The European
Accessibility Act (EAA) is an EU directive that establishes binding accessibility targets that
must be met by many different types of products and services to strengthen the rights of people with
disabilities to access goods and services, including ebooks, dedicated reading software, ereading
devices, and ecommerce.
The EAA has been approved on 27 June 2019, should be implemented by EU Member States within 28 June 2022
and will enter in force from 28 June 2025.
This note aims to demonstrate that the technical requirements of the European Accessibility Act related
to ebooks are met by the EPUB® standard.
The methodology used is mapping the requirements of the EU Accessibility Act related to ebooks to the EPUB Accessibility specification.
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1. How EPUB conforming to EPUB accessibility guidelines cover European Accessibility Act requirements
EPUB is the standard format for the creation and distribution of publications in the digital publishing
trade sector.
The specifications of the EPUB standard are based on the Open Web Platform: HTML, CSS, JavaScript and
SVG are the core technologies used for content creation. The use of the latter means that EPUB
publications can be written with a high degree of accessibility simply through the proper application of
established web accessibility techniques, namely the Web Content Accessibility Guidelines
(WCAG).
In order to outline how to make fully accessible EPUBs, the EPUB Accessibility guidelines have been drafted to address two key needs in the EPUB
ecosystem:
discoverability of accessibility features of publications;
evaluation and certification of accessible EPUB publications.
Providing accessibility metadata facilitates informed decisions about the usability of an EPUB
publication. Consumers can examine the characteristics of the content and decide whether an EPUB
publication is appropriate for each need.
While it has always been possible to create EPUB publications with a high degree of accessibility, this
document also establishes formal requirements for contents to be certified as accessible. These
requirements provide EPUB creators with a clear set of guidelines for evaluating their content with
respect to quality certification and enable it.
The EPUB Accessibility does not target a single version of EPUB (most commercially available publications
are in EPUB 3 or EPUB 2 format). It is designed to be applicable to all EPUB publications conforming to
any version or profile, including future versions of the standard.
2. Mappings
2.1 Annex I
Accessibility requirements for products and services
2.1.1 Section III
General accessibility requirements related to all services covered by this Directive in
accordance with Article 2(2)
The provision of services in order to maximise their foreseeable use by persons with
disabilities, shall be achieved by:
2.1.1.1 (a)
Ensuring the accessibility of the products used in the provision of the service, in
accordance with Section I of this Annex and, where applicable, Section II thereof
2.1.1.2 (b)
Providing information about the functioning of the service, and where products are used
in the provision of the service, its link to these products as well as information about
their accessibility characteristics and interoperability with assistive devices and
facilities
Making the information available via more than one sensory channel
Out of scope: requirement for Reading Systems and Distributors.
2.1.1.2.2 (ii)
Presenting the information in an understandable way
Out of scope: requirement for Reading Systems and Distributors.
2.1.1.2.3 (iii)
Presenting the information to users in ways they can perceive
Out of scope: requirement for Reading Systems and Distributors.
2.1.1.2.4 (iv)
Allowing alternative renditions of the content and its interoperability with a
variety of assistive technologies, in such a way that it is perceivable,
understandable, operable and robust
Note
In the context of the European Accessibility Act the term rendition does not
refer to the EPUB 3 multiple renditions specification, it means the ability
to access content in different ways.
Presenting in fonts of adequate size and suitable shape, taking into account
foreseeable conditions of use and using sufficient contrast, as well as adjustable
spacing between letters, lines and paragraphs
Providing electronic information needed in the provision of the service in a
consistent and adequate way by making it perceivable, operable, understandable and
robust
Out of scope: requirement for Reading Systems and Distributors.
2.1.1.3 (c)
Making websites, including the related online applications, and mobile device-based
services, including mobile applications, accessible in a consistent and adequate way by
making them perceivable, operable, understandable and robust
Out of scope: requirement for Reading Systems and Distributors.
2.1.1.4 (d)
Where available, support services (help desks, call centres, technical support, relay
services and training services) providing information on the accessibility of the
service and its compatibility with assistive technologies, in accessible modes of
communication
Out of scope: requirement for Reading Systems and Distributors.
2.1.2 Section IV
Additional accessibility requirements related to specific services
2.1.2.1 (f)
Ebooks
2.1.2.1.1 (i)
Ensuring that, when an ebook contains audio in addition to text, it then provides
synchronised text and audio
The audio synched to text feature is called Media
Overlay in the EPUB world and it provides an effective synchronization between
text and audio.
2.1.2.1.2 (ii)
Ensuring that ebook digital files do not prevent assistive technology from operating
properly
The EPUB Accessibility document uses the definition of assistive technology as defined in
WCAG2.
Ensuring access to the content, the navigation of the file content and layout
including dynamic layout, the provision of the structure, flexibility and choice in
the presentation of the content
Allowing alternative renditions of the content and its interoperability with a
variety of assistive technologies, in such a way that it is perceivable,
understandable, operable and robust
Note
In the context of the European Accessibility Act the term rendition does not
refer to the EPUB 3 multiple renditions specification, it means the ability
to access content in different ways.