The European Accessibility Act: A Push for Accessible Publications

Logo for the European Disability ForumThis article was kindly submitted by Alejandro Moledo, New Technologies and Innovation Officer at the European Disability Forum.

The European Accessibility Act has the potential to make the European internal market more inclusive and accessible for 80 million persons with disabilities. In December 2015, the Commission released a proposal for a European Accessibility Act[1], which is now at its final stage of negotiations. Many aspects of the proposed Directive have been challenged by users, industry, and governments, but ebooks remain one of the items in which, thankfully, there is a broad consensus.

A Short Background

When the European Union (EU) was examined by the UN Committee on the Rights of Persons with Disabilities one of the main recommendations from the Committee[2] was to present this EU accessibility legislation which the European Disability Forum (EDF) and its members have been strongly advocating for, for many years. Three months later, the Commission launched the long-awaited European Accessibility Act (EAA), not without some surprises too.

Firstly, the EAA is an Internal Market Directive. This means that the Commission aims at harmonizing existing and potential national legislation on accessibility by setting out common accessibility requirements for certain products and services across the EU. This will benefit companies and public agencies alike, because, once adopted, the accessibility requirements of the Directive will be further detailed in standards and technical specifications that will be easily used and followed by them. No more different accessibility standards for different countries.  Everybody wins: citizens, companies, public agencies, and governments.

Secondly, the Commission introduced exemptions in cases of a disproportionate burden to implement accessibility, or when applying accessibility constitutes a fundamental alteration of the product or service. For instance, a special telephone with a simplified use for older people will not need to comply with all the accessibility requirements for smartphones. Obviously, it will need to be proved. The body entitled to check and enforce this legislation will be the different national market surveillance authorities. These authorities will have the power to request a company, for example, to fix the accessibility of a given product if they want to place it in the European market, or to impose penalties if the problems remain unsolved.

Even though the structure and the approach of the Directive were promising, the scope of the EAA was disappointing. The proposal has a very strong component on new technologies: ebooks, computers, operating systems, self-service terminals (e.g. ATMs, check-in machine, etc.), smartphones, telephony and emergency services, TVs and audiovisual services, banking services, and ecommerce. However, it also lacks crucial products such as household appliances and the approach to transport services was very limited. More importantly, accessibility requirements for the built environment were not mandatory. What is the point of having an accessible ATM if we cannot access the bank?

Additionally, the EAA proposal did include a very important aspect within its scope: the use of accessibility requirements in public procurement and use of EU funds. Other EU acts already require to “buy accessibly”, however they do not explain how to do it. The EAA details the requirements to achieve this and to ensure that taxpayers money will not be spent anymore on inaccessible products, services and facilities that discriminate persons with disabilities. Even industry organizations agree with us on the importance of including public procurement in the EAA[3].

For example, let’s imagine that a public authority wants to publish an ebook. When drafting the technical specifications of the tender, the accessibility requirements for ebooks, or the relevant standards that comply with those requirements, will need to be included in the call. Therefore, in order to be considered as an eligible bidder, the interested publishers will have to prove that they will publish an ebook that is accessible.

What Happened with the Proposal?

Once the proposal was presented by the European Commission, the European Parliament and the Council (representing EU Member States) began to propose changes to it, and the work of accessibility advocates has not been easy. Surprisingly, the European Parliament, which is often very supportive of the positions of civil society organizations, did not have a positive approach at the beginning. We did our utmost[4] to switch its initial position. The final report of the Parliament[5], voted in September 2017, does include some improvements, but also some deteriorations. On the positive side, the Parliament supports the inclusion of accessibility requirements for public procurement and EU funds, and proposes mandatory requirements for the built environment for the provision of certain services in some circumstances. It also broadens the scope of transport services to cover urban modes of transport as well, and adds accommodation services. However, it fully exempts all microenterprises, and excludes audiovisual content from the Act.

In parallel, EU Member States agreed on December 2017 on a common position[6] which does also contain some pro’s and con’s. The Council text excludes completely public procurement and EU funds from the Act, as well as any reference to the built environment. It does exempt microenterprises, but only those providing services, hence ensuring the importers and distributors will need to check whether a product complies with accessibility. Furthermore, regarding emergency services, Member States do not want to include requirements for the emergency centers – making accessible emerging communication impracticable. Nevertheless, the accessibility requirements proposed by the Council are more robust and comprehensive than the Parliament, which proposed requirements which were in some cases very vague or simply examples.

