Directive (EU) 2019/882 · Annex I, section IV(f)
E-books are named in the directive, and so is everything around them
Publishing is one of the few sectors where the European Accessibility Act names the object directly. E-books and dedicated software are covered as services, e-readers are covered as products, and the obligations reach the file, the reading app, the shop and the metadata that tells a reader whether the book is usable at all.
Four different duties in one supply chain
| Who | What they owe |
|---|---|
| Publisher | The file itself: structure, reading order, alternative text, language, navigation |
| Retail platform | The shop as a service, plus accessibility metadata surfaced on the product page |
| Reading app | A service and software: screen reader support, font and spacing controls, navigation |
| E-reader maker | A product: technical file under Annex IV, declaration of conformity, CE marking |
Most organisations in this chain assume the duty sits with somebody else in it. In a complaint, each link is asked about its own part.
What makes an e-book file accessible
EPUB 3 with a real structure, not a fixed-layout export of a print PDF. Headings that describe the hierarchy, a navigation document that works, a declared language so synthetic speech pronounces the text correctly, alternative text for images that carry meaning, tables marked up as tables, and page-list markers where the edition matches a printed one so a student can follow a citation.
The frequent failure is the opposite of complicated: a book produced as images of pages, where the text is not text at all. No reading app can fix that, and no statement can describe it as accessible.
The metadata is part of the obligation
A reader with a disability has to know before buying whether the book will work. That information travels as accessibility metadata through the distribution chain, in the ONIX record and inside the EPUB, and surfaces on the product page: what the file supports, what is missing, whether there are hazards such as flashing, and how to reach the publisher about it. Metadata that says nothing is treated as a book that supports nothing.
Born accessible costs less than retrofitted
The economics decide this sector. A title produced from a structured source, with headings, alternative text and language declared at the point of layout, costs almost nothing extra. The same title rebuilt two years later from a print PDF costs a day of somebody's work, multiplied by the catalogue. Fixing the template that produces the export is the single change that moves a publisher from constant remediation to clean output.
That is why our report names the export route rather than the individual book. Typesetters, conversion vendors and in-house InDesign templates each leave a recognisable fingerprint in the failures, and correcting one of them clears hundreds of titles at once.
Where reading apps fail the test
- Custom text rendering that a screen reader cannot read, so the app is silent on the page.
- Font, size and spacing controls that stop short of what a reader with low vision needs.
- Page turns available only as a swipe, with no keyboard or button alternative.
- Annotations and search that are unreachable from the keyboard.
- Digital rights management that blocks the text from reaching assistive technology.
That last point is explicit in the directive: measures to protect copyright must not prevent the accessibility features from working.
Backlist, frontlist and what is reasonable
The obligation applies to what you offer to consumers now, which for a publisher means the catalogue on sale, not only the new season. Retrofitting a large backlist is real work, and the honest route is a statement that says which part of the catalogue meets the requirements today, on what timetable the rest follows, and how a reader can ask for a specific title. Silence about the backlist is what turns into a complaint.
Education and library customers ask first
Universities, schools and public libraries have their own accessibility duties, and they push them up the chain in procurement. A publisher who can produce a conformance report and clean metadata wins those tenders without a conversation; one who cannot loses them without knowing why.
What the statement has to say for a publishing service
The scope, which titles or which platform it covers, the standard applied, how the reading experience works with assistive technology, the known limitations with a reason, the contact point for reporting a barrier, and the date. Where you also make an e-reader, the device has a technical file instead, and the two documents have to agree with each other.
Audiobooks, magazines and subscription bundles
An audiobook is not an e-book, but the app that plays it, the catalogue that sells it and the subscription that bundles both are services in scope. Magazines exported as fixed layouts carry the worst failures in the sector, because the design grid survives the export and the reading order does not. Where a subscription bundles books, magazines and audio in one product, the statement covers the product the consumer bought, not the three production lines behind it.
Schools and universities add one more expectation: a route to request an accessible version of a specific title, answered in days rather than in a term. Publishers who set that route up in advance turn a recurring complaint into a support ticket.
How we work with publishers and platforms
We test a sample of real files from your catalogue, the shop journey, and the reading app on a device with a screen reader running, then write the statement from that result and sign the record with a public code. The developer report tells your production team which export settings are producing the failures, which is usually where a backlist problem is fixed once rather than title by title. See the app side and the product file.
Questions we get before buying
Are e-books really covered by the directive?
Yes. E-books and dedicated software are listed among the covered services, and e-readers are covered as products.
Does a PDF count as an e-book?
If you sell it as a digital book, it is in scope. A PDF of scanned pages with no text layer fails almost every requirement.
Whose duty is it, the publisher or the shop?
Both, for their own part. The publisher answers for the file, the platform for the shop and the metadata it displays.
What metadata do we have to provide?
The accessibility information that travels in ONIX and in the EPUB, describing what the file supports, what it lacks and any hazards, so a reader can decide before buying.
Do we have to fix the entire backlist?
The obligation covers what you offer now. A statement that sets out the current scope, the timetable and a route to request a title is the workable answer.
Can DRM stay in place?
Yes, provided it does not prevent accessibility features from working. Protection that blocks assistive technology is not compatible with the requirements.
Are small publishers exempt?
A publisher that is a service microenterprise, under 10 staff and up to 2 million euro, is exempt for services. A covered product carries its obligations regardless of size.
What standard applies to the file?
EPUB accessibility practice mapped onto the requirements of Annex I, tested with the reading systems your customers actually use.
Do libraries and universities ask for this?
Constantly, through procurement. A conformance report and clean metadata answer the questionnaire directly.
How many files do you test?
A representative sample across your production routes, because the failures come from the export settings rather than from individual titles.
Test the file, the shop and the reading app together
One test across the chain, one statement, one signed record, and a report your production team can act on.