Tag Archive for: EAA

Counting Down to the European Accessibility Act

image of the EU flag amongst full bookcases and a desk piled high with books

With a little over 12 months to go until the European Accessibility Act comes into force the DAISY Consortium is excited to bring you the next season of their highly regarded webinar series, entitled, “Counting Down to the EAA”.

There is much work still to be done in preparation for the new directive and, with this in mind, we want to bring our audience the very latest news, solutions and thoughts on various important topics of greatest interest to the publishing community.

Below you can find details of the first 4 webinars which are free to attend, will be packed full of resources, top tips and discussion points that you will not want to miss out on. Further webinars in the series will be announced in the coming months.

Countdown to EAA – T-367 Days

Jun-26 14 UTC

We kick-off this countdown series with an introduction to the EAA itself, exploring the implications for people involved in publishing and reading, and talking to industry professionals actively working to prepare their organizations and others.

Technical Approaches to Upgrading the Backlist – T-339 Days

Jul-24 14 UTC

The complexity of reworking existing materials to incorporate accessibility can vary greatly depending on the nature of the published content. There are however a series of strategies that, if adopted, can aid the rework process. In this webinar we will hear from those actively involved in supporting the rework of backlist titles to ensure they’re compliant with EAA.

Accessibility Testing – T-304 Days

Aug-28 14 UTC

Access to digital publications under the EAA requires the alignment of multiple platforms and technologies to deliver an accessible user experience from discovery to consumption. In this webinar, subject experts will explore the diverse range of tests and assessments, both automated and manual, that can be performed to help refine the user experience and ultimately ensure a content journey that supports accessibility.

Image Descriptions – T-269 Days

Sep-25 14 UTC

Authoring accurate, informative, yet concise image descriptions can sometimes feel like an art. When you add methods for authoring and implementing extended descriptions it is easy to appreciate how complex things can feel. This webinar will discuss the practical workflow approaches taken by a number of publishers to ensure image descriptions for both front and back list titles are authored in a timely fashion and to a high quality.

European Inclusive Publishing Forum – Update

The DAISY AGM this year included a presentation on the European Inclusive Publishing Forum which DAISY hosts to enable the sharing of information and practices from across Europe to support the publishing community in preparing for the European Accessibility Act.

Read the full details from each of the case studies mentioned in the video:

Visit the DAISY Consortium website for further details on the European Inclusive Publishing Forum.

EAA Case Study: Lithuania

The EU flag with an icon of The Gediminas Castle Tower in Vilnius in the middleThe European Accessibility Act has galvanized many European countries and The DAISY Consortium has been pleased to take part in many interesting and collaborative conversations with partners, members and interested parties.

Each country has their own story and their own unique set of experiences in approach to the EAA and we are attempting to capture some of these in our new series of case-studies. The more we can share and learn from each other, the better prepared we hope everyone will be.  


This case study looks at the work undertaken in Lithuania where we spoke with Inga Davidoniene from The Lithuanian Library for the Blind  (LLB). Founded in 1966, LLB’s purpose is to “meet the informational and cultural needs of people who are not able to read regular printed text”. LLB is the largest producer of content in accessible formats (braille, audio, DAISY) in the country. With this in mind, LLB has 4 major focus areas:

  • To produce publications in traditional accessible formats and to experiment with new formats and ways to meet users’ needs  and to meet the requirements of European legislation
  • To foster cooperation with publishing organisations in Lithuania
  • To increase awareness on inclusive publishing
  • To bridge the gap between publishers and readers with specific needs

Preparation for the European Accessibility Act neatly falls into all four of these work areas!

The digital publishing market in Lithuania is fairly small, with 200 publishers producing approximately 500 ebooks per year, either in EPUB or PDF. Up to this point, consideration of the accessibility features available in both formats has not been high on publishers’ priority lists and there is a noticeable lack of awareness in the market. Accessibility is a new topic for publishers here and LLB has been actively trying to show the industry that accessible books are good for business, demonstrating how they can connect with a new audience. More than half a million people in Lithuania are not able to read printed books. It’s very important for publishers identify this audience and for people with special needs to receive the books in the format they need. LLB acts as bridge between these two groups. This approach is working very well and at a recent mainstream event it was noted:

Our Future is Accessibility

This was a major milestone for Inga and her team.

