For publishers selling or distributing digital books in Europe, accessibility is no longer something to consider only after a book has been produced.

The European Accessibility Act (EAA), Directive (EU) 2019/882, covers certain products and services, including e-books and dedicated software for accessing them. The EAA began applying on 28 June 2025.

For publishers, that raises an important question:

What does EAA readiness actually involve?

The answer is broader than adding alt text to images. Publishers need to consider the accessibility of the digital book itself, its navigation, content structure, metadata, interoperability with assistive technologies, and the systems used to deliver or sell it.

This guide breaks the topic into a practical checklist.

What Is the European Accessibility Act?

The European Accessibility Act is an EU directive designed to improve the accessibility of certain products and services for people with disabilities.

The legislation covers products such as computers, smartphones and e-readers, as well as services including e-books, electronic communications, banking and e-commerce.

The EAA is implemented through national legislation in EU Member States. Therefore, publishers should consider both the EU-level requirements and the applicable national rules in the countries where their products or services are placed on the market.

For publishers, one of the most important points is simple:

E-books are explicitly included within the scope of the EAA.

Does the EAA Apply to E-Books?

Yes, e-books are among the services covered by the EAA. The EU’s official summary specifically identifies e-books as an in-scope service.

The EAA also defines an e-book and related dedicated software in terms of digital files that convey an electronic version of a book and can be accessed, navigated, read and used.

The legislation became applicable on 28 June 2025.

However, publishers should not interpret this as meaning that every existing digital file automatically has exactly the same legal obligations. The EAA contains transition provisions, exceptions and safeguards, and national implementation can affect how requirements are applied.

Why EAA Compliance Matters to Publishers

An inaccessible EPUB can create barriers for readers who depend on assistive technologies.

For example, a digital book may contain:

• Images without meaningful alternatives
• Poor heading structure
• Inaccessible tables
• Difficult navigation
• Incorrect reading order
• Missing accessibility metadata
• Multimedia without appropriate alternatives
• Content that does not work properly with assistive technologies

The EAA’s requirements for e-books include accessibility of the digital files and interoperability with assistive technologies. EU-level materials also identify requirements around access to content, navigation, structure, presentation, and accessibility metadata.

The important point is that EAA readiness should be treated as a publishing workflow issue, not simply a final-file inspection.

EAA Compliance Checklist for Publishers

Check 1: Make Images Accessible

Start with every meaningful image in the book.

Ask:

Does this image communicate information?

If yes, provide an appropriate text alternative.

For example, a scientific textbook might contain a diagram explaining how a process works. Simply labeling it “diagram” would not communicate the information to a reader who cannot access the visual.

For decorative images, the appropriate treatment can be different.

Publishers should therefore classify images according to their purpose and make sure the final EPUB communicates the relevant information in an accessible form.

Checklist:

• Review every image.
• Identify informative versus decorative images.
• Add meaningful alternative text where required.
• Check charts and diagrams separately.
• Avoid using filenames as descriptions.
• Verify the final EPUB rather than relying only on the source manuscript.

Check 2: Structure the EPUB Correctly

An accessible digital book needs more than visible text.

Its underlying structure should help users navigate and understand the content.

Review:

• Headings
• Paragraph structure
• Lists
• Sections
• Reading order
• Links
• Tables
• Navigation landmarks
• Document structure

The EAA’s e-book requirements address access to content and navigation as well as the structure and presentation of the content.

Think of the EPUB structure as the skeleton of the book. The visual design may look perfect, but if the underlying structure is confusing, assistive technology may not provide the same experience.

Check 3: Make Navigation Accessible

Readers should be able to move through a digital book without relying exclusively on visual cues.

Review the book’s:

• Table of contents
• Page navigation
• Internal links
• Chapter navigation
• Section headings
• Reading order
• Landmark structure

The objective is to make the content and its navigation usable through appropriate assistive technologies. This is specifically reflected in the EAA-related e-book requirements.

For publishers, this means accessibility should be checked at the book-navigation level, not just at the individual-page level.

Check 4: Review Tables, Charts and Complex Content

Complex content deserves additional attention.

A table that looks straightforward visually may become difficult to interpret if its structure is not properly encoded.

Similarly, a chart may communicate information visually that is unavailable elsewhere in the text.

Review:

• Data tables
• Charts
• Graphs
• Diagrams
• Maps
• Mathematical content
• Scientific notation
• Complex figures

Where the visual contains essential information, publishers should ensure that equivalent information is available in an accessible form.

Check 5: Make Multimedia Accessible

Some digital books include audio or video.

The accessibility approach depends on the type of media and how it is used.

The EAA-related e-book requirements specifically address cases where an e-book contains audio in addition to text, including synchronization between text and audio.

For multimedia books, publishers should therefore review:

• Audio alternatives
• Text alternatives
• Captions where applicable
• Synchronization between text and audio
• Controls
• Keyboard and assistive-technology access

The exact requirements should be assessed against the applicable EAA provisions and technical standards rather than using a generic multimedia checklist.

Check 6: Review Accessibility Metadata

Accessibility information should not be hidden from the workflow.

The EAA-related requirements for e-books include making accessibility features discoverable through metadata.

For publishers, this means accessibility metadata should be considered alongside normal book metadata rather than added as an afterthought.

Depending on the publishing ecosystem, relevant information can include the accessibility features available in the digital publication.

The practical objective is straightforward:

Help users and distribution systems identify the accessibility characteristics of the digital book.

Check 7: Check Assistive Technology Compatibility

An EPUB can look correct on screen and still have accessibility problems.

Why?

Because accessibility depends partly on how the underlying content interacts with assistive technologies.

The EAA-related requirements for e-books include ensuring that digital files do not prevent assistive technologies from operating properly and that the content can interoperate with a range of assistive technologies.

Publishers should therefore test more than visual appearance.

Where appropriate, testing can include:

• Screen readers
• Keyboard navigation
• Text resizing
• Reflow
• Navigation controls
• Focus behavior
• Reading order

Check 8: Review DRM and Accessibility

Digital rights management can create another accessibility consideration.

The EAA-related requirements identify the need to ensure that digital rights management measures do not block accessibility features.

This is particularly important when a publisher uses DRM or other technical controls around digital books.

The question is not simply:

“Does the DRM protect the book?”

It is also:

“Does the technical protection interfere with legitimate accessibility features?”

That should be tested as part of the publishing workflow.

Check 9: Test the Final EPUB

Automated checking is useful, but it should not be treated as the entire accessibility process.

A production workflow should include:

Source review → Accessibility remediation → EPUB generation → Automated checks → Manual review → Assistive-technology testing → Final validation

The exact testing process will depend on the type of book and the applicable requirements.

For example, a simple novel and a highly illustrated scientific textbook will present different accessibility challenges.

The important principle is to test the actual delivered EPUB, because accessibility issues can be introduced during conversion or production even when the source document was prepared correctly.

What About WCAG?

Publishers will often encounter WCAG, or the Web Content Accessibility Guidelines, when researching digital accessibility.

WCAG is an important accessibility standard, but publishers should be careful about treating a particular WCAG version as automatically equivalent to legal EAA compliance.

The European Commission explains that the relationship between legal requirements and harmonised technical standards matters. Its guidance on the Web Accessibility Directive also notes that later WCAG versions do not automatically become legally relevant simply because they have been published.

For EAA projects, publishers should therefore identify the applicable legal requirements and relevant harmonised standards, rather than simply stating “WCAG compliant” and assuming that settles the question.

EAA Exceptions and Important Considerations

The EAA is not a simple rule that applies identically to every company and every digital file.

There are exceptions and safeguards.

For example, EU guidance states that microenterprises providing services are exempt from the EAA accessibility requirements. The Council of the EU describes a microenterprise in this context as a business with fewer than 10 employees and annual turnover below €2 million.

The legislation also contains safeguards concerning disproportionate burden and fundamental alteration. These are not blanket exemptions that publishers can simply claim without assessment.

There are also provisions concerning certain legacy content and products already on the market, so publishers should review the specific circumstances of their catalogue rather than applying one rule to every title.

For legal interpretation, publishers should consult the EAA text, applicable national legislation, and qualified legal or compliance professionals.

A Simple EAA Checklist for Publishers

Use this checklist during EPUB production:

Area	Publisher Checklist
Images	Are meaningful images provided with appropriate alternatives?
Decorative content	Are decorative images treated appropriately?
Structure	Are headings, sections, lists, and other structures correctly represented?
Reading order	Does the content follow a logical reading sequence?
Navigation	Can readers navigate chapters and sections effectively?
Tables	Are tables structured so their relationships can be understood?
Charts & diagrams	Is important visual information available in an accessible form?
Mathematics	Is mathematical content accessible in the final publication?
Multimedia	Have applicable audio/video accessibility requirements been addressed?
Metadata	Does the publication provide appropriate accessibility information?
Assistive technology	Has the EPUB been tested with relevant assistive technologies?
DRM	Does DRM interfere with accessibility features?
Final EPUB	Has the actual delivered file been checked rather than only the source?
Documentation	Are accessibility decisions and testing results documented?

Frequently Asked Questions

1. What is EAA compliance for publishers?

For publishers, EAA compliance involves meeting the accessibility requirements applicable to in-scope e-books and related services. These requirements cover areas including access to content, navigation, structure, assistive-technology interoperability, and accessibility information.

2. When did the European Accessibility Act apply to e-books?

The EAA became applicable on 28 June 2025. E-books are among the services covered by the legislation.

3. Does every publisher have to comply with the EAA?

Not necessarily. The scope depends on the product or service and the circumstances of the economic operator. For example, EU guidance provides an exemption for microenterprises providing services, while the legislation also contains specific exceptions and safeguards. Publishers should assess their individual situation under the applicable national rules.

4. Does an accessible EPUB automatically mean EAA compliant?

Not necessarily. An EPUB can contain accessibility features while other legal, technical, or service-level requirements still need to be considered. Publishers should assess the complete applicable requirements rather than treating one EPUB accessibility test as a universal legal certification.

5. Is WCAG 2.2 the EAA standard for publishers?

Publishers should not make that assumption. WCAG is an important accessibility standard, but the legal relevance of particular technical requirements depends on the applicable legislation and harmonised standards. The European Commission explains that later WCAG versions do not automatically become legally relevant to EU accessibility legislation simply because they are published.

Conclusion

EAA readiness for publishers starts with the EPUB but does not end there.

Images, structure, navigation, complex content, multimedia, metadata, assistive-technology compatibility, DRM, and final-file testing all deserve attention.

The most practical approach is to build accessibility into the editorial, conversion, EPUB production, QA, and distribution workflow rather than treating it as a final correction exercise.

For publishers managing large catalogues, a repeatable checklist can help production teams identify accessibility issues consistently across new titles and legacy content.

And when a project involves a question of legal applicability, exemptions, disproportionate burden, or national enforcement, the safest approach is to verify the specific circumstances against the EAA and the relevant national legislation.