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<section id="abstract">
<p>The <a href="https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019L0882">European
Accessibility Act (EAA)</a> is an EU directive that establishes binding accessibility requirements that
must be met by many different types of products and services. It strengthens the rights of people with
disabilities to access goods and services, including ebooks, dedicated reading software, ereading
devices, digital rights management softwares, and ecommerce.</p>

<p>The EAA was approved on 27 June 2019 and comes into force on 28 June 2025.</p>
<p>The <a href="https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019L0882">European Accessibility Act (EAA)</a> is an EU directive that establishes accessibility requirements for different types of products and services. It aims to strengthen the rights of people with disabilities by providing access to products and services, including e-books, dedicated e-reading devices and software, digital rights management software, and e-commerce.</p>

<p>This note aims to demonstrate that EPUB® standard meets all the technical requirements related
to ebooks, as defined by the European Accessibility Act.</p>
<p>The EAA was enacted on 27 June 2019 to be forced from 28 June 2025.</p>

<p>The methodology used is mapping the requirements of the EU Accessibility Act related to ebooks to the <a
href="https://www.w3.org/TR/epub-a11y-11/">EPUB Accessibility 1.1</a> specification.</p>
<p>This note aims to demonstrate that EPUB® standard meets all the technical requirements related to e-books, as defined by the EAA.</p>

<p>The methodology used is mapping the requirements of the EAA related to e-books to the <a href="https://www.w3.org/TR/epub-a11y-11/">EPUB Accessibility 1.1</a> specification.</p>
</section>
<section id="sotd"></section>
<section id="introduction">
<h2>How EPUB conforming to EPUB accessibility guidelines cover European Accessibility Act requirements</h2>
<h2>How EPUB addresses all EAA requirements</h2>

<p>EPUB is the standard format for the creation and distribution of publications in the digital publishing sector.</p>
<p>EPUB is the standard format for the creation and distribution of digital publications, including e-books.</p>

<p>The specifications of the EPUB standard are based on the <a
href="https://www.w3.org/wiki/Open_Web_Platform">Open Web Platform</a>: HTML, CSS, XML, MathML and
SVG are the core technologies used for content creation. This means that EPUB
publications can be created with a high degree of accessibility simply through the proper application of
established digital accessibility techniques.</p>
<p>The EPUB standard is based on the <a href="https://www.w3.org/wiki/Open_Web_Platform">Open Web Platform</a>: HTML, CSS, XML, MathML, and SVG are the core technologies used for content creation. This means that EPUB publications can be created with a high degree of accessibility simply through proper application of established techniques for digital accessibility.</p>

<p>The <a href="https://www.w3.org/TR/epub-a11y-11/">EPUB Accessibility</a> specification [epub-a11y-11] addresses the following key areas for making fully accessible EPUB publications:</p>
<p>The <a href="https://www.w3.org/TR/epub-a11y-11/">EPUB Accessibility</a> standard [epub-a11y-11] addresses the following key areas for making EPUB publications fully accessible:</p>

<ul>
<li>conformance to Web Content Accessibility Guidelines (WCAG);</li>
<li>discoverability of accessibility features of publications;</li>
<li>conformance to Web Content Accessibility Guidelines;</li>
<li>specific EPUB requirements for accessibility;</li>
<li>evaluation and conformance reporting of accessible EPUB publications.</li>
</ul>

<p>The EPUB Accessibility 1.1 defines requirements for accessibility metadata. In this way consumers can examine the accessibility characteristics of the content and make well-informed decisions on whether an EPUB publication is appropriate for each need before buying, borrowing, or downloading it.
This metadata, attached to the digital file and distributed along the supply chain, ensures that persons with disabilities can be informed about the publication accessibility features.
In order to make sure that information gets to the end user, it is critical that all players in the value chain do their part in managing metadata and displaying it to the end user (aggregators, ecommerce, reading solutions).</p>