Industry and International Collaboration to Increase Awareness

Implementation of the EAA in Lithuania is the responsibility of The Ministry of Social Security and Labour and a draft of the new domestic accessibility legislation is expected soon. The ministry set up a working group aiming to transpose the EEA into national law and it includes representatives from other ministries together with delegates from public and private institutions. LLB is a member of this working group and participates in all activities and discussions about accessibility.

As yet, there are no firm implementation plans for the EAA but the forum is working towards this goal and are at the early stages. Ministry funding is expected to be made available this year in order to develop this formal approach.

In addition to this, in 2021 LLB invited publishers, disability organizations and delegates from the ministries of Culture, Education, Science and Sport and Social Security and Labour to talk about accessible text-books. By bringing together so many stakeholders it was possible to concentrate on how the EAA will affect the publishing industry in Lithuania, particularly considering that from 2024 all Lithuanian schools will be obliged to admit all students with individual needs.

LLB also promotes international collaboration and knowledge exchange in this field. In 2003, Lithuania joined the Federation of European Publishers and a close collaboration with FEP has allowed further European connections to develop. Working together with the LIA Foundation in Italy, for example, has enabled the Lithuanian market to build on their need for guidance and training with the LIA guidance being translated at the end of 2021.

Raising Awareness via Events

Raising awareness via industry events has been a key part of the EAA implementation strategy in Lithuania and LLB works closely with the Lithuanian Publishers Association  to set these up. In 2020 the online seminar “What do you need to know about the European Accessibility Act” included representatives from FEP and LIA  and this event kick-started future gatherings in Lithuania.

The Lithuanian Publishers Forum, held in 2021 discussed the topic “Books For All” and, as a result, publishers are now inviting Inga and her colleagues to speak at industry and in-house events which has been crucial for awareness building and EAA preparation.

During Book Week 2022, Inga chaired a panel discussion entitled “What do those who read differently read?” A discussion with readers about various book formats explored the need for accessible content and received much attention during this high profile week.

The Personal Touch

Publishers are beginning to take notice and to understand the importance of accessible content. Inga remarked that individual discussions with publishers are the most effective way to convey the accessibility message and to introduce colleagues to their virtual library service “ELVIS” which carries the possibility of attracting new audiences. ELVIS is one of the most important products created by LLB, allowing people with reading disabilities to look for and access their desired accessible publications at home. This service is adapted to the needs of visually impaired users – the system has a simple user interface, the possibility to change the print size, colours of the text and screen background. Currently 14,400 accessible book titles are available on ELVIS. Books are available in different formats including: audio, DAISY, accessible PDF and digital braille. Users can read/listen to books by streaming them online or downloading to their devices. Until recently, only publications created by LLB were available on ELVIS but, since 2022, the virtual library also makes available ebooks and audio books acquired from publishers.

Top Tips for Other Publishers on Their Accessibility Journey

  • Be stubborn and stick with it! This process is slow and it’s important to take small steps to achieve your goal.
  • Understand how international colleagues are progressing and learn from them.

Our thanks to Inga for her collaboration on this case-study. If you are interested in the work being done by LLB in this area or would be interested in taking part in a similar case-study please contact us for further information. The other case-studies in this series are available on our EAA Resources page.


European Accessibility Act – Baseline Readiness Survey Results

The EU flagThe clock is ticking. The European Accessibility Act is coming and will impact the way many publishers globally produce content that is sold in the European Union irrespective of where it originated.

The EU Accessibility Act is currently being transposed into national laws which will be complete by June 28, 2022, and the Act itself is scheduled to come into force on June 28, 2025. At the time of authoring this article, we have over 3 years before that date which may feel like a healthy amount of time. However, we all know that change and particularly change to established business practices can take a significant amount of time to implement correctly.

Throughout Europe some government entities, non-profit organizations, publishing associations, and publishers have been collaborating to raise awareness of the EU Accessibility Act, supporting publishers and organizations in their supply chain to learn about accessibility, and starting to prepare for the Act. Anecdotal evidence suggested that while some regions are actively progressing this activity, other regions have made little or no progress at all.

To gain an understanding of the activity taking place throughout Europe, encourage sharing of practices, and signpost the available resources, a survey was conducted. This work was coordinated through the DAISY Consortium hosted EU Inclusive Publishing Forum, a collaboration network of organizations supporting the implementation of the European Accessibility Act as it relates to digital publications.

This baseline survey was conducted to assess the current activities of EU Members, including identifying:

  • If any government ministries are engaged.
  • Establishing if a stakeholder platform has been created.
  • Identifying any training in place.
  • Reporting how ready they believed they are.
  • Finally, identifying what more might be needed.

