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Appraising Self-Checkout Accessibility in Ontario

Executive Summary

Major retailers in Ontario, from Loblaws to Canadian Tire, have been increasingly replacing cashiers with self-checkout kiosks. This policy brief examines how these kiosks can pose a hurdle to those with disabilities, citing measures from the Accessibility for Ontarians with Disabilities Act (AODA). Policy recommendations are offered that would ensure an accessible checkout experience for all Canadians, both from a social and technological standpoint.

Table of Contents

  1. Summary of Problem
  2. Current Policy Measures and Shortcomings
  3. Recommendation

1. Summary of Problem

Beginning in the 1990s, major retailers within Canada and the United States have attempted to automate the checkout aisle. These attempts have principally involved the installation of now-familiar self-checkout kiosks, which task customers with the work of scanning and bagging their own items in lieu of a paid cashier. In recent years, these kiosks have been equipped with incrementally more advanced digital technologies: from sensors and RFID chips that permit barcode-less scanning; to receipt scanners and security cameras that assist with loss prevention.

The deployment of self-checkout kiosks intensified during the COVID-19 pandemic. Contactless service, although initially a concession to social distancing measures and perceived labour shortages, has remained a ubiquitous part of the retail experience in Canada today. Landmark Canadian grocery and retail chains such as Loblaws, Shoppers Drug Mart, Dollarama, and Canadian Tire maintain checkout aisles where many (or even all) of the cashiers have been replaced by self-checkout kiosks.

The flagship Loblaws location at Maple Leaf Gardens in Toronto has 15 self-checkout kiosks.
Dollarama locations across Canada have been converting their checkout aisles to self-service

The emergence of self-checkout technologies has been covered extensively by the Canadian press, largely within the context of consumer rights, loss prevention, and the consequences of a cashless society. There remains an ongoing debate over whether these kiosks are conveniences that are popular with Canadians; or corporate cost-saving measures that are thrust upon them. 

This policy briefly instead examines self-checkouts as an accessibility issue. Through examples drawn from Canadian accessibility legislation and onsite documentation, it will be demonstrated how the self-checkout aisle can pose both a technological and social hurdle to Canadians with disabilities—and how these hurdles can be resolved through relatively minor policy changes.

Checking Out as an Accessibility Issue

From a technology standpoint, self-service kiosks often do not hit common accessibility benchmarks. This can occur on the level of individual pieces of hardware and software used within the kiosk. As noted by the CNIB Foundation, many payment terminals and touchscreen devices lack haptic feedback, auditory cues, or similar accessibility features that would permit Canadians with vision loss to use them unaided.

Furthermore, accessibility issues can be tied to the individual choices made by the retailer when they install a kiosk. The most popular self-checkout kiosks deployed in Canadian stores, such as the Fujitsu U-Scan Mini-Express and the Toshiba Self Checkout System 7, are highly modular systems. Although hypothetically accessible, seemingly innocuous installation choices can cause issues, such as placing a touchscreen too high off the ground or the kiosk itself in a tight space—both of which pose challenges to those with mobility devices.

Default version of the U-Scan Mini Express Optic, advertised on the Fujitsu website.
Implementation of the unit in a No Frills. Note the elevated PIN pad and positioning in a corner.

The accessibility of self-checkout aisles is often additionally complicated by the introduction of accompanying loss prevention technologies. Loblaws stores in Ontario, in pursuit of deterring shoplifting, have installed plexiglass barriers and security gates with receipt scanners that have made their floor plans more physically and cognitively demanding to navigate.

From a staffing standpoint, there has been a commiserate decline in dedicated cashiers within the checkout aisle to provide accommodation to those with disabilities. Self-checkouts are increasingly outnumbering traditional checkouts in major Canadian grocery and pharmacy chains, particularly in downtown Toronto—and they are unstaffed even during peak business hours.

This Shoppers Drug Mart on 465 Yonge Street offers 7 self-checkouts and 2 traditional checkouts.
The Loblaws location at Maple Leaf Gardens has 10 traditional checkout lanes, but only 3 were staffed on a weekday afternoon.

Many stores have even transitioned entirely to self-checkout arrangements. The downtown Toronto IKEA, UNIQLO, Michaels, and Canadian Tire locations employ no dedicated cashiers, instead tasking a floating employee (who often has other responsibilities in the store) to provide assistance in the checkout aisle when requested. Complicating the question of accommodation even further, there are also an emerging number of stores in Canada that advertise themselves as “unstaffed” and lack any front-facing employees, such as the popular Aisle 24 cashierless grocery chain.

The Canadian Tire at the Eaton Centre in Toronto lacks cashiers entirely, only offering self-checkouts.
Aisle 24 stores are completely unstaffed, requiring a paired smartphone app to open the door.

As corporate investment in self-service technologies shows few signs of slowing down, it is necessary to establish firmer rules regarding accessibility within the checkout aisle to ensure that businesses can continue to be easily patronised by all Canadians.

2. Current Policy Measures and Shortcomings

People with disabilities are not an outlier within Canada. In 2022, Statistics Canada documented that 27% of Canadians identified as having at least one disability, consisting of 8 million people aged 15 and older. These include dexterity (18.4%), pain (61.8%), and mobility (39.2%) disabilities; hearing (20.7%) and seeing (27.4%) disabilities; and memory (18.2%), developmental (5.7%), and learning (20.7%) disabilities.

These statistics, further, do not account for those who may be suffering from temporary or situational impairments that also require accommodation. For instance, in the United States, there are 26 thousand people a year who suffer from the permanent loss of an upper extremity—but an additional 13 million that suffer from a temporary loss owing to a major injury.

Within Ontario, the primary legislation ensuring the accessibility of the retail experience is the Accessibility for Ontarians with Disabilities Act (AODA)—specifically, the Customer Service Standard. The Customer Service Standard establishes minimum accessibility requirements for customer service within the province, applying to both public sector organizations and any business  that provides goods and services to the general public (and has at least one employee).

This standard is structured around three guiding principles that are intended to help organizations develop their own internal policies, practices and procedures.

  1. The goods or services must be provided in a manner that respects the  dignity and independence  of persons with disabilities.
  2. The provision of goods or services to persons with disabilities and others must be  integrated  unless an alternate measure is necessary.
  3. Persons with disabilities must be given an  equal opportunity  to that given to others to obtain, use, and benefit from the goods or services.

The Customer Service Standard standard came into full effect in Ontario on January 1, 2008. The AODA as a whole took full effect on January 1, 2025.

The Customer Service Standard

The accessibility issues found within the checkout aisle of Ontarian businesses can be attributed to both a failure of retailers to adhere to the guiding principles of the Customer Service Standard when deploying new technologies; and to a failure of the AODA in providing clear and specific benchmarks for meeting these principles.

Self-checkout aisles infringe on the three guiding principles of the Customer Service Standard in several ways. Primarily, when self-checkouts kiosks lack accessibility features, individuals who rely on such features are prevented from checking out in the same manner and location as other customers. They are not  integrated  into the checkout aisle and the customer service experience as a whole.

Often the only traditional checkout is reserved for exchanges, returns, and online order collection, such as in this downtown IKEA location.
It can be difficult to find a staffed checkout, if there is one available, as stores funnel customers towards self-checkouts.

The growing practice of removing dedicated cashiers, and instead dividing the time of a single employee between providing checkout assistance and performing other tasks within the store, poses further problems. For one, customers with disabilities are not provided an  equal opportunity  to check out, and may have to wait considerably longer to do so, because there is no dedicated alternative to self-checkout kiosks.

Furthermore, the positioning of human-assisted checkout as a secondary responsibility of employees impairs the  dignity and independence  of customers, who are now forced to request this support as a special accommodation.

Signs on the self-checkouts at Michaels instruct customers to “Ask a Team Member” if they need help.
Similarly, UNIQLO’s self-checkouts instruct customers to “call a Store Associate.”

The language of the Customer Service Standard is vernacular, relying more on illustrative examples rather than precise specifications for technology and store layouts. Consequently, large and small private organizations within the province are only required to consider what accessibility features could be built into their kiosks to accommodate the widest range of users.

Even the Integrated Regulation of the AODA, which ostensibly provides guidelines governing self-service kiosks for public sector organizations, “does not specify what features should be built-into the design” or otherwise stipulate “purchase requirements for the kiosk.” Technical features, structural features, and access paths are thus listed as potential accessibility concerns with no associated specifications.

