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Accessibility by default: what the EAA means for ePub3

A practical look at the European Accessibility Act and what publishers must ship by default for ebooks from 28 June 2025.

Editorial team reviewing publishing output at Crius Group

Blog · Crius Group · 2026-05-20

The European Accessibility Act (EAA), EU Directive 2019/882, sets legally binding accessibility requirements for digital products sold in the EU. For publishers, the most immediate consequence is that any ebook placed on the EU market from 28 June 2025 onwards must meet defined accessibility standards. This is not a recommendation or a best-practice guideline; it is a market access requirement. Ebooks that do not comply can be removed from sale.

In practice, EAA compliance for ePub3 means meeting a defined set of technical criteria. The file must have a logical reading order that assistive technologies can follow. Images must carry descriptive alt text. Headings must be marked up correctly so screen readers can navigate by chapter and section. Tables must have proper header associations. The ePub package must include accessibility metadata: fields that tell reading systems and distributors what accessibility features the file contains. These are not difficult to achieve in a well-structured workflow, but they are easy to miss in a layout-first production process.

Publishers with a large back catalogue face the most immediate challenge. New titles can be built to the standard from the outset, but bringing existing ePub3 files into compliance requires a systematic audit. The scale of that work depends on how the original files were produced. Files built from a structured XML source can often be regenerated with updated output templates. Files produced by exporting from layout software typically require more manual remediation because the structure was never explicitly encoded.

Distributors and retailers are beginning to enforce compliance through their metadata acceptance criteria. Aggregators that supply libraries and education markets are particularly active here, because their procurement clients (schools, universities, public libraries) are themselves subject to public sector accessibility obligations. A publisher whose ebook metadata does not signal compliance may find their titles excluded from certain channels entirely.

The practical first step for most publishers is an audit of their current ePub3 output against the EAA criteria. This means checking not just the file content but the production process that generated it, because a file that passes today may not pass next month if the process that created it does not reliably produce accessible output. Building accessibility into the workflow, rather than checking for it at the end, is what makes compliance sustainable at volume.

Crius Group produces accessible ePub3 by default in every workflow. Accessibility checks are part of the production pipeline, not an add-on. If you are assessing your current ePub3 output or planning a back-catalogue remediation programme, we can help you understand the scope and approach before you commit to a plan.

Related

Frequently asked questions

  • Does the European Accessibility Act apply to all ebooks?

    The EAA applies to ebooks placed on the EU market from 28 June 2025. This covers commercial ebooks sold through retailers and aggregators operating in the EU. There are limited exemptions for micro-enterprises and some non-commercial publications, but most trade, educational, and academic publishers are in scope. The safest approach is to treat EAA compliance as a baseline requirement for any ePub3 file intended for EU distribution.

  • What does an accessible ePub3 file actually need to contain?

    An accessible ePub3 must have: a logical reading order that assistive technologies can follow; correct heading markup for navigation; descriptive alt text on images and figures; proper table structure with header associations; and accessibility metadata in the package file declaring what accessibility features are present. It should also pass validation against the EPUB Accessibility standard (EPUB-A11Y-11).

  • Can existing ePub3 back-catalogue files be made EAA-compliant?

    Yes, but the effort varies. Files produced from structured XML sources can often be regenerated with updated, compliant output templates, a relatively low-cost route to compliance. Files exported from layout software typically need manual remediation because the underlying structure was not explicitly encoded. The first step is an audit of your current output to understand which files need remediation and how much work each will require.

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