<p>EPUB Accessibility 1.1 also defines the official accessibility criteria that EPUBs must adhere to claim conformance to the standard.
These criteria offer EPUB creators a precise set of instructions to assess their content in terms of quality assurance.</p>
<p>EPUB Accessibility 1.1 defines requirements for accessibility metadata. In this way consumers can examine the accessibility characteristics of the content and make well-informed decisions on whether an EPUB publication is suitable for each need before buying, borrowing, or downloading it. This metadata, attached to the digital file and distributed along the supply chain, ensures that persons with disabilities can be informed about the publication accessibility features. In order to make sure that information gets to the end user, it is critical that all players in the value chain do their part in managing metadata and displaying it to the end user (aggregators, e-commerce, reading solutions).</p>

<p>EPUB Accessibility 1.1 also defines the official accessibility criteria that EPUBs must adhere to, to claim conformance to the standard. These criteria offer EPUB creators a precise set of instructions to assess their content in terms of quality assurance.</p>

<p>EPUB Accessibility 1.1 does not target a single version of EPUB (most commercially available publications are in EPUB 3 or EPUB 2 format). It is designed to be applicable to all EPUB publications conforming to any version or profile, including future versions of the standard.</p>

<p>The EPUB Accessibility 1.1 does not target a single version of EPUB (most commercially available publications
are in EPUB 3 or EPUB 2 format). It is designed to be applicable to all EPUB publications conforming to
any version or profile, including future versions of the standard.</p>

<p>The EPUB allows the creation of both reflowable and Fixed Layout publications.</p>
<p>EPUB itself (the core format) allows the creation of both Reflowable and Fixed Layout publications.</p>

<p>In a reflowable EPUB the content adapts to the user's viewport, depending also on the user's chosen graphical characteristics, such as font size, line spacing, text color, etc.. In Fixed Layout EPUBs each element is positioned absolutely on the page (as it is usually an exact replica of the paper version) and the user does not have the ability to change the text formatting.</p>

<p>EPUB Fixed Layout are mainly used for publications where the meaning is layout-driven, such as comics, illustrated children’s books, and art books.</p>
<p>In a Reflowable publication, the content adapts to the user's viewport. This includes the user's chosen graphical characteristics, such as font size, line spacing, text color, etc. In a Fixed Layout publication, each element has a fixed position because the publication is usually an exact replica of the paper version. In these publications the user does not have the ability to change the graphical characteristics, such as font size, line spacing, text color, etc.</p>
<p>EPUB Fixed Layout are mainly used for publications in which the meaning is layout-driven such as comics, illustrated children’s books, and art books.</p>

<p>Although it is technically possible to produce Fixed Layout publications with a good level of accessibility, it should be kept in mind that some accessibility requirements cannot be met, precisely because of the limitation of the format, such as the ability to change the graphical formatting of the text according to the user's needs.</p>
<p>Although it is technically possible to produce Fixed Layout publications with a good level of accessibility, it should be kept in mind that some accessibility requirements cannot be met. This is because of the limitation of the format, including the ability to change the graphical formatting of the text according to the user's needs.</p>

<section id="relationship-to-wcag">
<h2>Relationship of EPUB Acessibility to WCAG</h2>

<p>EPUB Accessibility specification defines requirements necessary to make an EPUB publication fully accessible; these are on top of the requirements defined by the Web Content Accessibility Guidelines (WCAG) and relate to the specificificities of ebooks and digital publications.</p>
<p>EPUB Accessibility 1.1 defines the requirements necessary to make an EPUB publication fully accessible, including the requirements defined by the Web Content Accessibility Guidelines (WCAG). It further adds requirements solely related to the specific characteristics of e-books and other digital publications.</p>

<p>Web Content Accessibility Guidelines (WCAG) offer a broad framework of requirements for making digital content accessible to all, addressing a wide range of problems and providing solutions. WCAG guidelines cover several aspects, including multimedia content, interactive content, and basic web page structure.</p>
<p>Web Content Accessibility Guidelines (WCAG) defines requirements for making many different types of digital content accessible. It addresses a wide range of situations and technologies, including multimedia content, interactive content, and basic web page structure.</p>

<p>EPUB Accessibility specification not only defines how to apply WCAG specifically to EPUB publications, but adds additional requirements such as accessibility metadata, page navigation, audio-text synchronization, and Digital Rights Management guidance.</p>
<p>EPUB Accessibility 1.1 defines how to apply WCAG specifically to EPUB publications, and defines additional requirements such as accessibility metadata, page navigation, audio-text synchronization and Digital Rights Management guidance.</p>

