The European Accessibility Act and e-books: the six Annex I requirements, EPUB Accessibility 1.1, and what a PDF e-book has to do

The European Accessibility Act is the first law to make the accessibility of commercial e-books a market-access condition rather than a matter of goodwill. It has applied since June 28, 2025, and it reaches publishers, distributors, and retailers selling to consumers in the EU wherever they are based. This guide quotes the e-book requirements from the Directive's own Annex, explains the mapping the W3C has published for EPUB, and answers the question publishers with PDF backlists ask: does a PDF count, and what would it have to do?

Scope and dates

Article 2 of the Directive lists the products and services in scope. Among products "placed on the market after 28 June 2025" are e-readers (Article 2(1)(e)); among services "provided to consumers after 28 June 2025" are e-books and dedicated software (Article 2(2)(e)), alongside e-commerce services, which covers the online shops that sell them. Article 31 required Member States to apply their transposing measures from June 28, 2025. Article 4(5) exempts microenterprises providing services from the service requirements, which relieves the smallest publishers of the obligation on the e-books they provide. Article 32 sets the transitional measures: service providers may continue for a period ending June 28, 2030 to use products they lawfully used before the date to provide similar services, and "service contracts agreed before 28 June 2025 may continue without alteration until they expire, but no longer than five years from that date". That is the origin of the June 2030 date quoted for backlists; it is a transition for existing arrangements, not a deferral for new titles.

The six e-book requirements

Annex I, Section IV(f) requires, for e-books:

1. "ensuring that, when an e-book contains audio in addition to text, it then provides synchronised text and audio";
2. "ensuring that e-book digital files do not prevent assistive technology from operating properly";
3. "ensuring access to the content, the navigation of the file content and layout including dynamic layout, the provision of the structure, flexibility and choice in the presentation of the content";
4. "allowing alternative renditions of the content and its interoperability with a variety of assistive technologies, in such a way that it is perceivable, understandable, operable and robust";
5. "making them discoverable by providing information through metadata about their accessibility features";
6. "ensuring that digital rights management measures do not block accessibility features".

Section IV(e), for consumer banking, and IV(g), for e-commerce, sit alongside these and matter to the shops that sell e-books: identification, security, and payment functions must be perceivable, operable, understandable, and robust, and e-commerce services must provide the accessibility information about products being sold where the responsible operator has provided it, which is where the e-book's accessibility metadata ends up.

The EPUB mapping

On August 28, 2025 the W3C published a Group Note, *EPUB Accessibility, EU Accessibility Act Mapping*, that takes each Annex I requirement in turn and shows how EPUB Accessibility 1.1, together with WCAG, satisfies it: media overlays for synchronised text and audio; WCAG's non-interference, name-role-value, and keyboard requirements for not blocking assistive technology; EPUB's table-of-contents and page navigation plus WCAG's adaptability and reflow for access, navigation, and structure; full WCAG conformance for alternative renditions; EPUB Accessibility 1.1's discoverability metadata section; and its distribution guidance for DRM. The note records a limitation for fixed-layout publications such as comics and children's books, and it contains no discussion of PDF or any non-EPUB format. EPUB Accessibility 1.1 itself became a W3C Recommendation in October 2024. For a publisher, the consequence is that EPUB has a documented, standards-body-backed route to meeting the Act, and other formats do not.

What about PDF e-books?

The Directive is format-neutral: an e-book sold as a PDF is an e-book and must meet the same six requirements. Read against a PDF, they demand a tagged file with a correct structure and reading order (requirements ii and iii), a document that assistive technology can navigate by headings, bookmarks, and page labels (iii), text that can be reflowed or otherwise presented flexibly (iii and iv), accessibility metadata both in the file and in the retail feed (v), and no DRM that blocks text-to-speech or screen readers (vi). PDF/UA is the standard for the first of these, and the PDF/UA versus WCAG guide explains why it is necessary but not sufficient. Flexibility of presentation is where PDF struggles: a fixed page can be zoomed and, in some viewers, reflowed from tags, but it cannot offer the font, spacing, and layout choices an EPUB reader gives. The practical advice is therefore:

• New titles: produce EPUB 3 conforming to EPUB Accessibility 1.1, and treat a PDF edition as a secondary format that must still be tagged and described.
• PDF-only backlists: decide title by title between conversion to EPUB and remediation to a tagged, PDF/UA-aligned file with metadata; the transitional period is for existing contracts, so plan the work rather than wait for 2030.
• Fixed-layout and image-heavy titles: these are the hardest in either format; the W3C note acknowledges the limitation for EPUB, and for PDF the alt text and spatial graphics guides describe the alternatives that make them usable.
• Metadata everywhere: accessibility features must be declared in the file and passed through the supply chain so that shops can display them, as Section IV(g) expects.

Who enforces, and what "in scope" costs

The Act is enforced through national market surveillance authorities and, for services, the authorities each Member State designates; consumers and organisations can bring complaints under national law. A publisher outside the EU that sells to EU consumers is providing a service in the EU. The same Act's e-commerce provisions apply to the storefront, so a retailer can be non-compliant for an inaccessible checkout regardless of the books. The EN 301 549 guide covers the standard being revised to support the Act and the presumption of conformity it will carry once cited.

Frequently asked questions

Sources

The statements above rest on the primary sources below. Where a source is a law or standard, the version and date named in the text are the ones checked on the review date. This guide is general information, not legal advice.

1. EUR-Lex: Directive (EU) 2019/882 (European Accessibility Act), Articles 2, 4, 31, 32 and Annex I Section IV . Scope, dates, the microenterprise exemption, the transitional measures, and the six e-book requirements quoted verbatim.
2. W3C: EPUB Accessibility, EU Accessibility Act Mapping (Group Note, August 28, 2025) . The requirement-by-requirement mapping to EPUB Accessibility 1.1 and WCAG, and the fixed-layout limitation.
3. W3C: EPUB Accessibility 1.1 (Recommendation)