Having these two positions ready, the inter-institutional negotiations, known in Brussels as “trilogues” (Commission, Parliament and Council) started on March 5, and both the Parliament and the Council seem confident that, despite the difficult discussions ahead, the EAA might be adopted in 2018. For disability organizations getting the Act adopted this year is of high importance, as next year the EU will hold its elections and we do not want to miss the political momentum. Having said that, people with disabilities will not want just any Accessibility Act, and we keep advocating for a meaningful and ambitious Directive that truly makes a change in the everyday life of Europeans with disabilities.

And What About ebooks?

During the negotiations in the Parliament, EDF and the Federation of European Publishers jointly sent a letter to the Member of the European Parliament responsible for this file calling for the inclusion of two important aspects for the provision of accessible ebooks: the inclusion in the scope of the ereaders (both hardware and software), as well as the metadata on the accessibility of ebooks. These proposals were taken up by both the Parliament and the Council, and we can say that there are not big changes in their approach to these requirements. This means that there is almost certainty that these two aspects will be in the final text.

Both institutions do propose to add ereaders in the scope of the Directive. The ereaders will then have to comply with the general accessibility requirements for Information and Communication Technologies, including their user interface. Additionally, the ebook providers will also need to inform the users about the functioning of the service and its accessibility characteristics (i.e. the above-mentioned metadata). They will also have to design their websites and mobile applications in an accessible manner and provide information about complementarities with assistive technologies (e.g. screen readers, Braille displays, coupling with hearing technologies, etc.).

Finally, when it comes to the accessibility requirements of the ebooks themselves, the amendments introduced by the EU co-legislations clearly point at the characteristics of the EPUB 3 standard, which already incorporates accessibility guidelines. Thus, the proposed requirements in the Directive talk about access and navigation throughout the content, dynamic layouts, flexibility and choice in the presentation of content, prohibition of preventing assistive technologies to work properly and, among others, it also ensures that Digital Rights Management measures do not block accessibility measures.

All in all, it seems that legislators, users and the industry agree on adopting a European Directive that truly underpins the efforts to make publishing more inclusive and accessible. Despite the potential (and yet not decided) exclusion of microenterprises delivering services, including therefore ebooks, which will especially affect small publishers, the EAA can definitely have an impact in boosting accessible ebooks so that everybody in Europe will be able to enjoy reading them, no matter how they choose to read and through whatever device suits their purpose.

About EDF

The European Disability Forum is an independent NGO that defends the interests of 80 million Europeans with disabilities. EDF is a unique platform which brings together representative organization of persons with disabilities from across Europe. EDF is run by persons with disabilities and their families. We are a strong, united voice of persons with disabilities in Europe.









International Publishers Association calls on Publishers to Support the Accessible Books Consortium

The Accessible Books Consortium (ABC) is delighted that Michiel Kolman, President of the International Publishers Association (IPA) and Senior Vice President at Elsevier and Hugo Setzer, Vice-President of the IPA and CEO of Manual Moderno are encouraging publishers to support ABC and sign the ABC Charter for Accessible Publishing. Both Elsevier and Manual Moderno are signatories to the ABC Charter. Michiel Kolman’s call to action is available on youtube and their full interviews in the WIPO magazine

NNELS Accessible Publishing Workshop – Toronto

March 20th, 2018

This 3-hour workshop in Toronto is intended for people who know (or want to know!) some HTML and can navigate some of the inner workings of an EPUB file.

Laura Brady will demonstrate how code problems can trip up assistive technology, and how to clean an ebook’s markup while also giving hands-on comparisons of what works seamlessly and what gets snagged in various environments. Laura is an ebook developer, the principal of Brady Type, and the editor-in-chief of EPUB Secrets. She consults on workflow, tools, specifications, and production best practices.

Audience: ebook production staff, or other interested people such as consultants, alternate-format producers, editors, writers, librarians, and publishing students.

Cost: free!


March 20th, 2018


9-12 ET


900 Bay Street, Toronto, Canada

Learn More:

Further details about the event and how to attend are available on the workshop registration page.

Digital Publishing Summit Program Announced!