Promoted through the network and disseminated directly to people in EU member countries to complete the survey was sent to as many people as practical to respond on behalf of their country. It did however prove challenging to find a suitable individual, organization, or government department in every country, especially some of the smaller EU countries.

To encourage participation in the survey it was agreed that no identifiable information would be publicly shared about any of the responding countries, but a list of the participating countries can be found at the bottom of this page.

Responses were received from only 14 of the 27 EU members, however those regions responding cover 74% of the EU population. We can only speculate as to why some countries did not respond, but there are likely to be two primary reasons:

  1. Communication difficulties – the survey not finding someone in a suitable position to respond, or messages being misplaced.
  2. Lack of meaningful activity – there is little motivation to complete a survey to measure activity on a topic when no meaningful activity is currently taking place.

The countries who did respond reported a broad range of experiences and activities through the survey, with some countries responding multiple times offering slightly differing perspectives. This indicated that while some activity in preparing for the European Accessibility Act was underway, some of the respondents are still at the early part of this journey, and communication between interested parties (government departments, the publishing community, and beneficiary groups) had scope for improvement.

Government Involvement

Despite governments actively progressing the requirement to transpose EAA into national laws, the survey found only half of the countries that responded had a government ministry assigned to support the implementation of the Act. Some countries had multiple government departments actively involved in supporting the implementation of the Act, typically with one department leading. Whereas other countries highlighted challenges between legislation implemented at the national level impacted practices governed regionally.

Stakeholder Groups

Only half of the respondents reported having a steering group or stakeholder platform to guide and advise on accessible publishing and reading.

Those responding with active groups reported benefiting from have participation from publishers, publisher associations, disability organizations, and sometimes also government representation.

Training and Resources

At the time of responding only 4 of the 14 countries responding had any web-based resources designed to support awareness and implementation of accessible publishing in their country, although some indicated that work was underway to create online resources. The availability of training was reported by 5 countries, which ranged from trainers in other countries being brought in to assist in educating publishers through in-person courses, to online resources being developed. Participation at mainstream publishing conferences and the hosting of special events were also reported.


When asked to rate their current state of readiness only 2 were confident that everything was in hand, reporting that there was a plan which was on track. Most respondents (9) highlighted that activity was taking place but concerns remained about being ready. 3 responses were received indicating some alarm that very little seemed to be happening. In some instances of duplicate responses, government entities reported being more confident in their readiness than other organizations actively involved in the process.


Finally, a broad range of pressing needs were identified, including the following themes:

  • Awareness-raising: concern was highlighted about communication within the publishing community and all parts of the supply chain to ensure everyone was conscious of their roles and responsibilities.
  • Training: even some of the countries with training available highlighted the need for further training resources to upskill staff in all areas of publishing.
  • Clarity over EAA requirements: progress continues in defining the practices and measures of accessibility in different formats, as well as defining the terms associated with exclusion and implementation (disproportionate burden, fundamental alteration, monitoring, reporting)

Next Steps

The survey highlighted that some excellent work was already taking place throughout the EU to prepare the publishing industry for the implementation of EAA, but all indications suggest that significant work remains in readiness for June 2025.

Collaboration between countries, sharing of best practices, training resources, and involvement in the DAISY Inclusive Publishing Forum all offer promise for the future.

We aim to repeat this survey as we progress towards 2025, tracking the progress of countries in preparing for the Act and facilitating sharing resources and best practices between active parties.


Thanks to members of the DAISY Consortium EU Inclusive Publishing Forum for supporting this activity, and to all the respondents who completed the survey from the following countries: Austria, Belgium, Denmark, Estonia, Finland, France, Germany, Ireland, Italy, Lithuania, Slovenia, Spain, Sweden, The Netherlands.

Further information

EU Accessibility Act: Update (W)

EU Accessibility Act - Update Cover slideIn our series of free weekly webinars December 1st saw a session focused on the European Accessibility Act giving us a chance to check-in and find out the latest updates as we prepare for the act.

This page contains:

Full Video of the Webinar


  • Richard Orme, DAISY Consortium—host and chair
  • Antoine Fobe, European Blind Union
  • Cristina Mussinellim, The LIA Foundation
  • Thomas Kahlisch, dzb lesen

with contributions from:

  • Louis Marle, Albin Michel, France
  • Oscar Heslinga, Inginitas Learning, Netherlands
  • Jonas Lillqvist, Svenska Litteratursällskapet, Finland

Session Overview

This webinar discussed the implementation progress and latest developments in EAA legislation which is already shaping practices in Europe and around the world. Many organizations that sell into Europe are having to adapt their practices to comply with the new accessibility requirements.

