The European Accessibility Act (Directive (EU) 2019/882) became applicable on 28 June 2025, and e-books and e-reading software are explicitly named in its scope. For publishers and e-book sellers, EAA e-books accessibility is no longer a differentiator for the print-disabled market; it is a market-access condition. A title that cannot meet the baseline can, in principle, be kept off the EU market.
The legal baseline runs through the harmonised standard EN 301 549, which points to WCAG 2.2 Level A and AA. But e-books add layers the web does not have: the file format (EPUB), the reading system that renders it, and the discovery metadata that tells a buyer whether a book is accessible before they purchase it. This guide covers all three, with the technical detail you need to brief your production and retail teams.
Who is in scope, and what the deadline actually means
The EAA covers e-commerce, banking, electronic communications, transport, audiovisual media access services, self-service terminals, and crucially for this audience, e-books and dedicated software and devices for reading them. That sweeps in publishers (as the entity that designs the product), aggregators and distributors, retail platforms, and the makers of reading apps and e-ink devices. If you produce, distribute, or sell e-books into the EU, you have an obligation somewhere in the chain.
The directive applied from 28 June 2025. Each member state implements it through national law, so the enforcement body and penalty regime depend on where you sell. Germany uses the Barrierefreiheitsstaerkungsgesetz (BFSG), in force from the same date; France enforces through the RGAA, aligned with EN 301 549 and WCAG; Italy applies the Legge Stanca with AgID guidelines. The technical bar is harmonised even though the paperwork and regulators are not. For a wider view of how these regimes fit together, see our European Accessibility Act overview.
The accessible EPUB: what conformance looks like in the file
EPUB 3 is the practical target because it carries the structure and metadata the EAA needs. Conformance is not a single switch; it is a set of properties baked into the package. The essentials your production workflow must guarantee on every title:
- Real, selectable text, not pages flattened into images. Scanned-image EPUBs fail immediately because there is nothing for assistive technology to read.
- A logical reading order and semantic structure: properly nested headings, lists marked up as lists, and roles via EPUB structural semantics so a screen reader can navigate by chapter, section, and landmark.
- Alternative text for meaningful images and figures, and a clear convention for decorative images.
- Reflow that survives resizing and text-spacing changes (WCAG 1.4.4 Resize Text, 1.4.10 Reflow, 1.4.12 Text Spacing), so a reader can enlarge type, change the font, or widen line spacing without losing content or function.
- Math expressed as MathML rather than image snapshots, and tables built as real data tables with header associations, not as visual grids.
- A correct language declaration on the package and inline language changes marked up, so text-to-speech pronounces words in the right voice.
Contrast still matters wherever your EPUB carries its own styling: 4.5:1 for normal text and 3:1 for large text and UI components remain the AA thresholds. Note that WCAG 2.2 removed the old 4.1.1 Parsing criterion and added requirements such as 2.4.11 Focus Not Obscured (Minimum) and 2.5.8 Target Size (Minimum), which bite mainly on the reading-system and store-interface side rather than inside the book file. For a fuller breakdown, see our WCAG checklist.
Reading systems and the store: accessibility beyond the book
A perfectly tagged EPUB is useless if the app that opens it traps keyboard focus or the checkout flow cannot be completed with a screen reader. The EAA treats the whole product, so your reading apps, e-ink devices, and the storefront that sells the title are all in scope under the same WCAG 2.2 A and AA baseline as your website.
Reading systems must honour the accessibility features in the file rather than overriding them: respect the embedded reading order, expose navigation by headings and page list, allow font and spacing changes, and pass media overlay synchronisation through to assistive technology. The surrounding storefront and account flows are held to the same standards as any EN 301 549 interface. That means keyboard-operable controls, visible focus, accessible forms, and status messages that are announced. If your purchase or download journey includes a login, the WCAG 2.2 criterion 3.3.8 Accessible Authentication (Minimum) discourages cognitive-function tests such as solving a puzzle with no accessible alternative.
These are the failures automated and manual testing catch on a storefront. You can run a free accessibility scan of your e-book store and account pages to find missing labels, contrast failures, and broken focus order before an auditor or customer does.
Metadata: the part publishers most often miss
This is where e-books diverge sharply from the web. Under the EAA, a reader must be able to tell whether a book is accessible before buying it. That promise is kept by accessibility metadata travelling with the title through the supply chain, surfaced in the store as a human-readable accessibility summary. A conformant EPUB with no metadata still fails the discoverability obligation.
In practice you populate two things that mirror each other. Inside the EPUB package, schema.org accessibility properties: accessibilityFeature (for example alternativeText, structuralNavigation, MathML, displayTransformability), accessibilityHazard (such as none, or flashing for animations), accessMode, accessModeSufficient, and a human-readable accessibilitySummary. In the trade feed, the ONIX 3.0 equivalents, principally List 196 codes in the Product Form Feature block, which carry the same claims to retailers and library systems.
- Declare what the book offers (text-to-speech allowed, structural navigation, alt text present, MathML) honestly; overstating features is both a compliance and a trust problem.
- Include a plain-language accessibility summary the store can display, for example: 'This EPUB has a full table of contents, page-list navigation, alt text on all informative images, and reflowable text.'
- Keep the in-file schema.org metadata and the ONIX List 196 codes consistent, because retailers ingest the ONIX and readers may inspect the file.
- Where you claim conformance, reference the level you actually meet (for example EPUB Accessibility 1.1 mapped to WCAG 2.2 AA) rather than a vague 'accessible' label.
A practical compliance path for your catalogue
You will not remediate a large backlist by hand. The realistic sequence is to fix the pipeline first, then triage the catalogue. Set your conversion and authoring tools to produce conformant EPUB 3 with metadata by default, so every new title is born accessible. Then prioritise the backlist by sales and by remediation cost: text-heavy fiction and trade non-fiction reflow cleanly and convert fast; fixed-layout, illustrated, and STEM titles need the most work and the clearest documentation.
- Validate every file with EPUBCheck for structural integrity, then run the Ace by DAISY checker for accessibility-specific issues.
- Spot-check with a real screen reader and a reading system that renders the accessibility summary, so you confirm the experience, not just the markup.
- Publish an accessibility statement for your store and platform describing conformance status, known limitations, and a contact route for accessibility problems.
- Document any disproportionate-burden or fixed-layout exception per title, with the reasoning, rather than relying on a blanket claim.
Treat the storefront and the file as one product. A buyer who cannot find the accessibility summary, cannot complete checkout with a keyboard, or downloads a conformant EPUB into an app that strips its structure has still been failed under the EAA. Brief your retail, production, and engineering teams together, because the obligation only counts as met when all three hold.