European Accessibility Act (EAA) Checklist: Is Your Ebook Store Compliant?

The European Accessibility Act (EAA) has been in effect since June 28, 2025. If you sell ebooks in the European Union—or to EU customers from anywhere in the world—your digital publishing platform, storefront, and reading applications must now meet specific accessibility requirements.

This is not a future obligation. It is current law, with enforcement mechanisms and potential penalties already active across EU member states.

This checklist covers the key requirements publishers and ebook retailers need to address, organized by the areas most likely to need attention.

What the EAA Requires for Ebook Services

The EAA (Directive 2019/882) covers "e-commerce services" and "ebooks and dedicated software," which means three components of your digital publishing operation fall under its scope:

1. The ebook files themselves — EPUB and PDF content must be accessible
2. The storefront/website — where readers browse and purchase content
3. The reading application — web readers, native apps, and any software used to consume the content

Each has distinct requirements. Missing compliance in any one area can trigger enforcement action.

Checklist: Ebook File Accessibility

EPUB 3 is the recommended format for accessible ebooks. The W3C's EPUB Accessibility specification maps directly to EAA requirements.

• Navigation structure: All ebooks must have a logical reading order, a table of contents (NCX or nav), and properly nested headings (h1–h6)
• Alternative text: Every image must include descriptive alt text. Decorative images must be marked as such (role="presentation")
• Language declaration: The primary language must be declared in the EPUB metadata, and language changes within the text must be marked
• Semantic markup: Use EPUB semantic roles (epub:type) and ARIA roles for tables, lists, footnotes, and sidebars
• Font flexibility: Reflowable EPUBs must allow font resizing, typeface changes, and line/letter spacing adjustments. Fixed-layout EPUBs should provide a reflowable alternative where feasible
• Color contrast: Text-to-background contrast must meet WCAG 2.1 AA standards (4.5:1 for normal text, 3:1 for large text). Information must not be conveyed by color alone
• Accessibility metadata: Include schema.org accessibility metadata (accessMode, accessibilityFeature, accessibilityHazard, accessibilitySummary) in the EPUB package document
• Text-to-speech compatibility: Content must not block TTS engines. Pronunciation hints (SSML or PLS) should be provided for specialized terminology

Checklist: Storefront Accessibility

Your ebook store—whether a standalone website or part of a larger platform—must comply with WCAG 2.1 Level AA at minimum.

• Keyboard navigation: All functionality must be operable via keyboard alone. Tab order must follow a logical sequence. Focus indicators must be visible
• Screen reader compatibility: All interactive elements (buttons, forms, filters, cart) must have proper ARIA labels and roles
• Search and filtering: Catalog search must work with assistive technologies. Filter controls must announce their state (expanded/collapsed, selected/unselected)
• Checkout process: Payment forms must have labeled fields, clear error messages, and be fully navigable without a mouse
• Accessibility information display: Product pages must display the accessibility features of each ebook (based on the accessibility metadata in the file). Readers need to know before purchase whether a title meets their needs
• Responsive design: Content must be readable and functional at 200% zoom and on mobile viewports
• Media alternatives: Promotional videos must have captions. Audio previews must have transcripts

Checklist: Reading Application Accessibility

Your web reader, iOS app, Android app, and desktop apps must all meet accessibility standards. This applies to both custom-built and white-label reading applications.

• Screen reader support: The reading interface must work with VoiceOver (iOS/macOS), TalkBack (Android), and NVDA/JAWS (Windows). Content must be read in the correct order
• Visual customization: Readers must be able to adjust font size, typeface, line spacing, margins, and color themes (including high contrast and dark mode)
• Navigation controls: Table of contents, bookmarks, and page/chapter navigation must be keyboard-accessible and screen reader-compatible
• Audio playback controls: For audiobooks, playback speed, chapter navigation, sleep timer, and bookmarking must be accessible via keyboard and screen readers
• Focus management: When navigating between pages, chapters, or UI elements, focus must be managed predictably. Opening a menu or dialog must move focus; closing it must return focus
• Gesture alternatives: Touch gestures (swipe to turn pages, pinch to zoom) must have button-based alternatives for users who cannot perform gestures

Who Is Exempt?

The EAA includes a limited exemption for microenterprises (fewer than 10 employees and annual turnover under €2 million). However, this exemption does not apply to the ebook files themselves—only to the service (storefront/app) requirements. Even micro-publishers must produce accessible content.

Additionally, if a non-EU publisher sells to EU customers through an EU-based platform or distributor, the platform is responsible for compliance—but publishers who supply inaccessible content create liability for their distribution partners.

Penalties and Enforcement

Each EU member state defines its own penalties. Enforcement approaches include market surveillance (inspecting products and services for compliance), complaints from consumers or advocacy organizations, and administrative fines. Some member states have proposed fines up to €100,000 per violation.

Beyond fines, non-compliance risks exclusion from public procurement contracts—a significant revenue stream for publishers selling to libraries, universities, and government institutions.

How to Get Compliant

For most publishers, the fastest path to compliance involves three parallel workstreams:

1. Audit your EPUB production pipeline. Ensure your content creation tools output accessible EPUBs with proper structure, metadata, and alt text. Tools like ACE (Accessibility Checker for EPUB) from the DAISY Consortium can automate much of this validation
2. Evaluate your storefront. Run a WCAG 2.1 AA audit on your ebook store. Automated tools catch about 30% of issues; manual testing with screen readers and keyboard-only navigation catches the rest
3. Choose a compliant reading platform. If your reading application doesn't meet accessibility standards, fixing it is a significant engineering effort. Using a platform that already handles DRM and content protection with built-in accessibility support eliminates this burden entirely

Publica.la's reading applications are built with accessibility as a core requirement, not an afterthought. Screen reader support, visual customization, and keyboard navigation are standard across all platforms.

Need help with EAA compliance? Explore Publica.la's platform for publishers—built with accessibility standards from the ground up—or schedule a meeting to discuss your compliance roadmap.