The European Accessibility Act: Why, What and When?

Antoine Forbe began the webinar by giving us an essential refresher to the EAA, reminding us that it is essential for approx 80 million people in Europe who rely on accessible content. It became necessary to develop a single, coherent set of accessibility rules and in 2015 the European Commission proposed a wide-reaching accessibility act. After long periods of negotiation, the EAA was adopted in 2019, creating an obligation for member states to ensure that selected products and services placed in the EU market comply with accessibility requirements. There are many benefits, including:

For Businesses

  • A reduction in costs for the production of accessible goods
  • Easier cross border trading
  • Marketing opportunities for accessible products and services

For Citizens

  • More accessible products in the market
  • Competitively priced products
  • Fewer barriers to access
  • More jobs where accessibility expertise is needed

The act is not truly horizontal in that it applies to only a select list of products and services, with specific emphasis on digital. It does, however, bring a comprehensive set of minimum accessibility requirements that all businesses must respect and this is a wonderful step in the right direction. The act will have a wide impact on the publishing industry throughout the supply chain.

Requiring national transposition by June 2022, the EAA is in fact a directive, the entry into force date is 2025.

Update on Technical Developments

Cristina Mussinelli spoke to us about digital publishing standards that are important in meeting the requirements of the EAA directive.

EPUB offers the greatest opportunity for the econtent itself and a new version, EPUB 3.3, is due to be published soon. Accessibility requirements are one of the main areas of focus within the standard and it is accompanied by EPUB Accessibility 1.1, an accessibility specification together with the Digital Publishing WAI-ARIA Module 1.1.

Metadata standards are vital for the end-user in order to inform the reader about accessible content. The following standards need to be adhered to: schema.org within the EPUB package, ONIX to directly inform the retailer and coming soon, a standardized method of describing content accessibility from W3C.

Work and research have been completed to make sure that these standards are robust enough to meet the requirements of the EAA.

For retailers and libraries, the W3C has recently published the User Experience Guide for Displaying Accessibility Metadata 1.0

Work continues in this area to look at other ebook formats, all the various departments in the publishing supply chain and a focus on end user awareness.

DAISY’s EU Inclusive Publishing Initiative

Thomas Kahlisch explained the work of The DAISY Consortium and its efforts to improve collaboration between the organizations involved in the EAA and the publishing industry via a community network.

Areas of focus include: guidance, survey, case studies and signposting of resources. The survey was sent out to all EU countries and we have heard back from 14 (74% of the market). The complete findings will be published in January 2022 but results already show that countries are at very different stages in their preparation for the EAA. Some countries have steering groups which help to connect and collaborate both nationally and internationally.

Case studies from Finland, The Netherlands, Germany and Italy look more closely at some of the preparatory details and materials that are already being used and we look forward to publishing more of these country-specific studies as part of the EU Inclusive Publishing Initiative.

Thomas finished by drawing attention to the variety of resources available on this good work at Inclusive Publishing’s EAA Resource page which includes details of how to collaborate with the EU Inclusive Publishing Initiative.

Publisher Voices

Previous webinars about the EAA have emphasized the importance of starting to prepare now for 2025 and many publishers have begun their journey towards accessible publishing already. We heard from Luis Marle, Albin Michel, France; Oscar Heslinga, Inginitas Learning, Netherlands; Jonas Lillqvist, Svenska Litteratursällskapet, Finland on the progress they have been making, informing us of some of the lessons they learned on the way. Please take the time to listen to their extremely useful advice.

Related Resources

Legislation Resources

Standards and Technical Developments

Communication Activities

Discover the other webinars we’re running!

EAA Case Study: Germany

The European flag with an icon of The Brandenburg Gate in the centerThe European Accessibility Act has galvanized many European countries and The DAISY Consortium has been pleased to take part in many interesting and collaborative conversations with partners, members and interested parties.

Each country has their own story and their own unique set of experiences in approach to the EAA and we are attempting to capture some of these in our new series of case studies. The more we can share and learn from each other, the better prepared we hope everyone will be.


This case study looks at some of the work underway in Germany where The EAA has already been transposed into national law. We spoke with Dana Minnemann from dzb lesen, the German centre for Accessible Reading, and Kristina Kramer from Börsenverein des Deutschen Buchhandels, the German Publishers and Booksellers Association, 2 organizations who are very connected with their accessible publishing focus. Germany is one of the first countries to produce a text for implementation from the Federal Ministry for Labour and Social Affairs (Bundesministerium für Arbeit und Soziales) 

The publishing landscape in Germany is large and varied with digital publishing seeing something of a boom recently which has helped to turn publisher’s attention towards the accessibility of their digital content. Awareness surrounding accessible publishing has been influenced by the mandatory legislation although many publishers remain unaware about how to implement accessibility within their current workflows and are looking for guidance in this area.  The STM sector is probably the furthest ahead in their accessibility journey but is fair to say that the industry, as a whole feels, a new sense of responsibility. 

In Germany EPUB 3 is used extensively in the trade fiction market and a born accessible content checker is used in conjunction with these files which is an adaptation of the Ace by DAISY EPUB checker. Plans are to switch over to the mainstream Ace checker. The German publishing industry supports and closely follows the work done by FEP and The Lia Foundation in advocating for the use of EPUB 3 and this has helped to build awareness. 

Industry Task Force 

In December 2020 a Task Force was convened to bring together approximately 30 experts who meet every 6-8 weeks to discuss next steps, concepts for seminars, training courses and webinars. The task force concentrates on articulating the needs of each sector and includes participants from each area of publishing together with colleagues from Austria and Switzerland (both German-speaking markets). The task force works on a collaborative approach for all areas of the industry. 

The task force has produced industry documentation in German and these are housed in an accessibility area on the Publishers Association website alongside links to material that has been developed by other international partners. Guidelines such as a checklist for EPUB 3, together with best practice reports will be available on this site. 

The Publishers Association has close connections with international partners such as Federation of European Publishers, the International Publishers Association and the Accessible Books Consortium.  

Challenges Ahead 

For the German market there are a number of challenges that Dana and Kristina foresee in the future: 

  • Funding: dzb lesen and Börsenverein have applied for financial support from the Federal Ministry in order to be able to develop further training and seminars. 
  • The Backlist – questions over how to handle accessibility for legacy content remain and it is currently unclear as to whether publishers will be required to attend to this content and how this might be achieved. Costs surrounding this are also a concern. 
  • The text itself in the EAA directive is, at times, unclear and there are quite a few open questions that exist which may affect the recommendations that the task force are making. In particular, questions over how detailed alt text needs to be for specialist content has caused uncertainty amongst members. Where questions like this arise, the task force tends to refer back to guidance from the DAISY Consortium. 
  • Awareness around accessibility in the workflow and how to cater to the many different types of workflow that are utilized will be a challenge moving forward, but the task force are tackling this. 
  • Metadata and what exactly needs to be filled in by the publisher  

Final Thoughts for Other Publishers 

The time is golden right now 

Kristina urged all publishers to seize the moment and to treat the EAA has a huge opportunity for change 

Both organizations involved in this case study have commented that their collaboration and connection in this project has been fundamental for the successful implementation of the EAA in this market.  

Our thanks to Dana and Kristina for their collaboration on this case-study. If you are interested in the work being done in the German market or would be interested in taking part in a similar case-study please contact us for further information.   

Resources and Links 

EAA Case Study: Finland

The EU flag with a landmark icon of Helsinki's cathedral placed in the middleThe European Accessibility Act has galvanized many European countries and The DAISY Consortium has been pleased to take part in many interesting and collaborative conversations with partners, members and interested parties.

Each country has their own story and their own unique set of experiences in approach to the EAA and we are attempting to capture some of these in our new series of case studies. The more we can share and learn from each other, the better prepared we hope everyone will be.  


First up is Finland, a country with two official languages, Finnish and Swedish, and with a relatively small book market. We had the pleasure of speaking with Miia Kirsi from Celia who are integral to the Finnish approach to the EAA. Celia, the national library for accessible literature and publishing in Finland, works towards equality in reading and learning and belongs to the administrative sector of the Ministry of Education and Culture.  

Publishing houses in Finland tend to be small and, in accordance with the EAA, micro-enterprises are not necessarily required to adhere to the new legislation. The hope is that everyone will make the effort to comply, irrespective of their size.  Audio publishing, and consequently all forms of digital publishing, is experiencing something of a boom in Finland and in 2020 the ebook market represented 4500 titles.  Not bad for a population of just 5 million! 

