There is an ongoing discussion in the market about the timeline and implications of the European accessibility act (EAA) and how these will impact publishers’ plans not only for frontlist EPUB requirements but also for ensuring their backlists can remain in print, supported by an accessible digital alternative that allows all potential readers to engage with the content of a book. The June 28, 2025, deadline for the act has long been established, but there is debate about how that timing affects frontlist versus backlist titles. Some of the following is adapted from a blog post I wrote for the Book Industry Study Group, and I encourage readers to visit bisg.org to explore additional resources on the subject from many voices. The complex nature of accessibility and compliance for EPUBs may end up being transformative for our industry, and not only owing to the impact on selling print and EPUB formats in the EU. This topic merits all of our research and consideration.
So, what is the EAA? The act itself is an overarching piece of EU legislation that will be implemented in EU nations under individual national laws. While the EU has issued broad guidance (including prioritizing compliance by e-books), we have yet to see how individual countries will codify the act’s requirements. To further complicate matters, there’s a general lack of consensus in the publications industry about whether EPUBs—to wit, accessible EPUBs—are a product or a service, which could affect how rapidly frontlist and backlist content must comply with the act; will it be by the 2025 launch date for the act, or by a potential 2030 deadline for other services? Some industry figures suggest that EPUBs—including those in the backlist—may be allowed to drift into the 2030 window without being converted into a fully accessible file, others indicate that the 2025 deadline applies only to frontlist titles, and still others have voiced the opinion that all content must be compliant by June 28, 2025.
I am not an attorney, and as an executive of a vendor that converts and makes EPUB files compliant with GCA, WCAG, and DAISY guidelines, it would be easy to suggest that I have a vested interest in encouraging publishers to rapidly convert all of their list. My colleagues and I know our piece of the workflow very well, but accessibility is a nuanced topic that should be considered both as part of your production workflow and as part of your overall strategic plan. The analysis shared here is intended to promote discussion—preferably between you and similar publishers, as well as with your legal counsel—to arrive at the path best suited to your list and your business needs and reflective of your counsel’s guidance regarding your responsibilities to everyone who wishes to read or engage with the content in your books.
I encourage you to take a number of measures that will not cost you a dime on conversion services and can open up meaningful, internal dialogue about your content in advance of the EAA coming into effect.
- Speak with your attorney. To some degree, this conversation will be philosophical, as even without EU nations enacting the act or drafting policies, you will need to monitor these developments and review them with your counsel. In the interim, consider opening up some dialogue with your attorney or a legal professional about the potential impact on your business and ask them for guidance about how to proceed in the absence of final legislation or the presence of any court cases filed after the act and supporting national laws that go into effect.
- Ask your production managers to run some of your existing EPUB files—both recent frontlist books, as well as some deep backlist—through the ACE Checker from DAISY. ACE scores your EPUB files on a number of factors, including the presence and length of alt text, tagging structure, and more. This will give you a baseline on how compliant your current production practices are, as well as how much work your backlist titles may need.
- Discuss how alt text is or can be created as part of your editorial process. While vendors can write alt text entries as part of EPUB conversion or remediation, there’s a good argument to be made that—acquisitions allowing—it makes sense to ask authors to provide alt text entries for their images when supplying art. For some publishers, adding more tasks to an author’s plate is a bridge too far, so that task is falling to copy editors and editorial staff. Regardless, like any change, map it out in your workflow. Who has the skills, what are the hard and soft costs, and how best can you routinize this element so that it’s not a question mark for each title at the final phases of production?
- A lot of these steps have an impact on metadata. If you have alt text in a title, if you’re classifying an EPUB as “accessible,” you’ll want to add these things to your metadata for transparency and frankly for discovery, too. While you’re cracking things open to see what metadata you can and should add to support people using adaptive technology, give some thought to how this metadata can be used in your marketing stream to emphasize that a book has an accessible edition available. This report from eBOUND Canada, written by accessibility experts Laura Brady, Amanda Lee, and eBOUND Canada staff, provides a thorough review of best practices for handling accessibility metadata.
- Don’t go it alone. Many publishers have been very openly discussing these challenges on LinkedIn and via other channels, so you do not have to figure this all out on your own. Reach out to your network to see what they’re doing, engage with peer presses and members of the BISG Workflow Committee, explore becoming a DAISY member, participate in the Benetech GCA-certified program, or contact consultants like Bill Kasdorf, Laura Brady, and other trusted resources in the industry, such as Fondazione LIA.
While Westchester has released some further guidance on how we’re advising our clients to navigate the EAA, we realize that we are but one of many voices in the industry providing ideas and suggestions. The above steps are a good opening framework if you haven’t started the process yet. And if you are much farther along in the process, please do share your viewpoints and advice with your colleagues. It would be appreciated by the many publishers navigating the EAA and its impact on their production workflows.
