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European Accessibility Act (EAA) – Ebook Compliance Guide

The European Accessibility Act (EAA) introduces mandatory accessibility requirements for digital products and services sold within the European Union, including ebooks. From June 28, 2025, all new publications made available in the EU market must comply with EAA accessibility standards. This article explains what publishers need to do to ensure compliance.

 

1. What Is the EAA?

The European Accessibility Act is an EU directive designed to ensure that digital products and services — including ebooks — are accessible to people with disabilities.

For publishers, this means:

  • Ebooks must be technically accessible

  • Accessibility features must be properly implemented

  • Accessibility metadata must be provided

  • An accessibility statement must be available

  • Documentation must be maintained

 

2. Accessibility Features Required in Ebooks

Your ebook files (typically EPUB format) should include the following accessibility features:

✔ Reflowable Text

  • Text must resize without loss of content or functionality.

  • Users must be able to adjust font size and layout.

✔ Logical Reading Order

  • Content must follow a clear, structured reading sequence.

  • Screen readers must interpret the book correctly.

✔ Alternative Text (Alt Text)

  • All meaningful images, charts, and diagrams must include descriptive alt text.

  • Decorative images should be properly marked as decorative.

✔ Proper Heading Structure & Semantic Markup

  • Use structured headings (H1, H2, H3).

  • Use semantic HTML tags within EPUB.

  • Avoid manual formatting that breaks structure.

✔ Assistive Technology Compatibility

  • Must work with:

    • Screen readers

    • Text-to-speech systems

    • Voice navigation tools

     

✔ Sufficient Color Contrast

  • Text must be readable against background.

  • Avoid low-contrast color combinations.

✔ Navigational Aids

  • Functional table of contents (TOC)

  • Page navigation markers

  • Internal links working correctly


✔ Accessible Tables & Forms (If Applicable)

  • Proper table headers

  • Clear cell associations

  • Logical tab order in forms

 

 

3. Accessibility Metadata Requirements

Accessibility is not only about file structure — metadata must clearly communicate accessibility features.

You must provide:

📌 ONIX Accessibility Metadata

Using ONIX Code List 196, include:

  • Accessibility features

  • Compliance standards

  • Hazards (if any)

📌 EPUB Accessibility Metadata

Embed accessibility information directly within the EPUB package.

📌 Certification of Compliance

Where applicable, reference standards such as:

  • WCAG 2.1

  • EN 301 549

 

📌 Accessibility Summary

Provide a clear description of:

  • Which accessibility features are included

  • Any known limitations

📌 Accessibility Hazards

Declare if the publication includes:

  • Flashing images

  • Motion effects

  • Audio without controls

 

4. Accessibility Statement (Mandatory)

Every publisher must create and maintain an Accessibility Statement.

The statement must include:

  • Description of accessibility features implemented

  • Known limitations or barriers

  • Contact information for accessibility support

  • Date of last accessibility review

 

This statement should be:

  • Available on your website, and/or

  • Included within the ebook itself

 

5. Documentation Requirements

You must maintain documentation demonstrating compliance with accessibility standards.

This may include:

  • Internal accessibility checklists

  • EPUB validation reports

  • WCAG audit documentation

  • Production workflow documentation

Authorities may request this documentation if compliance is reviewed.

 

6. Compliance Timeline

📅 June 28, 2025

  • All new publications made available after this date must comply.

  • Existing publications should be updated toward compliance where feasible.

 

Non-compliance may result in:

  • Market restrictions within the EU

  • Regulatory penalties

  • Distribution limitations

 

 

7. Technical Standard: Accessible EPUB (EPUB 3)

Most accessible ebooks are created using:

  • EPUB 3.x format

  • WCAG-aligned semantic structure

  • Proper ARIA roles and landmarks

EPUB 3.3 is the current technical specification and supports accessibility best practices.

 

8. Practical Steps for Publishers

To prepare for EAA compliance:

  1. Audit your production workflow

  2. Update EPUB export settings

  3. Train designers and formatters on semantic structure

  4. Implement accessibility metadata processes

  5. Create a standardized accessibility statement template

  6. Document compliance procedures

 

 

9. Summary

To comply with the European Accessibility Act, publishers must ensure:

 

✔ Technically accessible EPUB files

✔ Proper accessibility metadata

✔ Public accessibility statement

✔ Maintained compliance documentation

✔ Timely implementation by June 28, 2025

 

Accessibility is no longer optional for EU distribution — it is a legal requirement.