Logo for EDRLab the organizers of this conferenceEDRLab has announced the program for their annual Digital Publishing Summit (DPUB) which will take place in Berlin May 16-17, 2018. As ever the program is an exciting mix of tech presentations and high level sessions from the production of natively accessible ebooks to the spread of highly interoperable EPUB 3 reading applications on all platforms, with Readium LCP.  Delegates can expect plenty of practical demo sessions as EDRLab encourages adoption of open standards and software by the European publishing industry.

The program is of huge interest to accessible publishing, in particular the session on EPUB 3 as an accessible and mainstream format. Early bird pricing is available until February 28 and full information is online at the EDRLab website.

BIC Breakfast – Accessible eBooks, London

April 25th, 2018

Since 2013, BIC (Book Industry Communication) has run a series of informal, monthly breakfast sessions to provide an opportunity for anyone to discuss publishing, book supply chain issues, successes, and challenges of interest or concern within the book industry. Experts are invited along to share insights and swap ideas. Providing an overview of ebook accessibility, this BIC Breakfast will inform attendees about what is involved in the production of accessible, digital products and what organisations should consider when producing them. Richard Orme, Chief Executive Officer, DAISY Consortium will present Ace by DAISY which enables organisations to validate their EPUB files against internationally-recognised standards for accessibility.


April 25th, 2018


The Poetry Café, London, U.K.

Learn More

For details on how to register BIC has set up a page on eventbrite

Understanding ebooks, London

April 25th, 2018

Join publishing industry expert Ken Jones (@circularKen) for this one day Book Machine course to help you understand the ebook market and to gain some of the practical skills required to produce your own digital content. Accessibility plays an intrinsic part in successful ebook publishing and Ken will be looking at this as part of this fascinating insight.


April 25th, 2018


London, U.K.

Learn More:

Webinar on Digital Equality: The Importance of Accessibility in Your Publishing Strategy

February 28th, 2018

Compelled by clear ethical reasons and compliance requirements, most publishers are working to make content fully accessible. Creating content that is “born accessible” also opens up new opportunities for publishers to expand the reach of content and connect with new audiences and markets.

In this free webinar from napco media, you’ll learn:

  • How properly structured and tagged content improves discoverability and is the foundation for accessibility
  • What Section 508 and WCAG compliance means for publishers and their digital content
  • Practical tips to build accessibility into publishing workflows
  • How well structured content and metadata improves rendering for multiple formats and platforms, including HTML5 and EPUB3


February 28th, 2018


2pm ET, 11am PT

Learn More:

Further details on speakers and how to attend are available on the webinar registration page.

If Accessibility Is So Easy Now, Why Is It Still So Hard?

This post was kindly submitted by Bill Kasdorf, Principal at Kasdorf & AssociatesHeadshot of Bill Kasdorf, author of this piece and Principal at Kasdorf and Associates

I recently served as Guest Editor for the January 2018 issue of Learned Publishing, which is devoted entirely to the subject of accessibility. One of my roles, in addition to recruiting about half of the articles, was to contribute one.

Since I’m a consultant and work with a lot of different publishers, organizations, and service providers, the LP editors suggested that I try to quantify the costs and “level of effort” to make a publication accessible. How much does it cost to add image descriptions? How much does it cost to get MathML for equations? What’s the level of effort and cost to provide correct tagging—the structural semantics that assistive technology depends on? And so on.

I suspect that most people reading this blog on Inclusive Publishing are smiling and shaking their heads, thinking “good luck with that.” Not only will people not tell you what they pay, or what they charge, there is no one cost for any of those things—not to mention all the other things that can come into play, like closed captioning and transcripts for video, for example. The answer is always “it depends.”

Which is not helpful.

Accessibility is so much easier now! Isn’t it?

In addition to my consulting work, I participate in lots of industry standards initiatives and working groups. I’m very aware of current standards, and I see them coming. The result, due to my natural optimism, is that I have a tendency to say “Accessibility is way easier now than you realize! We finally have good clear specifications like EPUB Accessibility 1.0, and many specs and standards are built on top of the fundamental features of the Open Web Platform like HTML and WCAG and WAI-ARIA, and specifications are so much better aligned globally! And they’re based on technologies that publishers and their suppliers already use anyhow! And there’s help out there, like Benetech’s Global Certified Accessible program and the Ace by DAISY checking tool, to help you get things right!”

