Ebook Accessibility and the EAA: What Publishers, Retailers, and Self-Publishing Authors Must Do Now

The European Accessibility Act has been in force since 28 June 2025. For most digital industries, that deadline prompted a scramble around websites, apps, and checkout flows. For the publishing industry, the picture is more specific - and in some ways more demanding. The EAA explicitly names e-books, dedicated e-reading devices, e-reading software, and digital rights management (DRM) software as in-scope products and services. This is not a general web-accessibility obligation applied loosely to publishing. It is a direct, named requirement.

This guide is for publishers, ebook retailers and distributors, production and typesetting teams, and self-publishing authors selling into the EU. It covers what the law requires, what the technical standard looks like in practice, how the backlist obligation works, and what a realistic remediation plan looks like.

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What the EAA actually covers in publishing

The EAA establishes accessibility requirements for e-books, dedicated e-reading devices and software, digital rights management software, and e-commerce. That four-part scope is worth reading carefully, because each element carries distinct obligations.

E-books are classified as services under the directive. Publishers are considered service providers, as are other economic actors involved in the supply chain, including distributors, online retailers and libraries that loan digital books, websites and mobile apps, e-reading software, DRM solutions, and metadata aggregators.

Dedicated e-readers - Kindles, Kobos, and similar hardware - are classified as products. The EAA covers e-readers, defined as "dedicated equipment, including both hardware and software, used to access, navigate, read and use ebook files." E-readers must include a built-in synchronised text-to-speech technology.

DRM software is explicitly in scope. DRM should not block assistive technology from accessing the information. The requirement that digital rights management measures do not block accessibility features is satisfied by EPUB Accessibility 1.1, section Distribution. In practice, this means DRM implementations that prevent screen readers from reading text aloud - a common problem with older lock schemes - are non-compliant.

E-reading software - apps on phones, desktop reading programs, browser-based previews - falls under the scope of the EAA and must be designed with accessibility in mind.

The obligation is not limited to EU-based publishers. The EAA applies to anyone selling ebooks in the EU, regardless of where the author or publisher is based. A US academic press, a UK trade publisher post-Brexit, or a self-publishing author distributing through Amazon KDP's EU stores all fall within scope if their titles are available to EU consumers.

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The technical standard: EPUB Accessibility 1.1 and WCAG 2.1 AA

The EAA does not invent its own technical standard for ebooks. It references existing international standards - specifically, the EPUB Accessibility 1.1 specification and WCAG 2.1 Level AA.

The W3C's EPUB Accessibility - EU Accessibility Act Mapping note aims to demonstrate that the EPUB standard meets all the technical requirements related to e-books as defined by the EAA. This document, published at w3.org/TR/epub-a11y-eaa-mapping/, is the authoritative crosswalk between EPUB Accessibility 1.1 and the EAA's Annex I requirements. Production teams should treat it as the primary reference when mapping their workflow to legal obligations.

EPUB Accessibility 1.1 was published as a W3C Recommendation on 17 October 2024.

Why EPUB 3? The EPUB format has the necessary features required for a person with a print disability and is useful for people with other disabilities in line with EAA requirements. Its interoperability allows it to be supported by both consumer reading tools and equipment dedicated to people with disabilities. Books in EPUB format can be automatically vocalised, transcribed in electronic braille, enlarged, and modulated in their presentation. EPUB 3 is the most likely candidate to meet the demands of the EAA.

Providing at least one compliant format for a given title - for example, an accessible EPUB 3 alongside a fixed-layout PDF - can satisfy the requirement for that title. The obligation is to ensure the reader can access the content accessibly, not to make every format file accessible.

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What an accessible EPUB must contain

The following requirements flow from EPUB Accessibility 1.1 read against the EAA's Annex I. They apply to the content file itself.

