Self-service terminals: the exemption runs twenty years from entry into use, not from 2025

A typical scenario, not a real case. A local public transport company sells tickets three ways: from its website, its app, and ticketing machines at the main stops. An outside agency runs the website and holds the accessibility statement. A software vendor builds the app and holds its technical documentation. A third company manufactured the ticketing machines, ran the conformity assessment, and issued the EU declaration of conformity — filed in procurement with the supply contract. None of these records can answer a simple question: is the ticketing machine installed at the terminus back in 2015 still within the period the law allows it to stay as it is, or should it already have been replaced?

The start date is written, and it has already passed

Legislative Decree 82/2022 of 27 May 2022 transposes Directive (EU) 2019/882 on accessibility requirements for products and services into Italian law. Article 1(1) is blunt about the date: the decree «stabilisce i requisiti di accessibilità dei prodotti e dei servizi di cui ai commi 2 e 3 immessi sul mercato a far data dal 28 giugno 2025» — sets accessibility requirements for the products and services under paragraphs 2 and 3, placed on the market from 28 June 2025 (our translation throughout, for the Italian-only decree). Not a future deadline: a written date, already more than a year behind us. Paragraph 2 lists the products covered, among them, point (b), «i terminali self-service di pagamento e quelli destinati alla fornitura dei servizi disciplinati dal presente decreto» — self-service payment terminals and those dedicated to the services this decree covers. The directive being transposed names them more explicitly, in a list the Italian legislator compressed: Article 2(1)(b) names, among self-service terminals, “automated teller machines”, “ticketing machines” and “check-in machines”.

Two different transitional clocks, not one

Article 25 keeps two regimes apart, easy to blur. Paragraph 1 sets a ceiling for service contracts: «Fino al 28 giugno 2030 i fornitori di servizi possono continuare a prestare i loro servizi utilizzando prodotti che utilizzavano in modo legittimo prima di tale data […]. I contratti di servizi conclusi prima del 28 giugno 2025 possono essere mantenuti invariati fino alla loro scadenza, ma per non più di cinque anni da tale data» — until 28 June 2030, service providers may keep using products they lawfully used before that date […]. Service contracts concluded before 28 June 2025 may stay unchanged until they expire, but no longer than five years from that date — 28 June 2025 plus five years, arithmetic that lands exactly on the date written just before it in the same paragraph: 28 June 2030.

Paragraph 2 is a different clock, and never mentions 2030: «I terminali self-service utilizzati in modo legittimo dai fornitori di servizi per la fornitura di servizi prima del 28 giugno 2025 possano continuare a essere utilizzati per la fornitura di servizi analoghi fino alla fine della loro vita economica utile, ma per non più di venti anni dalla loro messa in funzione» — self-service terminals lawfully used to provide services before 28 June 2025 may keep being used for similar services until the end of their useful economic life, but no longer than twenty years from their entry into use. For the 2015 ticketing machine: entry into use in 2015, plus twenty years, equals 2035 — five years past the 2030 ceiling for contracts. But it is a ceiling, not a vested right: if the useful economic life the company assigns to that model is shorter — ten years, say — the real deadline falls in 2025, not 2035. The decree defines neither vita economica utile (useful economic life) nor messa in funzione (entry into use): both are left to be worked out case by case.

Three different supervisors over the same service

For the same company, who checks what changes by channel. The website and app answer to the Agency for Digital Italy, which Article 21(1) designates «in qualità di Autorità di vigilanza sui servizi» — as the supervisory authority for services. The ticketing machine as a product answers instead to the Ministry of Enterprises and Made in Italy, which Article 18(1) instructs to step in when it is «in possesso di sufficienti elementi per ritenere che un prodotto non sia conforme ai requisiti di accessibilità applicabili» — in possession of sufficient grounds to consider a product non-compliant with the applicable accessibility requirements. But if that same machine is, as here, a self-service terminal used for a transport service, oversight shifts again: Article 21(6) assigns it «ai soggetti pubblici che hanno affidato ovvero autorizzato l’erogazione al pubblico del servizio di trasporto» — to the public bodies that awarded or authorised the public provision of the transport service — the municipality or region behind the concession, not the Agency. Three institutions, for three pieces of one service.

The technical standard still missing from the EU Official Journal

Article 14 of the decree offers a shortcut: whoever complies with a harmonised standard published in the EU Official Journal is deemed compliant for the parts it covers. The standard built for this — EN 301 549, “Accessibility requirements for ICT products and services” — is published free by ETSI, unlike ISO, CEN, UNI and CEI, which stay paywalled and whose content we do not quote. The version actually published today is V3.2.1, March 2021: its own foreword states it was prepared “to provide […] one voluntary means of conforming to the essential requirements of Directive (EU) 2016/2102” — the directive on public-sector website accessibility, not the 2019/882 at issue here. A revision built specifically for the 2019/882 exists but is not yet the standard in force: a “Final draft EN 301 549 V4.1.0”, dated June 2026, whose approval vote closed on 24 August 2026 — nine days before we write this — with no outcome we could confirm. That draft says, in the conditional, the shortcut is not available yet: “Once the present document is cited in the Official Journal of the European Union under that Directive, compliance […] confers […] a presumption of conformity”. Not yet.

The one piece of data no corporate system holds in full

For every self-service terminal, compliance depends on facts that live in different places: the entry-into-use date, deciding whether the transitional regime still applies and until when; the manufacturer’s EU declaration of conformity and technical documentation, usually sitting with the supplier or in a purchasing file; the supervisory authority actually competent for that channel, which changes with whether the terminal serves transport; and the absence, today, of a harmonised standard in the EU Official Journal conferring a presumption of conformity. The asset register knows when a unit was installed, not whether it complies. Procurement knows whether a supplier declaration exists, not when its term starts running. Neither cross-references the authority competent for that channel.

What we have not verified

We do not give legal advice, and we do not assess any specific product or service. We have not verified the outcome of the vote on EN 301 549 V4.1.0, which closed on 24 August 2026: the version we read is the one ETSI distributed during the vote. Nor have we checked whether the Commission has adopted implementing technical specifications under Article 15 of the directive absent a harmonised standard. We found no definition in the decree of vita economica utile or messa in funzione: both remain factual questions.

The two axes, applied

Complying. In our system, the same setup keeps, for every self-service terminal installed, the entry-into-use date alongside the supplier’s conformity file and the authority competent for that channel — one row per unit, not three separate archives, updated whenever a unit moves or is replaced.

Deciding. The same system brings the website, the app, procurement and the asset register together into a single operating model, on which AI agents execute decisions with a human operator in command. Always in two modes: on-premises, on autonomous machines with no deep integration into the network, or dedicated cloud, with a data centre in Italy and premises staffed by us. This is our platform’s method, applied to a sector where the deadline is not one date for everyone, but a different date for every unit installed.

Do you operate self-service terminals for a regulated service — transport, payments, ticketing? Half an hour with one of our engineers for the first unit-by-unit map of when the transitional regime lapses.