The EPUB Accessibility exemption property

The exemption property allows EPUB creators to indicate that an EPUB publication that does not meet accessibility conformance requirements has an exemption under the applicable jurisdiction's laws.

Introduction

Overview

Some jurisdictions provide exemptions for meeting accessibility requirements. For example, the European Accessibility Act [[directive-2019/882]] provides three exemptions to meeting its requirements: to microenterprises that employ fewer than ten people and have an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million, when accessible production would prove a disproportionate burden, or when making the content accessible would require a fundamental alteration of the product.

Although it is possible to explain these exemptions in the accessibility summary for an [=EPUB publication=], plain language statements are not easily processed by machines. A vendor may want to know that a publication is exempt before allowing it in their bookstore without an accessibility conformance claim, for example.

This document defines a new property named exemption in the accessibility vocabulary namespace [[epub-a11y]] to address this need for machine-readable metadata.

Terminology

This document uses terminology defined in EPUB 3.3 [[epub-33]].

Only the first instance of a term in a section links to its definition.

Accessibility conformance exemptions

When a jurisdiction provides specific legal exemptions for [=EPUB publications=], [=EPUB creators=] whose content fails to meet the requirements of the EPUB Accessibility standard [[epub-a11y]] (or any other standard), can use the exemption property to indicate when their publications fall under one of these provisions.

EPUB creators do not have to include an accessibility conformance claim of "none" when listing that a publication has an exemption from accessibility requirements, but it is best practice to also provide this information. Reading systems that do not recognize the exemption might otherwise list the accessibility status as unknown.

The property MAY be repeated to list exemptions for multiple jurisdictions and/or for multiple exemptions within a single jurisdiction.

The EPUB Accessibility standard does not define exemptions for inaccessible publications. This property only exists for jurisdictions where such exemptions are legislated.

Refer to for the list of currently recognized exemptions.

The exemption property

The EPUB Accessibility standard [[epub-a11y]] reserves the prefix "a11y:" for use with properties in the http://idpf.org/epub/vocab/package/a11y/# namespace. [=EPUB creators=] do not have to declare a prefix in the [=package document=].

Definition

Definition of the exemption property
Name: exemption
Namespace: http://idpf.org/epub/vocab/package/a11y/#
Description:

Identifies the accessibility exemption the [=EPUB publication=] falls under.

The value SHOULD be one of the values listed in .
Allowed value(s): xsd:string
Cardinality: Zero or more
Extends: Only applies to the [=EPUB publication=]. MUST NOT be used when the refines attribute [[epub-33]] is present.
Example: 
<meta property="dcterms:conformsTo">none</meta>
<meta property="a11y:exemption">eaa-microenterprise</meta>

Exemption values

Value Definition

eaa-disproportionate-burden

Article 14 paragraph 1 of the European Accessibility Act states that its accessibility requirements shall apply only to the extent that compliance: … (b) does not result in the imposition of a disproportionate burden on the economic operators concerned [[directive-2019/882]].

Use of the eaa-disproportionate-burden value indicates an EPUB publication is exempt because it would require such a disproportionate burden to make accessible.

EPUB creators are responsible for ensuring their publications meet the legal requirements for this exemption.

eaa-fundamental-alteration

Article 14 paragraph 1 of the European Accessibility Act states that its accessibility requirements shall apply only to the extent that compliance: (a) does not require a significant change in a product or service that results in the fundamental alteration of its basic nature [[directive-2019/882]].

Use of the eaa-fundamental-alteration value indicates an EPUB publication is exempt because it would require such a fundamental alteration to make accessible.

EPUB creators are responsible for ensuring their publications meet the legal requirements for this exemption.

eaa-microenterprise

The European Accessibility Act defines a microenterprise as: an enterprise which employs fewer than 10 persons and which has an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million [[directive-2019/882]].

It further states in Article 4 paragraph 5: Microenterprises providing services shall be exempt from complying with the accessibility requirements referred to in paragraph 3 of this Article and any obligations relating to the compliance with those requirements [[directive-2019/882]].

Use of the eaa-microenterprise value indicates that the publisher of an [=EPUB publication=] that does not meet accessibility standards qualifies under the definition of a microenterprise.

[=EPUB creators=] are responsible for ensuring they meet the legal requirements of a microenterprise when using this value.

To request new values, please open a new issue. When requesting a new value, please provide a unique name that identifies both the jurisdiction and the exemption. Requests must cite the legislation that defines the exemption.