The EPUB Accessibility exemption property

The exemption property indicates that an EPUB publication that does not meet a jurisdiction's mimimum accessibility conformance requirements has an exemption under its 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 exemptions for [=EPUB publications=] that do not meet its minimum legal accessibility requirements, the exemption property can be used, when applicable, to indicate a publication falls under one of the provisions.

<meta property="dcterms:conformsTo">none</meta>
<meta property="a11y:exemption">eaa-microenterprise</meta>

An EPUB publication that meets accessibility standards might also claim exemptions. A publication could indicate conformance to [[wcag22]] Level A, for example, and also have to claim an exemption because Level AA conformance is required by law.

An accessibility conformance claim of "none" is not required when an EPUB publication fails to meet the requirements of [[[epub-a11y]]] [[epub-a11y]] but the accessibility status could be presented as unknown if it is not set and the exemption is not recognized.

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

<meta property="dcterms:conformsTo">none</meta>
<meta property="a11y:exemption">eaa-microenterprise</meta>
<meta property="a11y:exemption">eaa-fundamental-alteration</meta>

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. The prefix does not have to be declared 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

It is strongly advised to seek legal guidance when unsure whether an EPUB publication meets the legal requirements for these exemptions.

Value Definition

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.
`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.
`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.

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.

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.

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.

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.