<p>The additional requirements set by EPUB Accessibility specification are critical to fully comply with the requirements of the European Accessibility Act.</p>
<p>The additional requirements defined by EPUB Accessibility are critical to fully comply with the requirements of the European Accessibility Act.</p>
</section>
</section>
<section id="mappings">
<h2>Mappings</h2>

<p>This section of the document maps the requirements defined by EPUB Accessibility specification to the ones defines in European Accessibility Act in Annex I <cite>"Accessibility requirements for products and services"</cite>.</p>
<p>This section of the document maps the requirements defined of the European Accessibility to the EPUB Accessibility technical standard.</p>

<p>The mapping takes into account Section III <cite>"Accessibility requirements for products and services"</cite> related to all services identified by the European Accessibility Act - including ebooks - and Section IV <cite>"Additional accessibility requirements related to specific services"</cite>, sub-section (f) <cite>"Ebooks"</cite>, which defines specific requirements for ebooks.</p>
<p>The mapping includes the following sections from Annex I <cite>"Accessibility requirements for products and services"</cite> of the EAA:</p>

<ul>
<li>Section III<cite> "Accessibility requirements for products and services"</cite> related to all services covered by the EAA, including e-books</li>
<li>Section IV<cite> "Additional accessibility requirements related to specific services"</cite>, sub-section (f) <cite>"E-books"</cite>, which defines specific requirements for e-books</li>
</ul>

<section id="annex-I">
<h3>Annex I – Accessibility requirements for products and services</h3>
Expand All @@ -146,6 +138,8 @@ <h5>(a)</h5>
<blockquote>
<p>Ensuring the accessibility of the products used in the provision of the service, in
accordance with Section I of this Annex and, where applicable, Section II thereof</p>

<p>Out of scope: requirement for reading systems and other products used to provide the service.</p>
</blockquote>
</section>

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facilities</p>
</blockquote>

<p>This requirement is satisfied by EPUB Accessibility 1.1, <a
data-cite="epub-a11y-11#sec-discovery">section Discoverability</a>.</p>
<p>Satisfied by EPUB Accessibility 1.1, <a data-cite="epub-a11y-11#sec-discovery">section Discoverability</a>.</p>

<section id="annex-I-section-III-b-i">
<h6>(i)</h6>
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<p>Making the information available via more than one sensory channel</p>
</blockquote>

<p>Out of scope: requirement for reading systems, ecommerce websites and platforms.</p>
<p>Provision of information is covered by EPUB Accessibility, <a data-cite="epub-a11y-11#sec-discovery">section Discoverability</a>. Presentation of this information is out of scope of e-books, it is a requirement for reading systems, e-commerce websites, and platforms. </p>
</section>

<section id="annex-I-section-III-b-ii">
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<p>Presenting the information in an understandable way</p>
</blockquote>

<p>Out of scope: requirement for reading systems, ecommerce websites and platforms.</p>
<p>Provision of information is covered by EPUB Accessibility, <a data-cite="epub-a11y-11#sec-discovery">section Discoverability</a>. Presentation of this information is out of scope of e-books, it is a requirement for reading systems, e-commerce websites, and platforms. </p>
</section>

<section id="annex-I-section-III-b-iii">
Expand All @@ -189,7 +182,7 @@ <h6>(iii)</h6>
<p>Presenting the information to users in ways they can perceive</p>
</blockquote>

<p>Out of scope: requirement for reading systems, ecommerce websites and platforms.</p>
<p>Provision of information is covered by EPUB Accessibility, <a data-cite="epub-a11y-11#sec-discovery">section Discoverability</a>. Presentation of this information is out of scope of e-books, it is a requirement for reading systems, e-commerce websites, and platforms. </p>
</section>

<section id="annex-I-section-III-b-iv">
Expand All @@ -207,7 +200,7 @@ <h6>(iv)</h6>
to access content in different ways.</p>
</div>

