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.

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:

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.

Mappings

Annex I

Accessibility requirements for products and services

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:

(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

(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

This requirement is satisfied by EPUB Accessibility, section Discoverability.

(i)

Making the information available via more than one sensory channel

Out of scope: requirement for Reading Systems and Distributors.

(ii)

Presenting the information in an understandable way

Out of scope: requirement for Reading Systems and Distributors.

(iii)

Presenting the information to users in ways they can perceive

Out of scope: requirement for Reading Systems and Distributors.

(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

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.

This requirement is satisfied by WCAG 2.

(v)

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

This requirement is satisfied by WCAG requirement 1.4.4 Resize text (level AA) and by WCAG requirement Contrast 1.4.3 1.4.3 Contrast (Minimum) (level AA).

(vi)

Supplementing any non-textual content with an alternative presentation of that content and

This requirement is satisfied by WCAG requirement 1.1.1 Non-text Content (level A).

(vii)

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.

(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.

(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.

Section IV

Additional accessibility requirements related to specific services

(f)

Ebooks

(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.

(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.

This requirement is satisfied by:

(iii)

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

This requirement is satisfied by:

(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

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.

This requirement is satisfied by WCAG 2.

(v)

Making them discoverable by providing information through metadata about their accessibility features

This requirement is satisfied by EPUB Accessibility, section Discoverability.

(vi)

Ensuring that digital rights management measures do not block accessibility features

This requirement is satisfied by EPUB Accessibility, section Distribution (non normative).