European Accessibility Act readiness

Whether it applies to you is a question about sales, not headquarters

The Act is scoped by where a product or service is offered, not where the company is registered. A publisher in India, the United States or Australia selling e-books into EU retail platforms is inside its scope exactly as a publisher in Berlin is.

It also binds the whole supply chain rather than the publisher alone. Distributors, online retailers, e-reading software, DRM solutions, metadata aggregators and libraries lending digital books all carry obligations — which is why retailers have begun requiring accessibility information before they will list a title.

Print books are not covered. This is digital-only legislation. There are narrow exemptions — microenterprises providing services, and cases where compliance would impose a disproportionate burden — but the burden exemption has to be assessed and documented, not assumed.

The technical route

The Act states functional outcomes rather than a specific technology. In practice conformance is demonstrated through EN 301 549, the harmonised European standard for ICT accessibility, which incorporates the WCAG Level AA success criteria.

For digital publications specifically, the working standards are EPUB 3 together with EPUB Accessibility 1.1, which defines how WCAG applies to a publication and what conformance and evaluation metadata a file must carry. For your website, storefront and checkout, it is EN 301 549 and WCAG directly.

Automated checking has a role here but does not settle the question. Tools such as Ace by DAISY validate what a machine can validate; a conformance claim still requires human evaluation, and the specification expects the evaluator and their credentials to be recorded.

Metadata is now part of the product

This is the requirement publishers most often miss. It is not enough for a title to be accessible — its accessibility has to be described, and that description has to travel down the supply chain so a reader can find it in a shop.

That means two things in parallel: schema.org accessibility properties inside the EPUB package document, covering access modes, accessibility features, hazards and a human-readable summary; and the corresponding accessibility codes in the ONIX record that goes to distributors and retailers. Publishers still sending ONIX 2.1 generally cannot express this at all, which makes the ONIX 3 transition a compliance question rather than a technical housekeeping one.

Get this wrong and a perfectly accessible title is invisible to the readers who need it, and unevidenced to the retailer who has to list it.

The backlist question, answered honestly

There is a transitional provision allowing services already being provided before June 2025 to continue under prior terms for a further period, and there has been genuine disagreement about how far it shelters backlist e-books. The prudent reading — and the one most publishing bodies have taken — is not to rely on it.

The practical approach is to stop the problem growing first: produce every new title as born-accessible, then work the backlist in priority order by sales, adoption and risk. Where full remediation of an older catalogue is not achievable quickly, a documented, dated, credible remediation plan is worth considerably more in a compliance conversation than silence.

What we do about it

We assess where your titles and platforms actually stand against EN 301 549 and WCAG, remediate the files, set up production so new titles come out accessible rather than being fixed afterwards, author the schema.org and ONIX metadata, and give you conformance documentation you can hand to a retailer or a regulator.

Because we already produce NIMAS filesets and PDF/UA files from the same source material, publishers who come to us for US instructional-materials obligations can generally cover their EU obligations from the same work rather than commissioning it twice.

The process, step by step

1. We assess A gap assessment of representative titles and your storefront against EN 301 549 and WCAG.
2. We fix the pipeline New titles are set up to be born accessible, so the backlog stops growing.
3. We remediate the backlist Worked in priority order, against a plan with dates you can show.
4. We evidence it Accessibility metadata in the EPUB and in ONIX, plus a conformance report.