1. Background.
2. Roll-Outs To Date.
3. Lessons To Be Learnt.
1. Background.
1.1. VVI and Accessible Communication.
1.2. European Accessibility Act.
1.3. Access to Cash Bill.
1.1. VVI and Accessible Communication.
Voice of Vision Impairment (VVI) is Ireland’s only Disabled Persons’ Representative Organisation (DPRO) specialising in the rights and needs of visually impaired people, as per Article 4 (3) of the UN Convention on the Rights of Disabled People (UNCRDP), Articles 4 (3) and 29 (b (ii) etc., and as clarified by General Comment No. 7 of the UNCRPD.
Legal Opinion, Commissioned by VVI, regarding DPROs
A central disabling barrier to visually impaired people in Ireland is accessible communications (cf. UNCRDP, Article 9), and to this end, VVI has published our VVIMAC – Manual on Accessible Communications:
1.2. European Accessibility Act.
The European Accessibility Act (Directive (EU) 2019/882) was transposed into Irish Law on 12th of December, 2023, as S.I. No. 636/2023. Active from June 28th 2025, it covers areas including the accessibility of ATMs and Point of Sale (POS) terminals. In the case of ATMs, the legislation applies to the pilar banks; AIB, Bank of Ireland and Permanent TSB (PTSB) and did not apply to Independent ATM Deployers (IAD) like Brinks or Euronet.
By way of further background:
- In 2018, Euronet acquired 400 non-branch ATMs from Ulster Bank,
- In 2020, AIB sold its network of more than 500 non-branch ATMs to Brink’s and Bank of Ireland sold it’s network of 700 non-branch ATMs to Euronet.
A previous VVI article from November 2022 covers the history of accessible ATM’s in the Republic of Ireland and elsewhere in Europe.
Following the withdrawl of Ulster Bank from the Irish banking market in April 2023, the number of accessible ATMs in the whole country went from one to none. However, PTSB began roll-out of their audio guidance system in the Spring of 2024, and AIB began its roll-out in October, 2024.
1.3. Access to Cash Bill.
The Provision of Access to Cash Infrastructure Bill or ‘The Access to Cash Bill’ (2024), developed by the Department of Finance, seeks to ensure the continued reasonable access to cash throughout the State.
VVI played a significant role in disability-proofing the Bill:
The legislation is also set to allow the Central Bank the ability to authorise and supervise Independent ATM Deployers (IAD) and Cash-in-Transit (CIT) companies.
A spokesperson for the Department of Finance, on September 25th, 2024, told VVI that:
“The (Provision of Access to Cash Infrastructure) Bill 2024 commenced it’s second stage through the houses of the Oireachtas on September 26th. The Bill brings ATM deployers and cash in transit providers within the regulatory perimeter of the Central Bank of Ireland. The operation of ATMs is not currently a regulated activity and, as a result, there are no applicable codes or regulations. Under this legislation, ATM deployers and cash in transit providers will be required to register with the Central Bank. The legislation will give the Central Bank the power to make regulations to prescribe requirements for all ATM operators, including reporting and service standards.”
2. Roll-Outs To Date.
2.1. Permanent Trustee Savings Bank (PTSB).
2.2. Allied Irish Bank (AIB).
2.3. Other ATMs.
Note: For security and privacy reasons, the voice guidance feature on AIB and PTSB ATMs is accessible using plug-in headphones only (3.5mm TRS – i.e., traditional mini-jacks for headphones or earplugs).
2.1. Permanent Trustee Savings Bank (PTSB).
In March 2024, Permanent TSB updated its O’Connell and Grafton Street ATMs with voice guidance as part of a pilot project and completed a nationwide roll-out towards the end of April.
PTSB also have ‘lobby-style’ indoor ATMs and Self-Service Banking Machines (SSBMs) which are accessible outside of branch opening hours at their branch locations in Liffey Valley Shopping Centre and Blanchardstown Shopping Centre.
2.2. Allied Irish Bank (AIB).
Following a trial roll-out at their Dún Laoghaire, Gorey, Grafton Street, Rathfarnham, Sandymount and Tralee ATMs in October, 2024, AIB has installed voice guidance software on all its ATMs and internal cash and cheque lodgement machines that also dispense cash.
