California Business Compliance
Independent Accessibility and the ADA
Nobody would ever think there are so many details to correctly mount a credit card terminal, especially when it comes to accessibility — whether standing using tilt and swivel features, or seated and using our ADA Dismount feature at checkout. But there is a lot of detail and reasoning, especially since the ADA came into law and later expanded under Section 508 (ICT).
When the ADA refers to “independent accessibility,” it means a person with a disability must be able to approach, reach, operate, and use a facility, service, or device without requiring assistance from another person.
What the ADA Requires for Independent Accessibility
1. Independent Operation
ADA §309.4 (Operable Parts) — Controls and mechanisms must be usable with one hand and must not require tight grasping, pinching, or twisting of the wrist. Maximum operating force: no more than 5 lbf (22.2 N).
This ensures a person can dismount, move, and resecure a POS terminal without needing employee help.
Its ADA 309 Operable Part U-shaped pull handle and light-force dismount mechanism allow independent use by seated users, people with limited grip, or one-arm users.
2. Independent Reach and Range
ADA §308 (Reach Ranges) defines maximum and minimum reach heights:
- Forward reach: 15″–48″ above the floor (for users in wheelchairs).
- Side reach: 15″–48″ (unobstructed) or 46″ (obstructed).
The device must be positioned so a user can approach and reach controls directly.
Adjustable angles and dismountability ensure users can bring the terminal to their lap or into clear view — unlike fixed mounts that stay out of range.
3. Independent Access to Information
ADA §707 (ATMs and Fare Machines) requires visual, tactile, and privacy accessibility.
Users must be able to read the display, enter PINs privately, and review transaction info independently, even if seated or with low vision.
Allows repositioning for visual accommodation and privacy during PIN entry, fulfilling §707.4 and §707.5 requirements.
4. Independent Usability in Public Accommodations
ADA Title III (§36.402) requires barrier removal so that disabled customers can independently use goods, services, and facilities. Businesses must ensure equal access — meaning independence, not dependence on employee assistance.
By enabling self-service access and seated interaction, it removes a physical and functional barrier at checkout.
Legal Summary
“Independence” under the ADA means a person with a disability must not be forced to rely on others to access or use a device, service, or transaction point. If a customer must ask a cashier to move or hold the terminal, the business is not ADA compliant.
Here’s how it breaks down legally and practically
Below are the main legal points and practical implications for checkout terminal accessibility under federal ADA law.
1. ADA Title III – Public Accommodations
Under Title III of the Americans with Disabilities Act (ADA), all places of public accommodation — including stores, restaurants, and service counters — must provide equal access to goods, services, and payment methods for individuals with disabilities.
This includes checkout counters and payment devices such as credit card terminals, PIN pads, and touchscreen readers.
2. Specific ADA Standards That Apply
- Controls and operable parts (card readers, touchscreens) must be within reach range for a person seated in a wheelchair.
- Typically no higher than 48 inches for a forward approach or 54 inches for a side approach, with adequate clear floor space.
- Operable parts must be usable with one hand and without tight grasping, pinching, or twisting.
- Required actuation force must not exceed 5 pounds.
This section governs interactive payment interfaces (e.g., PIN entry, display, privacy). DOJ guidance applies these same requirements to POS terminals, as their use and functions are equivalent.
3. Common Violations
- The terminal is mounted too high or too far back to reach from a wheelchair.
- The device is fixed in position (cannot be tilted, pulled forward, or held).
- The screen or keypad is angled so that a seated user cannot see or reach it.
- A cashier must not assist with PIN entry, violating privacy and independence requirements (§707.4).
4. Legal and Enforcement Context
The DOJ and U.S. Access Board have clarified that card readers are part of the transaction counter and must be accessible. Private lawsuits and DOJ settlements often reference ADA §36.302 (“modifications in policies, practices, or procedures”) and §36.402 (“readily achievable barrier removal”).
5. In Plain Terms
If a wheelchair user can’t independently reach, see, or use a credit card terminal during checkout, that constitutes a violation of ADA Title III.
Businesses are required to provide equal, private, and independent use — not just access to the counter itself.