Structure and navigation

• All ebooks must have a logical reading order, a table of contents (NCX or nav), and properly nested headings (h1-h6).
• Semantic markup using epub:type and ARIA roles for tables, lists, footnotes, and sidebars.
• Reflowable text: WCAG Success Criterion 1.4.10 Reflow (Level AA) applies, meaning content must reflow without horizontal scrolling at 400% zoom. Fixed-layout titles (comics, illustrated children's books, art books) face genuine technical constraints here - the EAA acknowledges this, but it does not exempt them from all requirements.

Images and non-text content

• Every image must include descriptive alt text. Decorative images must be marked as such (role="presentation").
• Complex images - charts, diagrams, maps - require extended descriptions, not just short alt text.
• Comprehensive image descriptions for ebooks must be provided in a manner consistent with the Act.

Language and metadata

• The primary language must be declared in the EPUB metadata, and language changes within the text must be marked.
• MathML for equations: mathematical content encoded as images is not accessible; MathML is the required markup.

Multimedia

• Accessible options for videos associated with ebook content must be captioned, and audio content associated with ebooks must have synchronised transcriptions.

Screen reader and assistive technology compatibility

• Content must not block text-to-speech engines. Pronunciation hints (SSML or PLS) should be provided for specialised terminology. The ebook store must comply with WCAG 2.1 Level AA at minimum.

Accessibility metadata - the discoverability requirement

This is the requirement most publishers underestimate. All EPUB publications must include schema.org accessibility metadata in the package document that exposes their accessible properties, regardless of whether the publications also meet the accessibility or optimization requirements.

The discovery section of the EPUB Accessibility specification identifies schema.org accessibility metadata that publishers must include in the EPUB package document. Required fields include: a list of all accessibility features (accessibilityFeature), the modes in which the content is expressed (accessMode), and any potential physical hazards the content might present (accessibilityHazard).

The EAA adds a consumer-facing dimension: the EAA requires that e-books include accessibility metadata. Online library and retail catalogues should present the accessibility metadata and the accessibilitySummary to assist in making the decision to select a title. This means the metadata must flow through your ONIX records to retail listings - it is not enough to embed it in the EPUB file if your distributor never surfaces it to buyers.

It is common in trade publishing for ONIX records to be provided to distributors, which is also where they will harvest metadata about the publication. If the ONIX accessibility fields are not completed, users may lose the ability to search and discover the accessibility properties.

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The backlist problem

The EAA applies to currently published titles in addition to a publisher's backlist. Any ebook that continues to be sold in the EU after 28 June 2025 is subject to the requirement - not just titles published after that date.

Several EU member states, including France and Italy, have provided a transition period until 2030 for backlist titles already on the market in 2025.

Several member states, including France and Italy, have provided a transition period until 2030 for backlist titles already on the market in 2025. But publishers should not treat this as a blanket EU-wide grace period. It applies only where national legislation has specifically provided for it, and only covers content already on the market before June 2025.

Other regions such as Finland and Denmark believe that the directive applies equally to existing and newly published titles and are implementing legislation and issuing guidance to support that approach. The safest assumption, absent confirmed national guidance for every market you sell into, is that backlist titles sold in the EU need to comply.

Remediating ebooks can generate high costs, due to the lack of appropriate tools, the level of complexity of different categories of books, or the difficulties in converting them related to the fact that they were created when the standards and the formats did not include accessibility features. That is a real constraint - but it is also an argument for prioritising, not for waiting.

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The micro-enterprise carve-out: read it carefully

The EAA includes an exemption for micro-enterprises. A micro-enterprise is defined as one that achieves an annual turnover not exceeding €2 million or an annual balance sheet total not exceeding €2 million. The first condition - fewer than 10 employees - must always be met, plus one of the two financial conditions.

The critical nuance for publishers: this is a critical distinction - the micro-enterprise exemption under the EAA applies only to micro-enterprises that provide services. The exemption does not apply to the ebook files themselves - only to the service (storefront/app) requirements. Even micro-publishers must produce accessible content.

In plain terms: a very small publisher (under 10 employees, under €2m turnover) may be exempt from making their website or app accessible, but the ebook files they sell are still expected to meet the content accessibility requirements. EU member states transpose the directive into national law and can add stricter requirements. Some member states may narrow the micro-enterprise exemption or impose separate accessibility obligations that apply regardless of business size.

