The European Accessibility Act (EAA) came into full force in June 2025, applying to all digital products and services sold in the European Union — including eBooks. Publishers distributing to EU markets who have not yet addressed EPUB Accessibility 1.1 compliance are now operating outside the law in one of the world's largest publishing markets.
This guide explains what EPUB Accessibility 1.1 actually requires, what it means for your production workflow, and how to approach compliance efficiently without rebuilding your entire back catalogue.
What is EPUB Accessibility 1.1?
EPUB Accessibility 1.1 is the W3C specification defining accessibility requirements for EPUB publications. It is based on WCAG 2.1 (Web Content Accessibility Guidelines) adapted for the EPUB format, and covers the structural, semantic, and metadata requirements that make an eBook usable by readers who rely on screen readers, refreshable Braille displays, or other assistive technologies.
The specification defines three conformance levels — Level A, Level AA, and Level AAA. The European Accessibility Act requires Level AA conformance as the minimum threshold. Most institutional procurement, library licensing, and educational distribution channels in EU countries now enforce this requirement contractually.
What does Level AA compliance actually require?
1. Complete, accurate metadata
Every compliant EPUB must include schema.org accessibility metadata in the OPF package document, declaring: accessMode (textual, visual), accessModeSufficient, accessibilityFeature, accessibilityHazard, and accessibilitySummary. This metadata must be accurate — declaring "textual" accessModeSufficient on a Fixed Layout ePub with unsupported image text is a compliance failure, not a workaround.
2. Logical reading order
Every element of the publication must appear in the EPUB spine and reading order in a logical sequence. This is obvious for linear narrative text, but requires careful attention for sidebars, pull quotes, figures, tables, and any content that appears visually out of sequence from its semantic position in the document.
3. Meaningful alternative text for all images
Every image that conveys information must have alt text that conveys the same information to a reader who cannot see the image. Decorative images must be explicitly marked as decorative (empty alt text or role="presentation"). This requirement extends to figures, charts, diagrams, and any graphical element that a sighted reader would use to understand the content.
Alt text for complex scientific figures cannot be a generic description like "Figure 3." It must convey the actual information the figure communicates — the trend in the data, the structure being illustrated, the relationship being shown. This requires subject-matter awareness, not just image description.
4. Accessible tables
Tables must use correct HTML table markup with header cells (th elements with scope attributes), caption elements, and summary attributes where appropriate. Simple tables in most ePub3 productions already meet this requirement if the compositor has used semantic markup. Complex tables with merged cells, multi-level headers, or spanning relationships require additional ARIA attributes.
5. Keyboard navigation and ARIA landmarks
The publication must be fully navigable without a pointer device. EPUB reading systems handle most keyboard navigation, but the publication must include ARIA landmark roles — nav, main, aside — to enable screen reader users to jump between major content regions efficiently.
6. Language declaration
The publication language must be declared in the OPF metadata and on the html element of each content document. Language changes within the text (foreign language quotations, multilingual content) must be marked with lang attributes on the appropriate element.
What about Fixed Layout ePubs?
EPUB Accessibility 1.1 applies to Fixed Layout publications as well as reflowable ones, but achieving compliance is significantly harder. FXL accessibility requires per-page reading order declarations using the epub:type="pagebreak" and aria-label attributes, extensive use of the epub:switch element for alternative content, and careful management of the z-order to ensure reading order matches visual order.
Many Fixed Layout productions currently sold in EU markets do not meet Level AA — and the EAA does not provide a grandfathering exemption for existing titles. Publishers with large FXL catalogues distributed to EU markets should prioritise a compliance audit of their highest-revenue titles.
The back catalogue question
The EAA does not require immediate remediation of all existing titles — it applies to new publications and significantly revised existing publications. However, if an inaccessible title is being actively sold and has not been revised since June 2025, EU national enforcement authorities can require remediation. Prioritise your active commercial catalogue over your inactive backlist.
Building accessibility into production rather than retrofitting it
The most efficient path to compliance is embedding accessibility requirements into your standard production brief and QA checklist — so that every new title is born compliant, rather than requiring a remediation pass after production. Retrofit compliance costs 40–70% more per title than building it in from the start, because the compositor must reopen, re-examine, and revise completed work.
At Daintra, EPUB Accessibility 1.1 Level AA compliance is standard on all ePub3 productions — included in our base quote rather than charged as an add-on. If you're currently working with a vendor who charges separately for accessibility compliance, that's worth addressing in your next production contract.
