The 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.

Germany

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 

• Statistics and Data for the ebook market in Germany https://www.boersenverein.de/markt-daten/marktforschung/e-books/ 
• Bundesministerium für Arbeit und Soziales https://www.bmas.de/DE/Service/Gesetze-undGesetzesvorhaben/barrierefreiheitsstaerkungsgesetz.html 
• German Publishers and Booksellers Association website page on EAA https://www.boersenverein.de/beratung-service/barrierefreiheit/ 

Directive (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

• DAISY News – European Directive to Improve the Accessibility of Mainstream Ebooks
• The LIA Foundation – European Accessibility Act: A Chance for Publishers
• The LIA Foundation – Accessible Digital Books and Export: A Webinar for Canadian Publishers
• The LIA Foundation – Ebooks for All: Towards an Accessible Publishing Ecosystem
• The DAISY Consortium – DAISY Webinar: The EAA, Considerations for the Publishing Industry and benefits to Consumers Globally