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Enforcement: what the penalties look like

Each EU member state defines its own penalties. Enforcement approaches include market surveillance, complaints from consumers or advocacy organisations, and administrative fines. Some member states have proposed fines up to €100,000 per violation.

Under Germany's BFSG (the national EAA transposition), authorities may impose administrative fines of up to €100,000 per individual accessibility violation.

Violations of the EAA can result in marketing bans - both for products and for the provision of services - as well as fines of up to €100,000 per individual case. For publishers selling into Germany, the Abmahnung system also means competitors can file cease-and-desist claims without waiting for a regulator to act.

Beyond fines, non-compliance risks exclusion from public procurement contracts - a significant revenue stream for publishers selling to libraries, universities, and educational institutions.

Enforcement is intensifying through 2026 as national market surveillance authorities build capacity and consumer advocacy organisations begin filing complaints. See our EAA fines and penalties guide for a country-by-country breakdown.

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What counts as compliant: a summary

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Fixing your backlist: a practical approach

The backlist is where most publishers face the largest gap. A realistic remediation plan has five stages.

1. Audit metadata first - it is the fastest win. Run your existing EPUB files through Ace by DAISY, the open-source EPUB accessibility checker. The Ace App will review your EPUB file, note errors based on a variety of standards including the WCAG 2 Level AA standards for EAA compliance, and provide details about how to correct the error. Many backlist titles will fail primarily on missing or incomplete accessibility metadata - a fix that does not require touching the content itself.

2. Prioritise by commercial exposure. Prioritise your best-selling titles first - these have the most to lose from suppression. Titles actively sold in Germany, France, and the Netherlands face the most immediate enforcement risk given those countries' active market surveillance regimes.

3. Separate easy fixes from hard cases. Most fixes can be applied without touching the book's content. It is primarily structural and metadata changes. Text-heavy reflowable novels and non-fiction are far easier to remediate than image-heavy illustrated titles or fixed-layout children's books. There are technical limitations for certain types of fixed-layout publications, such as comics, illustrated children's books, and art books. For example, the flexibility and choice in the presentation of the content may not be available for these types of e-books. Treat these as a separate workstream requiring specialist resource.

4. Automate where possible, but do not rely on automation alone. Automated tools catch structural and metadata issues reliably. Alt text for meaningful images requires human judgement - automated tools cannot write accurate descriptions. Alt text entries can be created as part of the editorial process. There is a good argument that it may make sense to ask authors to provide alt text entries for their images when supplying art.

5. Build accessibility into the production pipeline going forward. Integrating accessibility early in the process - especially at authoring - significantly reduces costs. A born-accessible workflow costs a fraction of post-production remediation. Update your house style guide, your InDesign or Word templates, and your ONIX metadata workflow to include accessibility fields as standard outputs.

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Accessibility statements for publishers

The EAA also requires that accessibility information be provided to consumers before purchase. As content is made accessible, customers should have the information they need about the accessibility features of ebooks before the point of purchase. This means your retail listings, catalogue pages, and distributor metadata feeds need to surface the accessibility metadata embedded in your EPUB files.

Publishers operating their own storefronts also need an accessibility statement covering the website itself - separate from the per-title metadata. See our EAA overview for how the statement requirement fits into the broader compliance picture.

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The bottom line for publishers

The EAA is not a future concern for publishing. The EAA has applied since 28 June 2025, and any ebook sold to EU consumers after that date is subject to its requirements. The recognised technical path to compliance is EPUB 3 with EPUB Accessibility 1.1 conformance at WCAG 2.1 Level AA, with accessibility metadata flowing through to retail listings.

The backlist is the hardest part. Start with an Ace audit, prioritise by sales volume and market exposure, and treat fixed-layout titles as a separate problem. Build accessibility into every new title from day one - the cost of doing it at authoring is a fraction of remediation.

The obligation attaches to selling into the EU, not to being based there. If your titles are available on EU storefronts, the law applies to you.