The European Accessibility Act (Directive (EU) 2019/882) has applied to e-books sold in the European Union since 28 June 2025. Because the United Kingdom is no longer an EU member state, many UK publishers assume the Act does not affect them. For any publisher whose e-books reach consumers in the EU, through retailers, aggregators or its own store, that assumption is risky.
Why the Act matters to UK publishers
The Act sets accessibility requirements for products and services placed on the EU market, and e-books are named explicitly. The obligation follows the market, not the publisher’s home country. In practice, distributors and retailers serving EU customers are now asking publishers to supply accessible files and accurate accessibility metadata, and to state how each title conforms.
What the Act requires for e-books
The Act describes outcomes rather than file formats, but the industry has converged on a clear set of expectations for reflowable e-books:
- Logical structure and reading order, so that screen readers and text-to-speech present content in the intended sequence.
- Navigation: a complete table of contents, correct heading hierarchy and page-list mapping to the print edition where one exists.
- Text alternatives for images, charts and diagrams, written in context rather than generated as captions.
- Accessible tables and mathematics, with header cells marked up correctly and equations encoded in MathML rather than as images.
- Adaptable presentation, so readers can change font size, spacing and contrast without losing content.
- Accessibility metadata in the EPUB package and in ONIX feeds, describing the features, hazards and conformance of each title.
In production terms, publishers and distributors are working to the EPUB Accessibility 1.1 specification, which builds on WCAG 2.x Level AA, and validating files with EPUBCheck and the DAISY Ace accessibility checker.
Who is exempt
Microenterprises providing services are exempt. The EU defines a microenterprise as a business with fewer than 10 employees and an annual turnover or balance sheet total of no more than €2 million. Most established UK publishers exceed these thresholds. Retailers and platforms may still require accessible files from exempt publishers as a commercial condition.
What about the backlist?
The Directive allows member states to provide transitional arrangements until 28 June 2030 in certain cases, and interpretation for titles published before June 2025 varies between markets and distributors. Many publishers are not waiting: they are auditing backlist titles now, prioritising best-sellers and course-adopted titles, and remediating in batches so that the workload is spread rather than compressed into 2030.
A practical compliance checklist
- Audit a representative sample of frontlist and backlist EPUB files with Ace and a manual screen-reader review.
- Fix the source: apply consistent styles in InDesign or Word so that structure survives export, rather than patching each EPUB by hand.
- Write image descriptions with subject knowledge, and route them through editorial review.
- Convert mathematics to MathML and rebuild complex tables with proper header markup.
- Add accessibility metadata to the EPUB package and to ONIX records, using the agreed industry vocabulary.
- Validate every file with EPUBCheck and Ace before delivery, and keep the reports as evidence of conformance.
- Build accessibility into new titles from the first file, so that compliance becomes part of standard production rather than a separate project.
The UK position
Domestically, UK publishers remain subject to the Equality Act 2010, which requires reasonable adjustments for disabled people. Producing accessible e-books by default satisfies both the EU market requirement and good practice at home, and widens the readership for every title.
How Studio of Solutions supports compliance
Studio of Solutions audits, remediates and validates EPUB and PDF files for UK and European publishers, including MathML for STEM titles, contextual alt text and complete accessibility metadata. Each delivery includes validation reports suitable for distributors.
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This article provides general information and is not legal advice. Publishers should confirm their obligations with their distributors and legal advisers.