EAA requirements for e-books and e-readers

In brief

E-books and dedicated software are in the scope of the European Accessibility Act (Article 2(2)(e)). E-readers are covered as products under Article 2(1).

Besides the general service requirements in Annex I, Section III, Section IV sets six requirements for e-books, from synchronised audio to accessibility metadata.

Requirements for e-books (Section IV)

• Where the e-book contains audio together with text, provide synchronised text and audio.
• Make sure the digital file does not block assistive technologies from working.
• Provide access to the content, to navigation of the file and its layout, including dynamic layout, structure and flexibility and choice of presentation.
• Allow alternative renditions of the content and interoperability with a variety of assistive technologies in a way that is perceivable, operable, understandable and robust.
• Make the e-book discoverable by providing accessibility information through metadata.
• Make sure digital rights management measures do not block accessibility features.

Check the exact wording of Section IV before you cite it.

E-readers

E-readers are products under Article 2(1). Section I of Annex I includes text-to-speech among the requirements for them. See the page on EAA scope for the product list.

Technical route for EPUB

The W3C Recommendation EPUB Accessibility 1.1 sets conformance and discoverability requirements for EPUB publications. It builds on WCAG and adds requirements for accessibility metadata. It is a useful technical reference for the metadata and structure points, but it is not named in the Directive.

Stores and apps that sell or read e-books

A store or reading app that provides e-books is also a service in its own right. Its website, app, search, cart and checkout fall under the general service requirements. See the page on e-commerce requirements.

What to do

• Check file structure. Headings, reading order, alternative text, and navigation must work with assistive technology.
• Add accessibility metadata. Describe the accessibility features of each title so people can find them.
• Test with assistive technology. Use a screen reader and text-to-speech on the reading apps you support.
• Review DRM. Check that it does not block text-to-speech, text resizing or other accessibility features.
• Check synchronised audio. For titles with audio and text together.

Common mistakes

• Image-only pages. Scanned or fixed-layout files without a text layer block assistive technology.
• DRM that blocks text-to-speech. The Directive says DRM must not block accessibility features.
• No metadata. Without it, readers cannot find accessible titles.
• Ignoring the store. The shop and the reading app are services too.
• Treating EPUB conformance as the whole job. The Directive also covers the service around the book.

Sources

• EPUB Accessibility 1.1 (W3C Recommendation), opens in a new tab
• Directive (EU) 2019/882, European Accessibility Act (EUR-Lex), opens in a new tab

This page is for informational purposes only and is not legal advice. For binding requirements, refer to the official text of the European Accessibility Act (Directive (EU) 2019/882) and to the national law of the Member State where you operate.