The following transactions are enabled for voice guidance; Cash Withdraw, Cash and Balance, Balance Enquiry, Mini Statement and PIN Services (Pin Unlock and PIN change).
Should you encounter a fault using an AIB ATM, you have three channels to report same.
A. Phone the AIB call centre 017712424 explaining the issue you have and the location of the ATM.
B. Via AIB branch staff if you encounter an issue at an ATM located at a branch premises during branch opening hours.
C. By email to the AIB Self-Service Monitoring team explaining the issue and the location of the ATM. email: selfservice.monitoring@aib.ie
AIB also has lobbies with ATMs at the following 19 branches which are open from 8 am to 9 pm, seven days a week.
- Cork – South Mall.
- Dublin 1 – Capel Street.
- Dublin 2 – 100/101 Grafton Street.
- Dublin 2 – 1/4 Bagot Street.
- Dublin 6 – 9 Terenure Road East, Rathgar.
- Dublin 9 – 140 Lower Drumcondra Road, Drumcondra.
- Dublin 15 – West End Retail Park, Blanchardstown.
- Dublin 16 – The Lab, Level 1, Dundrum Town Centre.
- Dublin 22 – Naas Road Business Centre, Naas Road.
- Dundalk – 96 Clanbrassil Street, Dundalk, Co Louth.
- Galway – Lynch’s Castle.
- Kilkenny – 3 High Street, Kilkenny.
- Killarney – 25 Main Street, Co Kerry.
- Limerick – 106 O’Connell Street.
- Naas – 41 South Main Street, Co Kildare.
- Sligo – Stephen Street.
- Tralee – 1-2 Castle Street, Co Kerry.
- Waterford – 72/74 The Quay, Waterford.
- Wexford – North Main Street, Wexford.
2.3. Other Service Providers.
The remaining ATMs in the Republic of Ireland are operated by Bank of Ireland, Brinks and Euronet.
A spokesperson from Bank of Ireland tells VVI that it “will commence the roll-out of 664 new ATMs in 2025 which will have text-to-speech functionality and a headphone jack with adjustable volume, as well as high-contrast screens to support and improve the viewing experience for people with visual impairment.”
A spokesperson for Notemachine, a Brinks company informed VVI that they don’t have any plans to add voice guidance to their ATM’s at the moment.
To date VVI has not received a reply back from Euronet on our query.
3. Lessons To Be Learnt.
3.1. Meaningful Consultation
3.2. Headphones.
3.3. User Interface.
3.4. Assistance, Maintenance, and Reporting Faults.
3.5. 24-Hour Lobbies for ATMs.
3.1. Meaningful Consultation.
VVI was not at all consulted in the roll-out of the PTSB accessibility features, and we have heard nothing from Bank of Ireland in terms of consultation on its design and roll-out in 2025.
AIB informed us of the initial testing points less than a month before they were to be tried. AIB was looking for VVI members to test, for for VVI to feed back, and to that end, AIB placed the test sites in locations amenable to interested testers in VVI. However, testing is not consultation, and while VVI had been campaigning to AIB on accessibility for years, there was no meaningful consultation with us on the design of the voice guidance systems.
two quotes from VVI reps engaging with AIB paints the picture of frustration:
“they didn’t listen to our voice… They were the second to last bank to make their machines accessible and I have had complaints in with them about it for about at least 4 years.”
“To get accessibility on ATMs has certainly been a battle for years and really something the Central Bank as the regulator could have stipulated years ago separately from any European legislation. The Central Bank are under the Department of Finance and really should be fighting for us but we are left doing all the heavy lifting. Getting across the battle [we] had to go through is so important as you get passed all around the place and what feels like being ignored.”
As described in Section 1.1, above, VVI is the only collective representative voice of blind and partially sighted people in Ireland. As per Articles 4 (1, 3), 9, and 29 (b (ii)) of the UNCRDP, DPROs such as VVI have an exceptional role as priority consultees in all disability-proofing, including by financial institutions. However, so neglectful has the State been of such awareness-raising (e.g., under Article 8 of the UNCRDP), not even the Central Bank is aware yet of those obligations.
But apart from the legal and moral aspects, the most efficient and effective way of making sure that accessibility features designed for visually impaired people are fit-for-purpose is to “closely consult with and actively involve” their collective voice from the concept stage of implementation of the policy and design.
To this end, the Central Bank needs to make all financial institutions aware of their need to consult with DPROs, and indeed, it needs to meet its own legal obligations to closely consult with and actively involve DPROs (including VVI) in disability-proofing Ireland’s banking system. It may be that the Central Bank is waiting for guidance from the “lead Department” (of Children, Disability, Equality, Integration and Youth), but our rights to accessibility and collective representation are immediate (cf. UNCRDP, General Comment No. 1, para. 30).
3.2. Headphones.
Banks should provide free earplugs for their visually impaired customers so that they can access the ATM more easily. The model for such provision is AIB’s accessible card-reader provision to visually impaired customers on request. Such provision of earplugs would also be useful as traditional TRS connector jacks become less common and more difficult to obtain on the High Street.
In terms of making the headphone socket more locatable, one of VVI’s members who tested for AIB wrote:
“If I hadn’t already been informed as to the location of the headphone socket, I don’t’ think I would have found it. The area of the machine with the keyboards is a more or less flat surface in front of you and to find the earphone socket, you have to go to the edge nearest to you of the flat surface and go to the area just below it, where there is a tiny socket for the headphones next to a volume button.”
Possibly, tactile arrows resembling the print greater than sign “>” and a headphone symbol could help. Otherwise, in next iteration of machines, the positioning of the headphone jack itself could be made much more conspicuous or natural to find by those not using sight.
3.3. User Interface.
The following are audio prompts which are absent on AIB’s system, but which should be included on all voice guidance systems for ATMs.
- The ATM should inform the customer that the screen has been switched off.
- It would be useful, at the beginning, if there were a message explaining to the customer that they can skip the instructions if they wish, and saying how this is to be done. The activation button/key for this should be operable from when the blank screen confirmation has been made.
Quoting a VVI member and tester for AIB’s system:
“Currently, pressing#8 allows you to select an amount of your choice. Up to that point all the numbers select a predetermined amount. Therefore, when the menu is being read out you have to wait right until the end before you find this out. If selecting a non-determined amount was put to #1, then somebody withdrawing cash would be aware of this option immediately.”
- There should be an audio announcement if the ATM is out of service (as with the Permanent TSB ATMs), or if the accessibility feature is out of order. In case the problem is with the earplug jack, this message could play over an open speaker when someone puts the earplug in the jack.
3.4. Assistance, Maintenance, and Reporting Faults.
One of our testers tried reporting a fault to the AIB call centre on 017712424, as advised, which took her six minutes by phone, and after all that, she got no feedback. It took approximately a week before that report of a faulty headphone jack was addressed. Note that in the meantime, this ATM is not out of service to fully sighted people, but only to visually impaired people who require the use of earplug access.
Quoting our member:
“We need to establish a contact system where matters like this will be addressed on the same day with priority and not put into a queue.”
Also, accessibility Faults must be given priority both in the bank reporting the fault to the relevant section and by the engineer or whoever fixes it.
As a result of our feedback, AIB have said that such reports will be in a “Priority 1” fast-track process in future, including the possibility of reporting via email to selfservice.monitoring@aib.ie.
3.5. 24-Hour Lobbies for ATMs.
Using an ATM on a busy street can be difficult for a visually impaired person relying on audio, and it can add to discomfort when such transactions have to take place in heavy winds or driving rain.
In Europe and North America it is common for banks to have 24-hour ATMs in lobbies which are sheltered.
In 2.1 and 2.2 above, Irish examples have been given of ATMs in lobbies, but many of these are not open between the hours of 9pm and 7am. Banks should explore options of making sure that such lobby ATMs can be accessed 24/7. In terms of building new branches, lobby ATMs is something that should be considered as an aspect of universal design.