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EPUB Accessibility & the European Accessibility Act: The Law Is Now in Force

April 2, 2026·9 min read

The European Accessibility Act (EAA) deadline is not a future concern. It is here. From 28 June 2025, any business selling eBooks or digital reading platforms within the European Union must meet EPUB accessibility requirements or face significant regulatory penalties.

For publishers with EU distribution — and that includes most English-language academic, trade, and educational publishers — this is not optional.

What Is the European Accessibility Act?

The European Accessibility Act (Directive 2019/882) is EU law that mandates accessibility standards for a wide range of digital products and services. Under the EAA, eBooks and eReading applications are explicitly listed as regulated products.

The EAA requires that digital books distributed in the EU must conform to:

  • EPUB Accessibility 1.1: (the DAISY/W3C standard for accessible digital publications)
  • WCAG 2.1 Level AA: (the Web Content Accessibility Guidelines, internationally recognised accessibility benchmark)

    • Non-compliance is enforced at the national level by each EU member state, with penalties that include fines, distribution bans, and mandatory product withdrawal.

    Who Does the EAA Apply To?

    The EAA applies to any business that:

  • Sells eBooks to consumers or institutions in EU member states
  • Operates an eReading platform or app available in the EU
  • Provides digital content through EU library or educational distribution channels

    • This includes publishers headquartered outside the EU. If your titles are sold on Amazon.de, distributed through EBSCO, or supplied to German university libraries, the EAA applies to you.

    What Does EPUB Accessibility 1.1 Require?

    EPUB Accessibility 1.1 is not simply about adding alt text. It is a comprehensive standard covering four core areas:

    ### 1. Discoverability (Accessibility Metadata)

    Every EPUB must include machine-readable accessibility metadata in its `content.opf` file, declaring:

  • `schema:accessMode` — the senses required to read the content (textual, visual, etc.)
  • `schema:accessibilityFeature` — specific features present (alt text, reading order, etc.)
  • `schema:accessibilityHazard` — any content that may trigger adverse reactions
  • `schema:accessibilitySummary` — a human-readable accessibility description
  • `a11y:certifiedBy` — the organisation that certified compliance

    • Without this metadata, distributors including Amazon, Apple Books, and Kobo cannot surface accessibility information to readers, and the file cannot be considered compliant.

    ### 2. Optimised Page Progression (Reading Order)

    The logical reading order of the EPUB must match the visual reading order. This sounds simple but frequently fails in:

  • Multi-column layouts converted from InDesign
  • Sidebars, pull quotes, and callout boxes
  • Tables with complex row/column structures
  • Footnotes that appear mid-text rather than at page end

    • ### 3. Semantic Markup (Structural Tagging)

    Every element must carry its correct semantic role:

  • Headings must use `<h1>`–`<h6>` in correct hierarchy (not styled text)
  • Lists must use `<ul>` or `<ol>` (not manually bulleted paragraphs)
  • Figures must use `<figure>` with `<figcaption>` and `alt` attributes
  • Tables must include `<thead>`, `<th scope>`, and caption elements
  • EPUB-specific roles (via `epub:type` and ARIA `role` attributes) must be applied to landmarks: cover, frontmatter, bodymatter, chapter, footnote, etc.

    • ### 4. Alternative Access (Alt Text and Non-Text Content)

    Every non-decorative image must have a meaningful `alt` attribute. For complex images (charts, graphs, diagrams), a longer description is required — either inline or as a linked `longdesc`.

    MathML is required for mathematical notation. Images of equations are not acceptable under EPUB Accessibility 1.1.

    What Happens If You Don't Comply?

    Enforcement is handled by national market surveillance authorities in each member state. Penalties vary by country but include:

  • Fines: proportional to the publisher's annual turnover
  • Mandatory product withdrawal: from sale in the member state
  • Public naming: on national non-compliance registers
  • Distribution platform delisting: — Amazon, Kobo, and major aggregators are expected to require compliance metadata as a condition of listing

    • Additionally, the EAA creates civil liability — individuals with disabilities may bring complaints directly against publishers through national enforcement channels.

    What About the ADA Title II Deadline?

