The European Accessibility Act and Book Publishing
The European Accessibility Act (EAA), approved in 2019 and due to go into full force in June 2025, is officially a directive — meaning that it sets binding accessibility goals but leaves it to member states to make decisions about implementation. The stated goal is to eliminate and prevent barriers to free movement of products and services across member states, thereby strengthening the rights of persons with disabilities to access goods and services.
This legislation is almost certain to have a dramatic impact on the digital books marketplace, and even on how North American publishers operate. In much the same way that EU General Data Protection Regulation (GDPR) has people around the world accepting cookies whenever visiting a website, this progressive and ambitious European legislation is bound to cause commerce ripples.
The act governs a number of products and services but the most relevant here are:
consumer computer hardware systems (personal computers, notebooks, smartphones, and tablets) and operating systems,
self-service terminals (i.e., payment or ticketing terminals)
consumer banking services
electronic communication services
payment services
services to access audio-visual media services — which includes ebooks, dedicated reading software, e-reading devices, and e-commerce
“The goal is to eliminate and prevent barriers to free movement of products and services across member states, thereby strengthening the rights of persons with disabilities to access goods and services.”
Ebooks and software e-reading solutions are considered services. This means that the concept of a service provider includes publishers and all others involved in their distribution in the following areas:
Distributors and online retailers, e-commerce websites and mobile apps, online platforms
Software e-reading solutions
Digital rights management (DRM) solutions
Metadata
For both products and services, the EAA provides for mandatory compliance and ability to certify conformity via the CE marking (Conformité Européenne). The EAA foresees the presence of market surveillance authorities, both at the European and the national level, responsible for checking the compliance of products and services with EAA requirements.
There will be exemptions for microenterprises — that is, those companies that have ten or fewer employees, or an annual balance sheet not exceeding 2 million euros. Reporting on the state of a company’s compliance is required and will be required every five years. Neither a lack of priority, a lack of time, nor a lack of knowledge will be considered permissible excuses. While implementation at the national level is up to the legislatures in those countries, the EAA states explicitly that penalties should be effective, proportionate, and dissuasive.
The goal is to eliminate and prevent barriers to free movement of products and services across member states, thereby strengthening the rights of persons with disabilities to access goods and services.
EU law by WiStudio from Noun Project (CCBY3.0)
What does all this really mean?
If you want to export ebooks to the EU market, you need to pay attention to the standards and meet or exceed them. If you want to sell content via a website to the enormous EU marketplace, you need to figure out what WCAG stands for and how to implement it on your digital presence (Web Content Accessibility Guidelines). If you have a reading app that you hope will be used anywhere in Europe, you will want to mind your Ps and Qs.
This legislation is poised to have a seismic effect on digital publishing by influencing both emerging and developed markets. Creating accessibility-compliant digital publications to sell or distribute in the EU helps lay the foundation for born-accessible ebooks that can be sold to other markets. It invariably helps refine the quality of content and provides access to a larger audience.
The EAA mandates that accessibility should be achieved by the systematic removal and prevention of barriers through a universal design approach. Born accessible content ensures that access for disabled people is prioritized on an equal basis in the marketplace. Following inclusive design principles means that we are creating content that is better for all readers.
The legislation doesn’t specify formats but some general guidelines for EPUB include the following:
Navigation via the table of contents (TOC) and the text using the titles to understand the general structure and hierarchy
Print-corollary page list
Robust HTML
Read and navigate the tables
Understand the content of images, graphics, and photos thanks to the alternative description of the images
If publishing in the PDF format, content should be tagged and optimized for screen readers, including:
Searchable text file, not a scan of pages in image format
Structure of the document must be identified by tags
Reading order must be clear, logical, and easy to follow
Every non-textual element in the document must have an alternate description
Content that is certified accessible by specialists might provide a level of quality control and help contribute to the next important part of meeting the requirements of EAA: describing it accurately for the market. Accessibility metadata is a powerful way to describe the accessibility of your content and to help readers find what they need.
There are three kinds of accessibility metadata that this rubric covers:
Schema.org metadata, i.e., the descriptors inside an EPUB
ONIX metadata, that is the XML file of data that travels alongside an ebook into the market and which includes all the detail about a book. Codelist 196 details all the possible values.
Conformance metadata detailing certification details
If a publisher has done the work to create certified accessible content, then that content must be adequately described for the marketplace. The EAA requires retailers to display accessibility information on their website, which means that distributors and aggregators who sell into the EU must bet read to adapt their repositories and backends to receive accessibility metadata so that at the next stage of the supply-chain pipeline, digital bookstores will be able to display detailed accessibility metadata. This means displaying information on the accessibility features of each file in the catalogue and, if possible, setting a search filter that allows for the creation of a specific section of all the accessible titles available or to filter only accessible ones. See this book on Vital Source for an example of what that looks like:
“This legislation is poised to have a seismic effect on digital publishing by influencing both emerging and developed markets.”
It’s Time
Every single part of the ebook supply chain is strongly encouraged to start adapting its workflows, to acquire the required technical knowledge, and to embrace the culture of accessibility. We need to create an accessible publishing ecosystem to ensure that all areas of our digital workflow, from content creation through to paying for ebooks online and the accessibility of our reading apps, are fully accessible. Every department in a publishing house has a role to play in complying with the requirements of the EAA.
Please reach out if you need help figuring out how to cleanse your publishing workflows. Software, metadata, publishing guidelines can be confusing. I am here to help!
