E-books Are Named in the Law, and Most Are Not Ready

The European Accessibility Act names e-books, e-book software and the shops that sell them. If you publish or sell them into the EU, this is one of the few places where a specific content format sits directly in the text of the law.

There is a piece of luck in that. EPUB is built on HTML, so almost everything you already know about web accessibility applies, and the format was designed with reading systems in mind rather than page images.

Reflowable, Not Fixed Layout

This is the decision that determines everything else. A reflowable EPUB lets the reader change the font, the size, the spacing and the line length, and the text rewraps. A fixed-layout EPUB is a set of pages with everything pinned in place.

Fixed layout defeats the point for most readers who need it. Somebody using large text gets a small page they have to pan around, which is the same failure as a page that will not reflow at 320 pixels. Reserve fixed layout for books where the arrangement genuinely is the content, such as picture books and some technical illustration, and accept that those need more work.

What an Accessible EPUB Contains

• Real heading structure. Chapters and sections marked with heading elements, so a reader can move by chapter rather than by scrolling. Same rule as 1.3.1 Info and Relationships.
• A navigation document. The table of contents that reading systems use. Without it the book is one long scroll.
• Alt text on every meaningful image, and empty alt on decoration, exactly as on the web.
• Extended descriptions for complex images, since a chart in a textbook carries information a sentence cannot.
• A declared language, and marked passages where the language changes.
• Semantic markup for structure, so footnotes, page breaks and asides are announced as what they are.
• Page list where print page numbers matter, which is what lets somebody in a classroom follow along with a printed edition.
• Synchronised text and audio where the book carries both, which the EAA names directly rather than leaving to good practice.
• Digital rights management that leaves accessibility features alone. The EAA says so in terms, and a lock that blocks text-to-speech is the version of this that keeps happening.

Where E-books Actually Fail

1. 1Scanned pages. A book that is images of pages has no text at all. No screen reader, no search, no resizing. It is the EPUB version of an untagged PDF.
2. 2Images with no description, which in an illustrated or technical book removes a large part of the content.
3. 3Headings styled rather than marked, usually from a conversion that preserved the look and lost the structure.
4. 4No navigation document, so there is no way to move between chapters.
5. 5Tables used for layout, which read as nonsense in a linear order.
6. 6Fixed layout chosen by default by a conversion tool, rather than as a decision.

If You Are Buying Conversion

Most publishers do not make their own EPUBs. The questions worth asking a supplier are the same shape as the ones in briefs and contracts.

• Will the output be reflowable, and if not, why not for this title?
• Who writes the image descriptions, and are they priced in? This is the line item that usually is not.
• Will the file carry accessibility metadata?
• Will it be checked, and with what? The EPUB accessibility checker is the usual answer and it is a floor rather than a verdict.
• What happens to the source, so the next edition does not start from scratch?

The Standard Behind It

EPUB Accessibility is the specification, and it works by pointing at WCAG rather than inventing a new set of rules. Conformance is expressed as meeting WCAG at a stated level, which is why the criteria on this site apply to a book almost unchanged. The EPUB accessibility entry covers the terms.

For anything published as a PDF instead, the rules are different and harder, which is covered in PDF accessibility. If the source is a Word file, fixing it there first is far cheaper than fixing either output, as set out in Word, PowerPoint and Excel.