    US publishers face a parallel deadline. The US Department of Justice's updated ADA Title II regulations require state and local government entities — including public universities, public libraries, and state-funded educational institutions — to comply with WCAG 2.1 AA for digital content by April 2026.

    For academic and educational publishers, this means content supplied to US public higher education institutions must meet the same accessibility standards as the EAA requires for EU distribution.

    The practical implication: building accessibility into your production workflow once satisfies both the EAA and ADA Title II requirements simultaneously.

    How to Audit Your Current EPUB Files

    Before remediating, you need to know where you stand. The following free tools will give you a baseline:

    ### DAISY Ace (Accessibility Checker for EPUBs)

    The official open-source validator for EPUB Accessibility 1.1. Ace produces an HTML report listing every violation by category, with page-level detail.

    Run it from the command line:

    ```bash

    ace --outdir ./ace-report your-book.epub

    ```

    Or use our HoloRemedi platform, which runs Ace validation automatically on upload and presents the results in a visual dashboard with one-click remediation for common issues.

    ### epubcheck

    The IDPF's official structural validator. An EPUB must pass epubcheck before accessibility validation is meaningful — structural errors will mask accessibility issues.

    ### PAC 2024 (PDF Accessibility Checker)

    For PDF/UA compliance on PDF versions of your titles, PAC 2024 is the industry-standard validator used by regulators and distributors.

    The Remediation Process: What Is Actually Involved?

    Remediating a non-compliant EPUB involves four stages:

    Stage 1 — Structural Repair

    Fix any epubcheck errors: malformed XML, broken manifest entries, incorrect OPF metadata.

    Stage 2 — Semantic Reconstruction

    Apply correct EPUB semantic markup — heading hierarchy, list structures, figure tagging, ARIA landmarks, and `epub:type` attributes throughout.

    Stage 3 — Alt Text Generation

    Write descriptive alt text for every non-decorative image. For a 300-page illustrated textbook, this is the most labour-intensive stage — though AI-assisted tools can now generate high-fidelity alt text at scale, reviewed by a human editor.

    Stage 4 — Metadata and Certification

    Add the full EPUB Accessibility 1.1 metadata package to the OPF. Run final Ace validation. Export the Ace HTML report as your compliance evidence.

    How Many Files Do You Need to Remediate?

    This is the question publishers ask first. The EAA does not grandfather legacy content — all eBooks actively sold within the EU must comply from 28 June 2025. For publishers with large backlists, this means hundreds or thousands of titles.

    Manual remediation at typical agency rates (£80–£150 per file for a standard title) is not economically viable at scale. AI-assisted remediation platforms — including our own HoloRemedi — reduce per-file time by 6× while maintaining the accuracy required for certification.

    Frequently Asked Questions

    Does the EAA apply to eBooks already on sale before June 2025?

    Yes. The EAA applies to all products and services actively sold in the EU from 28 June 2025, regardless of when they were first published or distributed.

    What is the difference between WCAG 2.1 and WCAG 2.2?

    WCAG 2.2 is the current version, published in October 2023. The EAA references WCAG 2.1 AA as the minimum standard. Meeting WCAG 2.2 AA satisfies the EAA requirement and is recommended as future-proofing.

    Are print-replica PDFs included in the EAA?

    Fixed-layout PDFs sold as eBooks are within scope if they are sold as standalone digital products. Publishers should consult with legal counsel in their primary EU market for jurisdiction-specific guidance.

    Can we certify our own files, or do we need a third party?

    Self-certification is permitted under EPUB Accessibility 1.1. You declare compliance via the `a11y:certifiedBy` metadata field and supply the Ace report as evidence. Third-party certification is not mandatory but provides additional legal protection.

    What if we sell through Amazon or Apple Books — do we still need to comply?

    Yes. The obligation applies to the publisher, not the distribution platform. Platforms may enforce their own compliance requirements in addition to the legal obligation.

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    Holograph PressWorks provides EPUB and PDF accessibility remediation through our HoloRemedi platform. We deliver certified, compliant files alongside official Ace and VeraPDF reports. [Request a consultation →](/contact-us)