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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:

Publishing

  • 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.

Resources

FBF Event Report: The European Accessibility Act, A Chance for Publishers

Frankfurt Books Fair flagsWith the 2025 deadline for the implementation of the European Accessibility Act (EAA) approaching fast, experts from across publishing gathered at the virtual Frankfurt Book Fair under the subtitle All you need to know from international accessibility experts to present how the publishing sector can get ready and fully seize the opportunity the Act presents for all readers.

This report was kindly shared with us by the International Publishers Association and was prepared by Cristina Mussinelli and Elisa Molinari from the LIA Foundation.

The 2020  Frankfurt Book Fair, the most important event for the international publishing industry, went 100% digital for the first time ever. Nevertheless, the organizers were able to offer a rich professional program of events, seminars and conferences.

As such, Frankfurt Book Fair, IPA (International Publishers Association) and FEP (Federation of European Publishers) decided, in collaboration with Fondazione LIA (Libri Italiani Accessibili) to move the event on accessibility online. That event was convened by Aldus Up, the recently approved project funded under Creative Europe that is building on the work of Aldus, the European Fairs network.

This event: European Accessibility Act (EAA): A Chance for Publishers, was conceived as the first of a series of initiatives focused on accessibility, that the project will organize in the different EU book fairs in the forthcoming years under the coordination of Fondazione LIA. You can read more about the European Accessibility Act at the end of this report.

Overview

The seminar, chaired by Anne Bergman-Tahon, FEP Director, opened with remarks from Hugo Setzer, IPA President, and Peter Kraus vom Cleff, FEP President.

The seminar began with an introduction to the new legislation by Inmaculada Placencia-Porrero, Senior Expert Disability and Inclusion DG Employment Social Affairs and Equality European Commission. She presented the new Directive providing a general overview followed by the implications and the requirements for the publishing industry. Monica Halil Lövblad, Head of the World Intellectual Property Organisation’s Accessible Books Consortium further explained how this directive is inter-related with the Marrakech Treaty.

The Journey

The second part of the seminar aimed to take delegates on an accessibility journey, to better explain what problems visually impaired people face if a publication, a website or an app is not accessible and the benefits if they are accessible. Fondazione LIA provided a short video showing the experience of a visually impaired person in searching, accessing and reading a publication in these two different situations: not accessible and fully accessible.

The accessibility journey, starts with the production of ebooks following the Born Accessible principle, continues with the creation and distribution of that content to stores and online platforms accompanied by metadata describing the accessibility features.  Thanks to the possibility of buying or borrowing ebooks on accessible websites,  it is possible to complete the journey by making reading accessible to all.

Born Accessible

Cristina Mussinelli, Secretary General of Fondazione LIA, explained what makes a publication accessible and how to create Born Accessible content i.e. including accessibility from the very first steps within a workflow. She also provided information on the available international standard guidelines and the tools to check the compliance of ebooks with the requirements described. She highlighted the point that creating accessible digital publications means creating higher quality publications for any reader.

An Accessible Environment

Once the ebook is produced as accessible, it is important that it is also distributed in a fully accessible environment. Paolo Casarini, CTO and IT Director at Società editrice il Mulino, explained why and how they decided to acquire the knowledge to make PandoraCampus, their most important web platform providing students access to their publication, in an accessible format, with the support of Fondazione LIA. All the work they have done is based on international web standards, such as WCAG 2.1 (Web Content Accessibility Guidelines) and WAI-ARIA (Web Accessibility Initiative, Accessible Rich Internet Applications). They also made metadata available to end-users providing detailed information on the accessibility features of the publications and have published a statement describing all the work they have done to embrace accessibility.

Accessible Metadata

Luc Audrain, accessibility expert and former head of the accessibility project at Hachette Livre, France, stressed the importance of accessibility metadata options within ONIX and Schema.org. If used correctly, these can provide end-users with detailed information on the accessibility features of digital publications, such as presence of reading order, structural navigation, linked table of contents, alternative image descriptions, etc. This will become very important as one of the goals of the EAA Directive is to make accessible publications available in the marketplace. It will be fundamental for any end-user to know if an ebook responds to each need before acquiring it.

An Accessible Reading Experience

The last step of the journey is the reading experience. The European Accessibility Act requires both the reading devices and ereading apps to be accessible. Wendy Reid, Accessibility and Publishing Standards Lead at Rakuten Kobo, described the work being done in this field. She explained also that, as for the publications themselves, all the features that are required for accessibility, such as text or font adjustment or line spacing, make the reading experience better for everyone, irrespective of ability. The reference standards are the WCAG.

The Relevance of the Directive

The session closed with Anne Bergman interviewing Thomas Kahlisch, Representative of the European Blind Union and Director of the German Centre for Accessible Reading (dzb lesen) on the relevance of the Directive. He highlighted as a fundamental element the strong collaboration among the different stakeholders: publishers, the different actors of the publishing value chain, organizations representing print impaired persons and specialist organizations.

The concept of born accessible publications and of mainstreaming their distribution in the traditional channels has only emerged in recent years so many parts of the supply chain are not yet aware of the role they have to play in the accessible digital ecosystem, where if only one element in the chain fails, accessibility is lost and the end-user is penalized.  Accessibility should become a crucial element of the whole publishing supply chain’s strategy. Understanding users’ needs and acquiring the specific knowledge, through training and collaborating with those who have already embraced accessibility will be fundamental if the industry is to be ready by 2025.

The European Accessibility Act

The common goal presented at the seminar was to set the roadmap, create awareness and provide adequate knowledge to the publishing industry, in preparation of the entrance in force of the so called European Accessibility Act, the EU Directive 2019/882 of the European Parliament and of the Council of 17 April 2019 on the accessibility requirements for products and services.

The Directive will apply to many products and services, such as consumer general purpose computer hardware systems (personal computers, notebooks, smartphone and tablets) and operating systems for those hardware systems, self-service terminals (payment or ticketing terminals), consumer banking services, electronic communication services, payment services, services to access audiovisual media services. It also includes all ebooks, dedicated reading software, ereading devices and ecommerce placed in the EU market from June 28, 2025 by European and international business operators. Any publisher selling ebooks in Europe and all the actors of the epublishing supply chain will then need to respect the accessibility requirements set by this new legislation.

Just as ebooks and software ereading solutions are considered parts of a service,  the concept of service provider includes publishers and all the other economic operators involved in content distribution:

  • distributors and online retailers, ecommerce websites and mobile apps, online platforms;
  • software ereading solutions;
  • DRM solutions;
  • metadata managing systems.

The Directive in fact requires that all these organizations make content available to users through accessible services so that any user can carry out the entire process independently.

The goal here is to offer everyone the same opportunities to read and be informed, without distinction.

To break down current barriers it is necessary that a person with a visual disability can independently carry out all the steps necessary to select, buy and read. The seminar offered a chance to better understand the role that every member of the ebook value chain has to play in order to be compliant and to build a fully accessible epublishing ecosystem.

Organizers of the seminar have posted a video of the session which can be viewed at:

https://www.buchmesse.de/en/timetable/session/fep-ipa-fbm-european-accessibility-act-eaa-chance-publishing

Other Resources

European Accessibility Act: A Chance for Publishing

October 16th, 2020

Last year, the European Accessibility Act was passed. This event, organized by the IPA and the conference team at FBF will highlight the opportunities of the European Accessibility Act for publishers and feature statements from the Presidents of the Federation of European Publishers (FEP) and IPA. DAISY friends and IPP members will be taking part.

Earlier this year, DAISY ran a webinar on the EAA and the full recording is available for you to prep for this event!

Date

October 16, 2020

Venue

Online

Learn More

Event details can be found at the Frankfurt Book Fair website

The European Accessibility Act—Consideration for the Publishing Industry and Benefits to Consumers Globally (W)

Opening slide for the EU Accessibility Act webinarIn our series of free weekly webinars June 10th saw a session focused on the new European Accessibility Act and how we might approach this as an industry.

This page contains:

Full Video of the Webinar

Speakers

  • Richard Orme, The DAISY Consortium—host and chair
  • Inmaculda Placencia Porrero—European Commission
  • Anne Bergman—Federation of European Publishers
  • Cristina Mussinelli—Fondazione LIA
  • Luc Audrain—Inclusive Publishing Consultant

Session Overview

Introducing the European Accessibility Act

Inmaculda opened this webinar by giving us an overview of the EAA and how this applies to the publishing industry with regards to  services (ebook content and software) and products (such as ereaders), which fall within the scope of this new legislation. Both have accessibility obligations to meet within strict timelines and these were explained as well as transition periods

How the Publishing Industry Will Need to React and the Resulting Benefit to Consumers

Cristina Mussinelli gave us an overview of how the EAA is going to affect our industry and how we need to respond to the timelines for implentation, from various points of view—publishers, legal and consumers. We need to create an accessible publishing ecosystem to ensure that all areas of our digital workflow, from content creation through to paying for ebooks online and the accessibility of our reading app, are fully accessible. Every element of this workflow needs to play their part in complying with the requirements of the EAA.

By adopting international standards publishers can work towards creating born accessible digital content ie. content that is accessible from inception and available within mainstream publishing outlets. Accessibility metadata should be included as well as an accessibility statement describing accessibility features.

Helping Publishers Understand their Obligations

Anne Bergman showed how the FEP plans to raise awareness and why this is so important. The 29 publishers associations across Europe are ideally suited to promote accessibility obligations at bookfairs and in cooperation with booksellers and technology vendors. The Aldus project that unites bookfairs is organizing accessibility camps and various accessibility events to get publishers involved and play an active role in moving forward.

Some Concrete Organizational and Technical Advice

Luc Audrain, an inclusive publishing consultant in France, but formerly of Hachette Livre, talked about the move towards accessibility from a practical point of view and outlined organization and technical steps that publishers need to concentrate on in order to comply with the EAA.

Organizational Steps:

  • Raise Awareness
  • Build a Team or a Charter
  • Adopt a Progressive Approach
  • Decouple Specifications from the Purchase Order

Technical Steps:

  • Go Digital and Move to the EPUB 3 ebook format
  • Support the Main Actors of the Ecosystem and benefit from them
  • Use Open and Free Tools from the Community

Related Resources

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