This is intended to be helpful.

And all that is true. But this is when my good friend Tzviya Siegman says “Bill! Quit telling people it’s easy! It’s not easy!”

And of course, as usual, she’s right.

Okay, it can still be hard.

It was clear what I really needed to write about: “Why accessibility is hard, and how to make it easier.”

Researching and writing that article was really fun, and illuminating. I interviewed a hand-picked group of people—trade, scholarly, and educational publishers and leading service providers—that I know to be working hard on accessibility, who I knew could provide me with good insights, and who I could trust to give me honest answers.

And they knew they could trust me not to divulge any proprietary or sensitive information. I needed them to be able to pull back the curtain and let me see into the details of what they do.

Boy, did they.

Successful publishers are working hard on this.

Because of the developments I cited above, it is actually true that many publishers have workflows that can create EPUB 3s that are pretty darn close to meeting accessibility requirements. Close but no cigar.

The folks that are making the best progress on this are devoting lots of effort into documentation and training. One big educational publisher I interviewed provides extensive accessibility education, which includes workshops, training sessions, and even office hours when staff and vendors alike can talk to accessibility experts. Another one commented on how often they have to fix the work their vendors do, and how bizarre it is that they have to train vendors that are usually more technically expert than the publisher is.

The top challenge: getting image descriptions right.

Issue number one, to nobody’s surprise, is image descriptions. You may think the issue is just that they need to do them. But there’s way more to it than that. They need to understand how to do them properly, and when not to do them. Don’t just repeat the caption in the alt text—how annoying is that, to have it read to you twice by your screen reader? The image description shouldn’t just say what the image is, it should say what it is there for, what it is trying to convey within a given context. This can require two distinct types of expertise: subject matter expertise, and an understanding of what a user of assistive technology needs.

Plus, there is a huge variation in what is involved in creating image descriptions based on the nature and purpose of the image. A major educational publisher provided me with documentation showing that the most complex image descriptions, when created offshore, cost 11.5 times as much as the simplest ones; when created domestically, the most complex image descriptions cost a whopping 23.5 times as much as the simplest ones!

Involve the author, even if they don’t do it perfectly.

Most publishers are skeptical of getting authors to supply image descriptions, and of course for some types of publishing the authors don’t even provide the images in the first place. But who knows better why an image is in the book than the author? The University of Michigan Press has actually made excellent progress on this. For certain books, supplying image descriptions is in the author contracts, and they have trained editors who work with the authors to guide the authors on how to do them properly. They just need some copyediting and QC like the rest of the manuscript.

This is exceptional in two senses: (1) fantastic that they’ve successfully moved the task upstream before production even begins, so the descriptions just have to be copyedited; but (2) an exception in the sense that very few publishers are able to do this yet. Still, it points the way.

One of the service providers I interviewed has a very sophisticated image submission system that automatically fixes problem images or guides the author in real time to fix them; authors love it. This system has the ability to capture not only alt text but an extended description built in. Virtually nobody’s using those features yet, but I can foresee a day when it is taken for granted that part of the process of providing an image for a publication will include providing an image description. That same vendor stressed that just getting the description from the author in the first place, even if it requires refinement and editing, reduces the cost of the image descriptions dramatically.

I won’t go into all of the other technical issues here—math is of course another big one, and tables; you can read the article, it’s open access (thanks, Wiley!). Instead, I want to talk about how clear it has become that accessibility is a multidimensional problem.

Three types of complexity.

The most obvious dimension is the complexity of the content. A properly tagged EPUB 3 of a novel or a straightforward nonfiction book can indeed be accessible from the get-go, maybe just missing the accessibility metadata but needing no further work. But as the content becomes more complicated, the level of effort goes up dramatically. We’ve already talked about images; and STM content is obvious, with its math and tabular content. As of this writing, we are still in fact waiting for a good solution to the MathML issue, and navigating a complex table with assistive technology is very, very tricky.

Another dimension is layout complexity. Sighted folks have no problem navigating multiple-column layouts, recognizing footnotes and sidebars and marginal items, dealing with boxes and pull quotes and runarounds. Those lovely print pages are a baffling maze or briar patch to the user of assistive technology unless a lot of thought is put into proper structural markup and navigation. That user needs a logical reading order, the ability to jump from section to section, and the capability to skip things or go back to things. Enabling that isn’t trivial.