With regards to accessibility, it is far to say that for many this is still an afterthought in Finland. Education publishers are probably furthest ahead because of accessibility requirements for students. Ironically, trade publishers, for whom the accessibility challenge is arguably the most straightforward, are not doing so well and publishers don’t tend to consider the user experience. 

Stakeholder Platforms and Industry Collaboration 

In Finland, various government ministries are responsible for the implementation of the EAA. To foster collaboration there have been intra-ministerial meetings to which all stakeholders have been invited  

Celia works hard with other stakeholders to address challenges and their close collaboration with The Finnish Publishers Association is particularly important.  On October 6th they are co-hosting a seminar “Accessible Ebooks: From Directive to Practice”. Together, both organizations are actively advocating for EPUB 3 and are looking for ways to provide training in this area.  

Celia also takes part in the Nordic Inclusive Publishing Initiative (NIPI) which meets twice a month to share information. The group has members from all five Nordic countries and organized an online accessibility conference Include! in November 2020. There are plans for another conference focusing on Inclusive Publishing for Spring 2023. 

Pilot Project to Assess Digital Files 

Of the 4500 digital titles produced in Finland annually, the majority are produced in EPUB 2 – something which Miia and her team explored during their Accessible EPUBs Pilot this year. The main goals of this project were: 

  • To assess the current accessibility status of EPUB files 
  • To gather information about typical EPUB workflows 
  • To identify risks and weaknesses in the production of accessible content  
  • To identify and develop materials that are needed 

It appears that publishers are not tending to specify EPUB 3 – many are used to working with print-based workflow models so aren’t inclined to change. That being said, many of the files that were examined for this project did include accessibility features and were more accessible than expected. All had some semantic markup and many of them included a Table of Contents. They weren’t “accessible” per se but a move towards EPUB 3 could hail great improvements.  

Other areas that need attention are: 

  • The use of accessibility metadata 
  • XHTML files need improving – correct use of language tags etc 
  • Inclusion of alt text 

What is apparent from this project is that the publishing industry in Finland still looks to the print version first with the digital version being an afterthought. Digital files are not given the same level of scrutiny as print PDFs are given. 

Challenges in this Market 

  • Post-production work for InDesign files needs attention 
  • Responsibility: everyone needs to take an element of responsibility throughout the publishing workflow 
  • Knowledge and Awareness needs improving  
  • Understanding of Tools and Solutions  

Implementation Plans and Resources 

The government has prepared an implementation plan: The National Implementation of the Accessibility Directive for Products and Services (provided here in Swedish for easier translation). This is an ongoing project looking at all areas of implementation within the Finnish market. 

The Finnish Publishers Association and Celia plan to collaborate on various fronts to help the publishing industry prepare for the requirements of the EAA, to find reliable resources and obtain information about accessible publishing in Finnish or Swedish, all to be made available on a website that will point users to the correct path. 

Top Tips for Other Publishers on their Accessibility Journey 

  • Use InDesign more effectively!  
  • Educate all departments within a publishing workflow about the role they need to play. 
  • Not all areas can necessarily be outsourced – awareness about accessibility needs to be addressed in-house also.
  • Metadata needs early attention and training for in-house staff on the importance of accessibility metadata is vital. 

Our thanks to Miia for her collaboration on this case study. If you are interested in the work being done by Celia in this area or would be interested in taking part in a similar case study please contact us for further information.  

Resources and Links 

EPUB Accessibility: EU Accessibility Act Mapping

The European Accessibility Act (EAA) is an EU directive that establishes accessibility targets to be met by many different types of products and services in order to strengthen the rights of people with disabilities. It is relevant for the publishing industry as it includes ebooks, dedicated reading software, ereading devices and ecommerce sites.

W3C’s EPUB 3 Working Group has published a working group note demonstrating that the technical requirements of the European Accessibility Act related to ebooks are met by the EPUB standard.

Further information on this is available in the Working Group note.

Inclusive Publishing has a number of pages referring to the European Accessibility Act:

European Accessibility Act Requirements: Are Publishing Standards Fully Compliant?

The EU flagThe European Accessibility Act (EAA) is an EU directive establishing accessibility targets that must be met by many different types of products and services to strengthen the rights of people with disabilities. It is relevant for the publishing industry as it includes ebooks, dedicated reading software, ereading devices and ecommerce sites.

It is important for the publishing industry to get ready in preparation for June 2025 and a group of relevant stakeholders have put together a report on publishing standards so that the technical requirements of the directive can be met. Ideally, existing standards will provide the bedrock of this guidance, with the aim of fostering their adoption in time for EAA compliance.


Stakeholders and Authors

  • Federation of European Publishers, representing more than 29 EU Publishers’ Associations (FEP)
  • W3C Accessibility Task Force (EPUB 3 working group)
  • The LIA Foundation
  • Luc Audrain

What does the European Accessibility Act Mean for Global Publishing?

Flags of the member states of the European Union in front of the EU-commission buildingDirective (EU) 2019/882 of the European Parliament and of the Council on the accessibility requirements for products and services

Our thanks to Laura Brady (House of Anansi) and Tzviya Siegman (John Wiley & Sons) for this article.

The European Accessibility Act

What do publishers around the world need to know about the European Accessibility Act? This legislation is some of the strongest we’ve seen around accessibility and will force change, without question. If publishers plan to sell digital products into the European Union in the near future, they must get up to speed on what this means for their workflows.

So, what is the legislation exactly? The EAA is a directive that aims to improve the functioning of the internal market for accessible products and services, by removing barriers created by divergent rules in Member States.

Businesses will benefit from:

  • common rules on accessibility in the EU leading to costs reduction
  • easier cross-border trading
  • more market opportunities for their accessible products and services

Persons with disabilities and elderly people will benefit from:

  • more accessible products and services in the market
  • accessible products and services at more competitive prices
  • fewer barriers when accessing transport, education and the open labour market
  • more jobs available where accessibility expertise is needed

The Directive entered into force in June 2019.  Member states have until 28 June 2022 to adopt and publish the laws, regulations and administrative provisions necessary to comply with this Directive. This means introducing new and/or updating existing national legislations to comply with its principles and requirements. The full force of the legislation comes into effect on June 28, 2025.

The legislation follows market-driven standards, requiring publishers to produce their digital publications in an accessible format  It also requires the entire supply chain (retailers, e-commerce sites, hardware and software reading solutions, online platforms, DRM solutions, etc.) to make content available to users through accessible services.

The EAA hinges on the discoverability of products and services by end users. Using international standards for accessibility , such as EPUB 3, and describing the accessibility features within the content with schema.org and ONIX metadata enables publishers to expose metadata on retailer and publisher websites, which is crucial.

General Summary

The legislation applies to products and services placed on the market after June 2025

These include:

  • Hardware
  • Software
  • Websites
  • Mobile Apps
  • ecommerce
  • ereaders
  • ebooks and dedicated software
  • all products and services, including information about how to use above, user sign in, and identity management

There are several factors which allow specific organisations to be exempt from compliance. In addition, the directive does not apply to the following types of content on websites and apps:

  • Pre-recorded time-based media published before 28 June 2025.
  • Office file format documents published before 25 June 2025.
  • Online maps; though if the map is used for navigational purposes then the essential information must be provided in accessible format.
  • Third party content that is entirely out of the control of the website or app owner.
  • Reproductions of items in heritage collections which are too fragile or expensive to digitise.
  • The content of web sites and apps which are considered archival, meaning they are not needed for active administrative purposes and are no longer updated or edited.
  • The web sites of schools, kindergartens, and nurseries, except for content pertaining to administrative functions.

Service Providers must prepare necessary information and explain how services meet this act.

All accessibility information must remain private.

In general, this follows the same principles as WCAG’s Perceivable, Operable, Understandable, Robust model, but it points to specific outcomes. The requirements of this legislation incorporate many types of disabilities, including cognitive disabilities, which have only begun to be incorporated into WCAG.

It’s time for publishers to come to terms with what’s required to meet accessibility standards. If the EU is part of your market, it should be a business imperative to investigate how to fix workflows, and implement robust metadata practices.

Information from the EAA Legislation that Pertains to the Publishing Industry

Details from Appendix I in Directive 2019/882

Information and Instructions

Information, instructions for use must be:

  1. be made available via more than one sensory channel;
  2. be presented in an understandable way;
  3. be presented to users in ways they can perceive;
  4. be presented in fonts of adequate size and suitable shape, taking into account foreseeable conditions of use and using sufficient contrast, as well as adjustable spacing between letters, lines and paragraphs;
  5. with regard to content, be made available in text formats that can be used for generating alternative assistive formats to be presented in different ways and via more than one sensory channel;
  6. be accompanied by an alternative presentation of any non-textual content;
  7.  include a description of the user interface of the product (handling, control and feedback, input and output) which is provided in accordance with point 2; the description shall indicate for each of the points in point 2 whether the product provides those features;
  8. include a description of the functionality of the product which is provided by functions aiming to address the needs of persons with disabilities in accordance with point 2; the description shall indicate for each of the points in point 2 whether the product provides those features;
  9. include a description of the software and hardware interfacing of the product with assistive devices; the description shall include a list of those assistive devices which have been tested together with the product.

