4 of 5

31 October 2022

The European Accessibility Act – 4 of 5 Insights

E-books and the impact of the European Accessibility Act

Megan Lukins looks at the requirements of the EAA to e-books and at compliance challenges.


Megan Lukins



Megan Lukins


The European Accessibility Act (EAA) is an EU Directive which was due to be implemented into national law across all EU Member States by 28 June 2022. This legislative framework seeks to improve accessibility to a number of products, services and infrastructures for those affected by a disability and harmonise the rules around accessibility of goods and services in Member States. With over 80 million people across Europe impacted by a disability, it is hoped this legislation will remove barriers and promote full participation in e-commerce, new technologies and society in general, although a number of Member States are yet to implement it. One product clearly impacted by the EAA is the e-book.


E-books are included in the list of accessible products and services and, as such, publishers (and many other actors in the publishing supply chain) need to get to grips with the EAA. The Directive covers e-books, e-readers, reading software and e-commerce. An e-book is a digital form of a printed book designed to be read on devices like computers, tablets, or smartphones. Since the first e-book was published in the 1970s, they have become increasingly popular and now many people reach for their kindle or other device, where they can find a library of e-books before they think of buying a traditional paperback.

The EAA is broad in relation to e-books and takes into account the entire supply chain from book production to consumption. Some of the key requirements in relation to e-books specifically are:

  • when an e-book contains audio in addition to text, it must include synchronised text-to-speech technology
  • e-book digital files must not prevent assistive technology from operating seamlessly
  • the content must be displayed clearly and access to and navigation of the file content must be flexible
  • the e-books must be discoverable and information must be provided through metadata about their accessibility features
  • digital rights management measures.

The EAA doesn't stop at e-books and there are also a number of requirements which apply to e-readers (kindles etc.), defined as " dedicated equipment, including both hardware and software, used to access, navigate, read and use e-book files". For example, e-readers (or any products containing text and audio) must include a built-in synchronised text-to-speech technology. The interface within the product must be intuitive and work with any assistive technology. From June 2025 onwards, the reader must be able to find and read an e-book despite possible disabilities or use of assistive technology. The reader has to be able to locate the book from an internet bookstore or e-library, to buy or lend the book and, finally, to read it with an e-reader, computer program or mobile app.

Technical requirements

The EAA establishes requirements (set out in the Annexes) which need to be satisfied before the content can be certified as accessible.

There are two sets of accessibility standards that already exist in Europe. These are the WCAG 2.0 as supplemented, and the EPUB3 accessibility guidelines.  EPUB3 is the standard format for the creation and distribution of publications in the digital publishing trade sector. While the EAA does not set out a specific e-book file format, at the moment it is thought that EPUB3 is the most likely candidate to meet the requirements of the EAA. Producing accessible e-books which meet the requirements of EPUB3 is no mean feat and requires significant skills with desktop publishing tools and numerous applications which e-readers do not yet fully support.

What is a publisher to do?

While the bar for compliance is high, it has arguably been high for some time given the existence of the WCAG 2.0 and the EPUB3 standards. Many commentators argue the new requirements generally track the EPUB and WCAG guidelines which are already widely recognised in the industry and adopted by numerous players in the publishing supply chain.  Although some suggest the EAA is simply giving legislative effect to these pre-existing guidelines, others are concerned that many parts of the supply chain are unaware of their responsibility to uphold accessibility and the very fact organisations will need to adhere to these requirements as a matter of law is an enhanced burden. For those publishers which do not fully comply with these requirements and, more worryingly, lack the technical ability to comply at present, preparation for compliance with the EAA may be a significant challenge.

There is an element of 'watch this space' as we wait for all Member States to implement the Directive (you can track progress here) and look for guidance from the European Commission as to how players in the publishing supply chain should approach the technical requirements in the EAA. For the time being, getting up to speed with the requirements set out in WCAG 2.0 and EPUB3 would be a good starting point.

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