<p>This requirement is satisfied by <a href="https://www.w3.org/TR/WCAG2/">WCAG 2</a>.</p>
<p>Provision of information is covered by EPUB Accessibility, <a data-cite="epub-a11y-11#sec-discovery">section Discoverability</a>. Presentation of this information is out of scope of e-books, it is a requirement for reading systems, e-commerce websites, and platforms. </p>
</section>

<section id="annex-I-section-III-b-v">
Expand All @@ -219,14 +212,7 @@ <h6>(v)</h6>
spacing between letters, lines and paragraphs</p>
</blockquote>

<p>This requirement is satisfied by WCAG Success Criterion <a
href="https://www.w3.org/TR/WCAG2/#resize-text">1.4.4 Resize text</a> (level AA), WCAG Success Criterion
<a href="https://www.w3.org/TR/WCAG2/#contrast-minimum">1.4.3 Contrast (Minimum)</a> (level AA)
and WCAG Success Criterion <a href="https://www.w3.org/TR/WCAG2/#text-spacing">1.4.12 Text Spacing</a> (level AA).</p>

<div class="note">
<p>In case of Fixed Layout EPUBs some features (like adjustable spacing between letters, lines and paragraphs) may not be available.</p>
</div>
<p>Provision of information is covered by EPUB Accessibility, <a data-cite="epub-a11y-11#sec-discovery">section Discoverability</a>. Presentation of this information is out of scope of e-books, it is a requirement for reading systems, e-commerce websites, and platforms. </p>
</section>

<section id="annex-I-section-III-b-vi">
Expand All @@ -237,11 +223,7 @@ <h6>(vi)</h6>
content</p>
</blockquote>

<p>This requirement is satisfied by WCAG Success Criterion <a
href="https://www.w3.org/TR/WCAG2/#non-text-content">1.1.1 Non-text Content</a>
(level A), WCAG Success Criterion <a href="https://www.w3.org/TR/WCAG2/#audio-only-and-video-only-prerecorded">1.2.1
Audio-only and Video-only (Prerecorded)</a> (level A) and WCAG Success Criterion
<a href="https://www.w3.org/TR/WCAG2/#captions-prerecorded">1.2.2 Captions (Prerecorded)</a> (level A).</p>
<p>Provision of information is covered by EPUB Accessibility, <a data-cite="epub-a11y-11#sec-discovery">section Discoverability</a>. Presentation of this information is out of scope of e-books, it is a requirement for reading systems, e-commerce websites, and platforms. </p>
</section>

<section id="annex-I-section-III-b-vii">
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robust</p>
</blockquote>

<p>Out of scope: requirement for reading systems, ecommerce websites and platforms.</p>
<p>Provision of information is covered by EPUB Accessibility, <a data-cite="epub-a11y-11#sec-discovery">section Discoverability</a>. Presentation of this information is out of scope of e-books, it is a requirement for reading systems, e-commerce websites, and platforms. </p>
</section>
</section>

Expand All @@ -266,7 +248,7 @@ <h5>(c)</h5>
making them perceivable, operable, understandable and robust</p>
</blockquote>

<p>Out of scope: requirement for reading systems, ecommerce websites and platforms.</p>
<p>This requirement is satisfied by <a href="https://www.w3.org/TR/WCAG2/">WCAG 2</a>.</p>
</section>

<section id="annex-I-section-III-d">
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communication</p>
</blockquote>

<p>Out of scope: requirement for reading systems, ecommerce websites and platforms.</p>
<p>Out of scope: requirement for support services, such as call centres.</p>
</section>
</section>

<section id="annex-I-section-IV">
<h4>Section IV: Additional accessibility requirements related to specific services</h4>

<section id="annex-I-section-IV-f">
<h5>(f) Ebooks</h5>
<h5>(f) E-books</h5>

<section id="annex-I-section-IV-f-i">
<h6>(i)</h6>
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</ul>

<div class="note">
<p>In case of Fixed Layout EPUBs some features (like flexibility and choice in the presentation of the content) may not be available.</p>
<p>There are technical limitation for certain types of Fixed Layout publications, such as comics, illustrated children’s books, and art books. For example, the flexibility and choice in the presentation of the content may not be available for these types of e-books.</p>
</div>
</section>

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