Accessibility requirements for EPUBs under the EU Accessibility Act

Some frequently asked questions about the European legislation on the accessibility of digital products (EAA).

What is the EU Accessibility Act (EAA)?

The EU Accessibility Act (EAA) is a European directive that will come into effect on June 28, 2025. This law requires commercial providers of digital products and services, such as e-books, to make their offerings accessible to people with disabilities. The goal is an inclusive digital single market within the EU.

Does the EU Accessibility Act also apply to e-book publishers?

Yes, the law applies to commercial providers of e-books, including publishers, distributors, and independent authors. Both new publications and existing titles that remain for sale within the EU after June 28, 2025, must meet the accessibility requirements.

What technical requirements does the EAA impose on an e-book in EPUB format?

E-books must, among other things, meet the following requirements: they must be available in an accessible EPUB format (preferably EPUB 3), with correct semantic HTML structure (such as the use of <h1>, <nav>, <section>), well-functioning navigation (such as a table of contents and optional page numbers), alt-text for images, correct metadata with accessibility features (such as via schema.org or ONIX), and compatibility with screen readers and other assistive technology.

Is it still permissible to offer EPUB2 files under the EAA?

EPUB2 is not formally prohibited, but it is strongly discouraged. This format does not, or only limitedly, support many of the necessary accessibility features, such as semantic markup and flexible navigation. EPUB3 is the recommended standard for compliance with the law.

Do existing e-books need to be adapted for EAA compliance?

Yes, all e-books that remain commercially available within the EU after June 28, 2025, must comply with the EAA. Existing titles do not need to be adapted if they are completely withdrawn from sale within the EU before that date or only remain in archives.

Is an exception possible for small publishers or independent authors?

Yes, for micro-enterprises (fewer than 10 employees and an annual turnover below 2 million euros) an exception may apply on the grounds of disproportionate burden when providing their services. This exception must be substantiated and is not automatically applicable to the products themselves if sold via non-exempt channels.

How can publishers check if their EPUB files are accessible?

Publishers can use various tools to test their EPUB files for accessibility. Recommended tools include:

  • Ace by DAISY for an automatic accessibility analysis
  • EpubCheck for technical validation of EPUB files
  • Thorium Reader to manually test how an e-book is displayed with screen reader support

What are the consequences if a publisher does not comply with the EAA?

Non-compliance with the EAA can lead to sanctions such as fines or the withdrawal of digital publications from the market within the EU. Enforcement is carried out by designated national authorities in each EU member state. For UK-based publishers selling into the EU, enforcement would be by the authorities in the respective EU member states. Within the UK, separate accessibility regulations apply (such as the Equality Act 2010 and the Public Sector Bodies Accessibility Regulations 2018), with enforcement overseen by bodies like the Equality and Human Rights Commission (EHRC) and the Government Digital Service for public sector bodies.

What preparations can publishers already make for the EAA?

Publishers can prepare by migrating their publications to EPUB3, building internal knowledge about semantic HTML and accessibility, checking existing titles for conformity, and collaborating with e-book designers experienced with accessibility standards.

Where can publishers find official guidelines and technical specifications on e-book accessibility?

Official information and guidelines are available via, among others: