The European Accessibility Act – what you need to know
Nothing focuses the mind more than new legislation, and that’s particularly the case for the incoming European Accessibility Act (EAA), which comes into force on 28 June 2025. Organisations worldwide are working hard to grasp its implications.
The aim of the EAA is to ensure that products and services across certain sectors meet minimum accessibility requirements to better support people with disabilities, while harmonising standards to make it easier to do business within the European Union (EU). The EAA applies to any private organisation, other than microenterprises (a small business with fewer than 10 employees, that requires little start-up capital), that wishes to sell into the EU, regardless of its location. For publishers, the most important in-scope service is ebooks and related software, closely followed by ecommerce.
Making your content accessible
While the top-level requirement of the EAA is clear (‘make things accessible’), it become murky as you dig into the detail. I’ve seen a lot of back-and-forth between lawyers, accessibility specialists and content teams about these details – such as what is an ebook (obvious in many cases, less so for complex hybrid content like digital educational material), what is ebook player software, what counts as an ecommerce user journey? Some of these discussions may only be resolved in the courts, but who wants to risk that when the potential penalties are hefty fines, reputational damage and restricted business operations?
So seek as much legal and technical clarity as possible on the EAA’s scope and definitions by consulting with lawyers and accessibility specialists. Consider all parts of your site that a customer must navigate and interact with to find and access your ebooks, noting requirements that are specific to them and those applicable to all services, such as explaining (accessibly, of course) how your service is accessible. Be clear on exemptions too, for example those for certain types of content, or if making your service accessible would result in a disproportionate burden or fundamental alteration. In particular, identify regional variations caused by differing implementations of the EAA into member state laws. So much for harmonisation!
The EAA requires products and services to be accessible, but only defines ‘accessible’ in the broadest terms. However, if your content conforms to existing ‘harmonised standards’ there is a subsequent presumption of compliance to the EAA. So if your ePubs conform to EPub Accessibility 1.1, your PDFs conform to PDF/UA, and your web content/mobile app meets WCAG A/AA criteria (preferably 2.2) and/or EN 301 549, then you’re in good shape. If you’re not sure whether you meet them, consult an accessibility specialist.
Embedding accessibility metadata is a key requirement. Publishers that directly supply ebooks on their site will also need to make this metadata discoverable by customers so they can easily identify content that meets their individual needs. New guidance from the W3C’s Publishing Task Force recommends best practices for this.
You’ll need to share evidence of conformance to national authorities on reasonable request, and to report non-conformance and subsequent remediation steps. For anything you can’t make fully accessible in time, ensure you’ve prioritised the most critical content and have a robust roadmap in place for the remainder – demonstrating a proactive intent to fix is a crucial part of risk reduction.
Beyond compliance
Accessibility is more than legal compliance; it’s about better serving people who are marginalised in their access to technology and digital content of all kinds.
If you haven’t already, use the EAA as a springboard to truly embed accessibility into your working practices. Rather than be simply reactive to external pressures and painfully and expensively fix your accrued accessibility debt, target a ‘born accessible’ strategy (see right). Bring accessibility considerations back into the planning phase with a shift-left philosophy like Microsoft’s (see right), and greater engagement with disabled users to transform your content from being minimally accessible to truly usable by all.
Senior management can support teams by creating an organisational culture that doesn’t deprioritise accessibility whenever there’s a hint that budgets or timescales may be adversely affected. Importantly, review your third-party suppliers to make sure they deliver genuinely accessible work. Too often I see substandard content provided by suppliers, even from those who claim they can ‘do accessibility’, so dig deeper with your due diligence. That can be difficult without in-house expertise – train and recruit wisely to empower teams to both create and commission accessible content. Groups such as The DAISY Consortium, Inclusive Publishing, the Publishing Accessibility Action Group and the UK Association for Accessible Formats provide expert support and recommendations.
According to the World Health Organization, around one in six people globally have some kind of disability, yet there are worrying signs that progressive gains made in recent years are under threat: once 28 June 2025 has come and gone, the need for accessibility efforts will be as important as ever.
Nick Bromley
Nick Bromley is an accessibility consultant specialising in educational publishing. Follow him on LinkedIn.