What are the risks of publishing ebooks that are not accessible in the European Union?
03/2025
From June 28, 2025, the European Accessibility Directive will come into effect for publishers wishing to publish ebooks within the European Union, regardless of whether they are established in the EU or not. Does this apply to you? What are the accessibility requirements? And what are the risks in the event of an inspection?
Interview multiple candidates
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Search for the right experience
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Vet candidates & ask for past references before hiring
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Once you hire them, give them access for all tools & resources for success
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Who is required to make ebooks accessible?
Digital technology creates new opportunities for people with disabilities, and the book industry has a key role to play in ensuring content is accessible to all. This is the goal of the European Directive on accessible ebooks.
As the first link in the chain, publishers are directly impacted by this legislation. However, other stakeholders must also be involved:
Publishers, distributors, and booksellers must ensure that readers are informed about available accessibility features and can determine whether a book meets their needs.
Software developers must provide reading solutions that support all accessibility features.
Initially, only new releases will be affected. Digital books published before June 28, 2025, will not be subject to this legal requirement until June 28, 2030.
What are the accessibility requirements for publishers?
All digital books published within the European Union must meet specific accessibility criteria, regardless of where you are based. These include:
Including alternative descriptions for images that are useful for understanding the content;
Using file formats that allows readers to customize the layout according to the their needs (font size, contrast, and so on), and that are compatible with assistive technologies, such as text-to-speech;
Using anti-piracy measures for your files (DRM) that do not block or hamper accessibility features;
Providing accessibility information in the metadata for each of your ebooks, so they can be more easily discovered by readers.
3 examples of exemptions from accessibility requirements
Does this apply to all publishers wishing to publish ebooks within the European Union? You may be eligible for an exemption from accessibility requirements under the following conditions:
Size of Your Publishing House
If your publishing house has fewer than 10 employees and an annual turnover or balance sheet total not exceeding 2 million euros, you may qualify for an exemption.
Fundamental Change to Content
An exemption may be granted if making a book accessible would require altering its content in a way that compromises its integrity. This applies to cases where content and form are inseparable, such as comic books.
Disproportionate Burdene, assessed according to three factors:
Proportion of Accessibility Costs: The share of total production costs represented by accessibility expenses, including ongoing costs (accessible production) and one-time costs (such as hiring, training, or implementing accessibility tools).
Economic Potential of the Work: Factors such as genre, sales performance (both volume and value), and media exposure of the digital book.
Financial Resources of the Publisher: A comparison of net compliance costs with the publisher's net revenue to determine the financial impact.
Exemptions based on fundamental content changes or disproportionate burden must be formally declared and justified in accordance with a procedure that, for the time being, is likely to be country-specific.
In the meantime, the next section will provide an analysis and updates on the practical application of the European Directive on accessible digital books, broken down by country.
Implementation of the law on accessible ebooks in each European country
While the legislative framework for ebook accessibility applies across the European Union, its implementation procedures may vary by country.
Publishers will need to register the ebooks they claim as exemptions to the supervisory authorities in each country where their ebooks are sold, as there is currently no provision for a European one-stop shop.
With just a few months until enforcement begins, national authorities are gradually releasing details on compliance checks and potential risks.
We’ll be sharing these updates in the coming weeks. Follow us and subscribe to the De Marque Academy to stay informed!