The European Accessibility Act Is Live: What Publishers Must Remediate in Their Backlist

TL;DR

The European Accessibility Act has been law since 28 June 2025, and the first year gave us something no guidance document could. Real court decisions. In June 2026 a French court told a big retailer to fix its website and app within six months or pay a daily fine. A similar case against another retailer failed. For publishers the hard question was never new books. It is the backlist, and the honest answer depends on which country you sell into, because France, Sweden, Finland and Denmark wrote the same rule into national law differently.

This guide covers what EAA compliance means for ebooks, where EN 301 549 fits, how to plan backlist remediation, what accessibility metadata you must publish, and what changed in 2026.

Most publishers spent 2024 and early 2025 getting their new-title process ready. That was the right call, and new books now come out in reasonable shape. The backlist is the problem still open.

A publisher with 40,000 titles cannot fix 40,000 EPUBs in a year, and nobody expected it to. What has changed is that the first court decisions have arrived and regulators have started checking. The question is no longer what the law says, but which titles you fix first and what you can show if asked.

Table of Contents

1. What Is the European Accessibility Act, and Who Does It Cover?
2. Where the European Accessibility Act Stands in 2026
3. ePub Accessibility: What EAA Compliance Requires Inside the File
4. Where EN 301 549 Fits, and What Changes in 2026
5. Backlist Remediation: Does the EAA Apply to Titles Already on Sale?
6. Accessibility Remediation at Scale: Triaging a Backlist You Cannot Fix at Once
7. Accessibility Metadata Is the Part Most Publishers Get Wrong
8. The Storefront and the Reading App Are In Scope Too
9. Fines, and Who Is Left Out
10. A Checklist for the Next Six Months
11. Where KITABOO Fits
12. Start With the Catalogue, Not the Statute
13. Frequently Asked Questions

The European Accessibility Act is an EU law, Directive (EU) 2019/882, that sets one common set of accessibility rules for products and services sold in the European Union. It replaced a patchwork of national rules and has applied since 28 June 2025 in all 27 member states.

It covers a defined list rather than the whole economy, computers, smartphones, e-readers, ticketing machines, banking, transport, e-commerce, and ebooks together with the software used to read them. Below are the questions people ask most often.

Publishers are covered twice over, and that pairing is on purpose. The file, the shop and the reading app are all in scope, and doing well on one does not excuse a weakness in another.

Three things from that first year are worth knowing.

• France, court cases. In July 2025 two disability groups, apiDV and Droit Pluriel, warned four large grocery chains that their online shopping was not accessible. Nothing changed, so they went to court. In June 2026 the court in Caen ordered Carrefour to make its website and app fully accessible within six months, with a fine for every day it runs late. In a parallel case the court decided Auchan was not covered. That is being appealed.

• Sweden, inspections. In October 2025 the Swedish Post and Telecom Authority began its first EAA inspection, looking at laptops, smartphones and tablets. It started with paperwork and with the accessibility information given to customers.

• Germany, overlays rejected. German auditors using the BIK method treat an accessibility overlay widget as a reason to fail a site, not as a fix. If a widget is your plan for the shop, you do not have a plan.

A pattern shows up. Pressure comes from two directions, regulators checking paperwork, and disability groups going to court. Paperwork checks come first because they are cheap to run. That is why the dullest duty in the law, publishing correct accessibility information, is the one most likely to trip you up.

The law describes results, not a checklist, which is why teams find it hard to pin down. Annex I says information must reach people through more than one sense, content must be easy to understand and use, files must work with assistive technology, and accessibility features must be described in the product information.

For a reflowable EPUB, that comes down to a familiar list.

The problems that keep showing up in a converted backlist. None of them is unusual, which is what makes sorting titles in bulk possible.

For the technical detail behind any of these, our guide to ebook accessibility and our walkthrough on building accessible digital content go further than this page can.

EN 301 549 is the European standard that turns those results into things you can test. Meet it and you are treated as meeting the matching legal duty. That is the practical reason to work from the standard, not the law itself.

The version officially in use is EN 301 549 V3.2.1, published in 2021, which is built on WCAG 2.1 Level AA. A newer version is being prepared, expected to be numbered V4.1.1 and to move up to WCAG 2.2 Level AA. Until that version is officially adopted, V3.2.1 and WCAG 2.1 AA are what you will be measured against.

What that means for planning is simple. Fix your backlist to WCAG 2.1 AA now and handle the extra 2.2 items later. Waiting for the new version before you start is not a plan, because the duty already applies, and the gap between 2.1 and 2.2 is small next to the gap between an untagged file and a properly tagged one.

If your team already works to US rules, we have a separate comparison of WCAG, Section 508 and the ADA.

This comes up in every meeting because there is no single answer. Article 32, the transition rule, lets service providers keep using products they already used before 28 June 2025 until 2030, and lets earlier contracts run to their end for up to five years. Whether an ebook already on sale counts as one of those things is exactly what people disagree about.

