Regulatory context
E-books are explicitly covered by the EAA under Article 2, with dedicated requirements in Annex I covering both e-book content and the software used to read it (e-readers, reading apps). The EAA references the EPUB Accessibility 1.1 specification (based on WCAG 2.1) as the relevant standard for e-book content, and EN 301 549 for reading system software. Publishers must ensure e-book files are accessible, distributors must preserve accessibility features, and reading platforms must support assistive technology. The EAA also explicitly states that DRM (Digital Rights Management) must not block accessibility features - if DRM prevents text-to-speech, screen reading, or other assistive technology, it violates the Act.
Common issues Lumi finds in e-books & publishing websites
E-book content structure and navigation
E-books frequently lack proper semantic structure - missing heading hierarchies, absent table of contents navigation, unlabelled chapters, and missing page list navigation. EPUB accessibility requires logical reading order, structural navigation, and proper use of semantic HTML within content documents.
Image and figure descriptions in publications
Illustrations, charts, diagrams, infographics, and photographs in e-books often lack alt text or extended descriptions. Complex figures like data visualisations or scientific diagrams require detailed descriptions that go beyond simple alt text.
DRM blocking assistive technology
Digital Rights Management systems can prevent text-to-speech, screen reader access, copy-paste for accessibility tools, and font resizing. The EAA explicitly prohibits DRM from blocking accessibility features. Publishers and platforms must ensure their DRM implementation does not override assistive technology.
Reading app and platform accessibility
E-reader apps and web-based reading platforms frequently have inaccessible navigation controls, library browsing interfaces, and reading settings. Bookmark, annotation, and search features within reading apps need full keyboard and screen reader support.
Accessibility metadata and discoverability
E-books should include ONIX and schema.org accessibility metadata so that users can discover accessibility features (text-to-speech support, image descriptions, structural navigation) before purchasing. Missing metadata means users cannot make informed buying decisions.
E-books & Publishing-specific challenges
Publishing faces unique challenges because the EAA covers the entire supply chain - from content creation (publishers) through distribution (platforms, retailers) to consumption (reading apps, e-readers). Publishers need to produce accessible EPUB files with proper structure, navigation, and image descriptions. Distributors must not strip accessibility features during format conversion or DRM application. Reading platforms must support assistive technology and preserve the accessibility features present in the source file. Backlist titles numbering in the thousands need retrofitting. Complex content types - textbooks with formulas, children's books with fixed layouts, graphic novels - each present distinct accessibility challenges.
Compliance timeline
The EAA is enforceable from 28 June 2025 for new e-books and reading services. Existing e-books placed on the market before June 2025 are covered by transitional provisions until 28 June 2030. The EPUB Accessibility 1.1 standard (W3C Recommendation) is the de facto content standard referenced by the EU. Publishers should also be aware of the European Accessibility Resource Centre for Publishing (DAISY Consortium) guidance.
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Frequently asked questions
Does the EAA apply to e-books?
Yes. E-books and e-book reading software are explicitly listed in Article 2 of the EAA. Both the content (the e-book file) and the platform (reading apps, e-reader devices) must meet accessibility requirements. Publishers, distributors, and platform providers all have obligations.
What accessibility standard applies to e-books?
The EPUB Accessibility 1.1 specification is the primary content standard, which is built on WCAG 2.1 principles. For reading platforms and apps, EN 301 549 applies. E-book content should include proper structure, navigation, image descriptions, and accessibility metadata.
Can DRM block screen readers under the EAA?
No. The EAA explicitly states that DRM measures must not prevent accessibility features from functioning. If your DRM blocks text-to-speech, screen reader access, or other assistive technology, it violates the Act. Publishers and platforms must ensure DRM is compatible with accessibility.
Do existing e-books need to be made accessible?
E-books placed on the market after 28 June 2025 must comply. For existing backlist titles, transitional provisions allow until 28 June 2030. However, any e-book re-published or updated after June 2025 should meet the new requirements.
Related resources
Last reviewed: April 2026. Content is reviewed quarterly for accuracy.