liechtenstein and Norway.¹ It is not part of the EEA Agreement yet, so it does not bind Icelandic businesses.

In an answer to Alþingi in the 2023–2024 session, the Prime Minister wrote that the implementation of the directive “er í vinnslu” (is in progress). The answer also said that it will need changes to several Icelandic laws.³ We did not find a bill or a date for it in the sources that we checked on 3 October 2026.

Iceland did pass a different accessibility law in March 2026: lög nr. 20/2026. It covers websites and apps of public bodies only.⁴ It applies in stages:⁴

During the work on the bill, some organisations asked Alþingi to extend it to private businesses. The committee decided not to widen it beyond what the EU directive for public bodies requires.⁵

A rule that already applies

One Icelandic rule already applies to restaurants. The Act on Equal Treatment outside the Labour Market, lög nr. 85/2018, says that companies must make necessary and appropriate changes when a disabled person needs them in a specific case, to use a service on equal terms with others. This applies as long as the changes are not too burdensome or beyond what is reasonable.⁶

This is a rule for the individual case, not a technical standard for screens. In a restaurant, it can be as simple as a member of staff taking the order at the counter for a guest who cannot use the kiosk.

The standards behind accessible ordering

Two standards describe digital accessibility:

• EN 301 549 is the European standard for the accessibility of ICT products and services.
• WCAG (Web Content Accessibility Guidelines) from the W3C is the standard for websites and apps. The current version is WCAG 2.2, published on 12 December 2024.⁷

WCAG has three levels: A, AA and AAA. Some examples from WCAG 2.2:⁷

What to look for when you choose

Even without a legal requirement in Iceland, accessible ordering is good service. The World Health Organization estimates that 1.3 billion people, 16 % of the world’s population, live with a significant disability.⁸ Add older guests, tourists who read a menu in their second language, and anyone who has forgotten their glasses.

When you compare kiosks, QR menus or online shops, ask the supplier these questions:

1. Does the product meet WCAG 2.2 level AA, or EN 301 549? Can the supplier show a test report or an accessibility statement?
2. Can a guest in a wheelchair reach the screen, the card reader and the receipt printer?
3. Does the screen work with a screen reader, or does it offer another way for a guest who cannot see it well?
4. Can the guest make the text larger, and does the layout still work?
5. Is there enough contrast, and does the screen avoid using colour alone to show something, such as an allergen?
6. When the screen asks “Are you still there?”, how long does the guest have, and can you change the time?
7. Can the guest choose a language that they read well?
8. Do the photos and allergen icons also have text?

Keep one simple rule in the restaurant: a guest who cannot or does not want to use the screen can always order from a person. It is also the simplest form of the case-by-case adjustment that lög nr. 85/2018 describes.⁶

If you are looking at a self-service kiosk, QR ordering or an online shop from Resto, ask us the same questions. For what the research says about ordering on a screen, see Kiosks, QR and online ordering: what the evidence says.