Countries settled it differently. France gave a five-year grace period. Sweden left out some older content, though later law suggests that exemption is narrower than first thought and may cover only PDFs on the web. Finland and Denmark decided the rules apply the same way to old and new titles.

The same directive, four different answers. Source: DAISY Consortium’s Inclusive Publishing , which tracks regional divergence.

Two conclusions follow. If you sell across the EU, the strictest country in your footprint sets your real duty, not the most generous. And the grace periods that exist are expiring, not arriving. A French publisher relying on the five-year window is already a year into it.

Most large publishers have settled on the same approach. Plan for the strictest reading. Taylor & Francis treats the harshest reading of the EAA as its baseline. That is cheaper than finding out in 2029 that you read the rule wrongly across 40,000 titles.

Nobody fixes everything. Accessibility remediation at this scale is a sequencing problem. Take the riskiest and most-wanted titles first, and be able to show you chose that order.

Sort the catalogue on four things, not one. Sales tell you what is still selling. Institutional buyers tell you what universities, libraries and public bodies buy, which is where purchasing rules bite hardest. Complexity tells you what is cheap to fix. A plain-text novel and a textbook full of diagrams are not the same job. Source quality tells you whether you are repairing an EPUB or rebuilding from a print PDF.

Four groups, not one long queue. Group 4 is a decision, and a decision you never wrote down is the one that causes trouble.

Be careful with that last group. The law does let you argue that a fix would cost far too much, or would change the product beyond recognition. But that only counts if you did the assessment, wrote it down, and review it now and then. Quietly deciding a title was not worth fixing is not an exemption.

The other honest option for a title that no longer sells is to stop offering it in the EU. That is a business decision, not a compliance failure.

The law does not just ask for accessible files. It asks you to describe the accessibility features in the product information. In publishing that means metadata, and it is the one part a regulator can check without opening a single EPUB.

There are two layers. Inside the file, EPUB accessibility metadata records how the content can be read, which features it has, any hazards such as flashing, a conformance claim, and a short summary for a person to read. Outside the file, that information has to reach shops and libraries through your trade feed, which means ONIX 3.0 and its accessibility codes. One detail catches people out. Under EPUB Accessibility 1.1 the summary should not repeat what the codes already say.

Get this wrong and two things follow. A reader with a print disability cannot tell before buying whether your book will work for them, which is what the law exists to prevent. And an inspector sees a record with no accessibility information, which is the easiest finding to write up.

A perfectly tagged EPUB sold through a shop nobody can use does not make you compliant. The French cases prove it. They were about online shops, not book files. Three things need to hold up.

• The shop. Browsing, search, filters, basket and checkout all have to work with a keyboard alone, with a visible focus outline, labelled fields and errors a screen reader reads out. Product pages must also show each title’s accessibility features, so a reader can decide before paying.

• The reading app. Web and mobile apps have to work with VoiceOver, TalkBack, NVDA and JAWS. Readers need to change text size, spacing and colours, navigation and bookmarks must be reachable by keyboard, anyone who cannot swipe or pinch needs a button instead, and focus must behave predictably when menus open and close.

• Anything you white-label. If you deliver through someone else’s platform, their accessibility problems become your risk. Ask for a conformance report rather than a sales claim, and read the remarks column.

The law tells each country to set penalties that fit the offence. It sets no EU-wide figure, maximum fines differ a lot by country, and in at least one you can face criminal charges. The shape of the risk matters more than the numbers. Regulators can also pull a product from sale, order an audit, and publish what they found.

Losing sales usually hurts more than the fine. Public bodies, universities and library groups have their own accessibility rules for what they buy, so a catalogue nobody can use quietly stops qualifying long before anyone issues a fine.

The exemption for very small companies is narrower than publishers hope. If you are a tiny publisher, your shop may get relief. The files still have to be accessible.

• Work out which countries you sell into and find the strictest rule among them. That sets your real deadline.

• Run an automated check across the whole catalogue first. Ace, the free EPUB accessibility checker from the DAISY Consortium, separates files that need rebuilding from files that only need alt text.

• Group the catalogue by sales, institutional buyers, complexity and source quality. Write down your reasons.

• Finish Group 1 completely, checks and metadata included, before starting Group 2.

• Publish accessibility metadata in the file and the ONIX feed for every title you fix, on the day it goes out.

• Audit the shop and reading app against EN 301 549 with keyboard and screen-reader testing, not just a scan.

• Write down any assessment that a fix costs too much, with the numbers, and set a review date.

• Ask every vendor for a conformance report against EN 301 549, and read the remarks.

KITABOO’s reading apps are available on web, iOS and Android. KITABOO Fluid 360 covers production, importing from PDF, InDesign and DOCX, generating alt text and correcting reading order during authoring, and checking WCAG 2.2 AA conformance as content is built rather than audited afterward, which is what accessibility remediation at volume actually needs.

The law has been read closely enough by now. What separates calm publishers from worried ones is whether they can show four things. A grouped list of titles, a record of what was fixed and when, correct metadata on live titles, and a written assessment for anything left alone on purpose. That is what an enquiry asks for, and it is buildable in a quarter.