Do Self-Checkout Standards Exist?

Standards for designing accessible self-checkout kiosks are in fact well-documented and widely available in Canada. Within Ontario, the City of Toronto has developed the Toronto Accessibility Design Guidelines (TADG) as a mandatory requirement to ensure accessible, equitable, and barrier-free access to all city-owned or operated facilities. The TADG includes sections that outline the minimum accessibility requirements for self-service kiosks (Section 2.6.6) and other self-service interactive devices (Section 3.2.3).

Figure 2.6.6-B from the TADG, outlining minimum side reach requirements for an ATM.
Figure 2.6.6-D from the TADG, outlining contrast and font size requirements for signage.

These municipal standards are in fact based on a Canada Standard Association (CSA) standard that was developed in partnership with Accessibility Standards Canada (ASC) at the federal level: CSA B651.2:22 (Accessible design for self-service interactive devices including automated banking machines). The stipulations of CSA B651.2:22 closely align with international accessibility documentation governing self-service, such as the requirements for accessible routes and communications put forth in the Standards for Accessible Design within the American Disability Act (ADA).

The CSA B651.2:22 standard provides precise technological and architectural requirements for self-service kiosks with the intention of accommodating individuals with specific disabilities. Subsection 10.3.2.1 addresses the problem of touchscreens highlighted by the CNIB by dictating that these interfaces provide auditory and visual feedback and adhere to minimum colour contrast requirements (referencing the WCAG 2.1 for accessible web design).

Subsection 10.1.2 addresses accessibility issues related to individual installation choices by prescribing how high a touchscreen or point-of-sale device needs to be mounted off the ground and how wide aisles and other paths of access need to be to accommodate those using mobility devices.

Figure 3 b from the CSA B651.2:22 standard, recommending minimum knee and toe space for those using a mobility device.

Additional subsections offer guidelines for designing security gates (7.2), barcode scanners (10.5.4), credit card readers (10.5.5), signage (5.2.2), and the other composite components of the self-checkout aisle. Throughout the CSA B651.2:22 standard, these requirements are measured out to the individual millimetre or pixel and accompanied by rigorous technical diagrams.

In summary, we know how to make self-checkout aisles accessible in Canada. The problem is, however, that precise and enforceable technology and staffing requirements are not spelled out within current legislation.

3. Recommendation

This policy brief understands that the implementation of new, accessible technologies is costly, specifically for small businesses in Ontario. Consequently, this section proposes a flexible solution to ensure an accessible self-checkout experience.

  1. The business1 should (at minimum) provide a single, dedicated2 cashier at a traditional checkout—as well as an additional dedicated cashier for every 6 self-checkout kiosks;
  2. Moving forward, all self-checkout kiosk procurements and installations should adhere to the CSA B651.2:22 accessibility standard.

This policy brief also recommends future investigation into and development of accessibility standards for autonomous retail technologies as a whole. This could include expansion of the Accessible Self-Service Kiosk standard within the AODA to match the rigour of the adjacent Information and Communication Standards and Transportation Standards within the Integrated Regulation. With artificial intelligence and app-based integrations already being introduced into retail environments, there is also a need for the AODA to encompass a wider range of self-service technologies beyond these kiosks.

Overall, as autonomous technologies continue to advance, it will be necessary to establish a minimum floor of acceptable and accessible customer service within retail scenarios to ensure that all Canadians are able to receive equitable services and maintain their dignity and independence.

1The term business draws from the AODA definition, referring to a “person or organisation that provides goods or services to members of the public or other third parties and that has at least one employee in Ontario.” This document maintains that businesses that advertise themselves as “unstaffed” or “cashierless” still fulfill this definition. Although there may not be any visible customer service representatives on the retail floor, there are still employees and franchisees performing logistical and maintenance tasks behind the scenes.

2Within the context of this recommendation, a dedicated cashier refers to an employee whose primary or sole responsibility is operating a traditional checkout. This would not include an employee who floats between multiple checkouts to offer customer support. It would also not include an employee who is engaged in other responsibilities within the store, such as stocking shelves, and is on-call to assist customers at a traditional checkout when requested.

Checking In Appraising Self-Checkout Accessibility in Ontario