User Interface (UI) and functionality design.

Products and their UI must contain features that enable disabled people to perceive, understand and control them, by doing the following things:

  1. Communications must be over more than one sensory channel
  2. Speech alternatives must be provided
  3. When product uses visuals, must provide flexible magnification, brightness, contrast
  4. When product uses color, must convey information in an alternate way
  5. Audible information must be conveyed in an alternative way
  6. Visual elements must offer flexible ways of improving vision clarity
  7. Audio –  must provide user control of volume and speed and improve clarity
  8. Manual controls shall provide sequential controls (not simultaneous)
  9. Avoid operations requiring extensive strength
  10. Avoid triggering photosensitive seizures
  11. Protect user’s privacy when using accessibility features
  12. Alternatives to biometric id and controls
  13. Consistency of functionality and enough and flexible time for interaction
  14. Interaction with assistive tech
  15. the product shall comply with the following sector-specific requirements:


  • e-readers shall provide for text-to-speech technology

Support Services

Where available, support services (help desks, call centers, technical support, relay services and training services) must provide information on the accessibility of the product and its compatibility with assistive technologies, in accessible modes of communication.

Section IV, article f  Ebooks

  1. ensuring that, when an e-book contains audio in addition to text, it then provides synchronised text and audio
  2. ensuring that e-book digital files do not prevent assistive technology from operating properly
  3. ensuring access to the content, the navigation of the file content and layout including dynamic layout, the provision of the structure, flexibility and choice in the presentation of the content
  4. allowing alternative renditions of the content and its interoperability with a variety of assistive technologies, in such a way that it is perceivable, understandable, operable and robust
  5. making them discoverable by providing information through metadata about their accessibility features;
  6. ensuring that digital rights management measures do not block accessibility features

(Note: all of these, except as relates to DRM are part of the EPUB specification)

 E-Commerce Services

  1. providing the information concerning accessibility of the products and services being sold when this information is provided by the responsible economic operator;
  2. ensuring the accessibility of the functionality for identification, security and payment when delivered as part of a service instead of a product by making it perceivable, operable, understandable and robust;
  3. providing identification methods, electronic signatures, and payment services which are perceivable, operable, understandable and robust.

Section VII – Functional Performance Criteria

  1. Usage without vision. Where the product or service provides visual modes of operation, it shall provide at least one mode of operation that does not require vision.
  2. Usage with limited vision. Where the product or service provides visual modes of operation, it shall provide at least one mode of operation that enables users to operate the product with limited vision.
  3. Usage without perception of colour. Where the product or service provides visual modes of operation, it shall provide at least one mode of operation that does not require user perception of colour.
  4. Usage without hearing. Where the product or service provides auditory modes of operation, it shall provide at least one mode of operation that does not require hearing.
  5. Usage with limited hearing. Where the product or service provides auditory modes of operation, it shall provide at least one mode of operation with enhanced audio features that enables users with limited hearing to operate the product.
  6. Usage without vocal capability. Where the product or service requires vocal input from users, it shall provide at least one mode of operation that does not require vocal input. Vocal input includes any orally-generated sounds like speech, whistles or clicks.
  7. Usage with limited manipulation or strength. Where the product or service requires manual actions, it shall provide at least one mode of operation that enables users to make use of the product through alternative actions not requiring fine motor control and manipulation, hand strength or operation of more than one control at the same time.
  8. Usage with limited reach. The operational elements of products shall be within reach of all users. Where the product or service provides a manual mode of operation, it shall provide at least one mode of operation that is operable with limited reach and limited strength.
  9. Minimising the risk of triggering photosensitive seizures. Where the product provides visual modes of operation, it shall avoid modes of operation that trigger photosensitive seizures.
  10. Usage with limited cognition. The product or service shall provide at least one mode of operation incorporating features that make it simpler and easier to use.
  11. Privacy. Where the product or service incorporates features that are provided for accessibility, it shall provide at least one mode of operation that maintains privacy when using those features that are provided for accessibility.