Earlier this summer, the U.K. and Ireland book industry’s supply chain organization, Book Industry Communication (BIC), held the first in a planned series of webinars dedicated to examining how the publishing industry should be preparing for the European Accessibility Act (EAA). Slated to go into effect June 28, 2025, the act mandates that a range of products and services—including such online experiences as e-commerce websites and mobile apps—are made accessible to people with disabilities. In the case of publishing, webinar speakers stressed, the act applies to the entire digital publishing ecosystem—not just e-books but also such products as e-readers and e-tailer websites.
Mary Elliott, management partner of Fox Williams LLP, Solicitors, and head of their publishing and digital media practice, observed that the objective of EAA is to make it easier for companies to do business with different members of the European Union by resolving discrepancies in accessibility requirements between different European countries. She said that, while the EAA will bring benefits to the disabled community, businesses will also benefit by improving trade among the EU members. Companies that are not prepared for the EAA risk losing out on business opportunities, she said.
But there are challenges. For one thing, Elliott acknowledged that, given the number of players involved with implementing the act, even at this date it is hard to be certain about how the act will be implemented. While the core principals of the act are in place, she added, nations could very well have different specific standards and enforcement mechanisms. Still, she explained, companies that haven’t yet done so should familiarize themselves with the EAA and learn what requirements they may need to meet. By doing what you can to be in compliance with the EAA, companies lower their risk of facing penalties, Elliott said.
She also noted that not every company needs to comply with EAA. Companies with less than 10 employees and 2 million euros in sales are exempt. And companies that can prove meeting EAA requirements for their products and services would impose a “disproportionate burden” may also be excused in respect of those products and services, Elliott said. She stressed that the EAA is about digital accessibility and doesn’t apply to print books.
While June 28 is the deadline for new titles to meet the EAA requirements, there is a great deal of debate over whether it applies to backlist titles, since there is a provision that states that services, which includes e-books, existing prior to June 2025 can continue to act in the same manner until June 2030. While that question is being settled, publishers should not think they have until 2030 to get their backlists in order, Elliott warned.
Cristina Mussinelli is secretary general of Fondazione LIA, a nonprofit created by the Italian Publishers Association in collaboration with the Italian Blind and Visual Impaired Union to help publishers and the publishing supply chain comply with the EAA requirements. She said that while publishers are evaluating the backlist issue, they should immediately start producing all new titles as “born accessible” by next June.
She agreed with Elliot that companies should familiarize themselves with requirements in the act, pointing to the EAA section III of Annex I, which provides general accessibility requirements, and Annex II, which provides specific examples of solutions to meet the requirements outlined in Annex I. Mussinelli added that that to meet necessary EAA requirements, companies should focus on improving ePubs, and in particular ePub accessibility 1.1s, which are developed and managed as part of the publishing activities of the World Wide Web Consortium.
Mussinelli explained that the EAA requires the creation of an accessible digital ecosystem involving all the actors in the publishing value chain: distribution platforms; aggregators, online bookstores, and libraries; purchase and loan services; reading devices and solutions; digital publications; and metadata. All parts of the ecosystem must be in EAA compliance, Mussinelli stressed, because if one segment is not in compliance, “all the work done by the publishers won’t make any difference.”
Elliott added that, while it is going to take time for all aspects of the EAA to be worked out, companies need to begin their “journey” now. There is no need to panic, she said, but companies shouldn’t sit back “and wait for answers that may never come.”
The next BIC webinar on accessibility is set for early September and monthly events, with the exception of November, are scheduled through March.