And then there’s the issue of the file formats. It’s often necessary to make a publication accessible when all you have to start with is a Word file or a PDF. Sometimes those have some structure, but not always, and almost never the structure that assistive technology needs, namely proper HTML structural semantics and navigation between documents and resources. And don’t forget about PowerPoint files, and video and audio, and interactive features. Yipes!

Accessibility is everybody’s business.

Which leads to another dimension: everybody in the organization should be aware of accessibility and help to accomplish it. It should be discussed before a book is acquired or an article is submitted. Everybody handling the manuscript through the editorial and production process—including the vendors—needs to pay attention to it. And no matter how thoroughly and systematically it’s done, it always needs quality control.

I don’t want to undermine my optimistic stance that accessibility has gotten a lot easier. It has. But I have to admit that Tzviya was right: it’s still hard. And it should be obvious by now that trying to come up with some sort of easy metrics to assess the level of effort and cost to make a publication accessible—metrics that would be applicable across the board—is simply not possible. There are too many variables.

The solution is the workflow.

But there was one clear message from my study: the fundamental solution is workflow. The more publishers are able to build accessibility into their editorial and production workflows, the easier it is to make their publications accessible, and the lower the cost.

A final word: there is help out there. I mentioned two important resources at the beginning of this post.

Benetech’s Global Certified Accessible program provides in-depth analysis of EPUBs and recommendations to publishers, to help them build accessibility into their workflows, and then provides accreditation of those workflows once they prove to produce proper results. It’s not free, but it is an investment that will pay back many times, especially as the demand for publications to be accessible continues to grow.

And DAISY’s recently announced Ace by DAISY checking tool will be invaluable to publishers. It’s a free and highly customizable tool which is designed be integrated into publishing workflows; it systematically analyzes an EPUB for conformance to EPUB Accessibility 1.0, generating a report on its accessibility features and providing links to a fantastic knowledge base that explains what all the requirements are, including those that it finds lacking in your EPUB.

Accessibility is essential; you know that, or you probably wouldn’t be reading this in the first place.

The good news: it really is getting easier.

The DAISY Consortium Releases Ace, the Free EPUB Accessibility Checking Tool

Ace LogoThe DAISY Consortium is delighted to announce the launch of Ace by DAISY, the ground-breaking free and open source accessibility checking tool for ebooks created in the widely adopted EPUB format.

Ace by DAISY equips the publishing industry with a tool which can test their ebooks against internationally recognized standards for accessibility. Designed to assist content providers at any stage in their workflow, Ace by DAISY will make it easier to produce higher quaity, more accessible EPUB content files.

“Ace by DAISY is a significant step forwards, developed in partnership with the industry. It will help publishers achieve the shared goal of publication which can be enjoyed by everyone, irrespective of disability.” Richard Orme, CEO, The DAISY Consortium

This is the perfect time to encourage your technology teams to engage with this important new tool by integrating Ace within your workflows so that you can build accessibility requirements and testing into your product development at various stages.

Read the full Ace press release from The DAISY Consortium and visit the Ace by DAISY page for further information on getting started.

Learned Publishing Journal Focuses on Accessibility

Learned Publishing journal cover

Learned Publishing, the journal of the Association of Learned & Professional Society Publishers, published in collaboration with the Society for Scholarly Publishing, has dedicated its current edition to accessibility. Guest editor Bill Kasdorf (ApexCovantage) is passionate about all aspects of accessibility and chairs the Content Structure Committee at the Book Industry Study Group (BISG). Read by publishers, librarians, academics and others working in publishing around the world Learned Publishing has a fully international authorship.

“As confirmed in this special issue, accessibility is no longer a fringe topic — instead, publishing in a manner that is accessible to all is central to our purpose. All articles in this special issue will be freely available throughout 2018, as we believe the articles here will be a go-to reference point for all publishers, those with committed accessibility roadmaps and those just beginning to integrate accessibility into publishing workflows. This issue represents what we can do when we come together to address why and how our community can better serve all readers.” – Lettie Conrad, North American Editor of Learned Publishing

Articles include:

The full table of contents is available at: