The European Accessibility Act – an interview with Simon Mellins

BookMachine Simon Mellins Accessibility Interview

Accessibility has been a frequent theme in publishing conversations for some years now, and this year will see accessibility become a legal requirement for all ebook publishers – so it’s time for us to really get up to speed on this subject!

Luckily, we have some of the best experts in the business to advise us at our next Campus event on Wednesday 12 February from 5:00–6:00 p.m.

The Road to EU Accessibility Act Readiness: Lessons, Tips and Checklists will be a chance to learn all about this important legislation and what it means for you and your organisation.

Today, we’re delighted to present this interview with independent digital publishing consultant and accessibility specialist Simon Mellins, who will be chairing the panel next week. Read on for key information – and ✨ join us next Wednesday ✨ to continue this important conversation!


Thanks for joining us today, Simon. To start with, why is it so important for people to start getting serious about the European Accessibility Act? 

The European Accessibility Act (EAA) comes into force on 28 June 2025. This affects not just publishers inside the EU, but anyone selling their publications in any EU member state. The EAA is unusually specific for accessibility legislation insofar as it directly names ebooks as being within its remit. Noncompliance can lead to substantial penalties which differ by country, but can include huge fines and even prison sentences. Many other countries outside the EU have brought in (or are bringing in) similar legislation. Whilst many publishers are now aware of the need to comply with the legislation, many are leaving it extremely late to get organised and prepared. The actual measures needing to be taken, though significant in scale, are not as complex as you might think, and plenty of manageable strategies and useful services are now available to help manage the load.

How do different publishing formats affect accessibility?

The EAA doesn’t mention any formats in particular, but it’s well-known that the most accessible format that is most capable of meeting the act’s requirements is EPUB. That said, there are many considerations around how EPUB files are constructed that determine whether it is accessible, and compliant with the legislation. There are some exceptions and mitigations within the EAA that mean in some circumstances fixed-layout EPUB and even PDF can be used, but again, those EPUBs and PDFs need to be constructed in a particular way (including meeting the PDF/UA standard for the latter) to be compliant.

Can you describe some of the specific requirements for published material?

Some of the key requirements for content include ensuring text can be resized and can reflow to fit different window sizes; providing hidden descriptions of images that assistive technologies can read, so non-sighted users can know what was in an image where relevant; ensuring text contrasts sufficiently with background colours to facilitate different levels of vision; ensuring underlying code has the right structure to ensure assistive technologies can navigate and read the publication; and much more.

Is this something that only affects frontlist publishing?

The question of whether backlist/catalogue publications are within the act has been debated for years, and a pesky clause in the EAA relating to a 5-year ‘grace period’ remains contentious. However, industry consensus has now recognised that backlist publishing is in-scope – but don’t panic – you won’t have to have your entire backlist remediated on day 1, as most publishers seek to adopt a model that remediates key backlist as soon as possible, and provides deeper/less popular backlist on a rapid query response basis. Time will tell if this approach is considered acceptable to the European Commission, but the consensus among publishing lawyers so far seems to be that this approach will suffice.

And how about metadata – does the Act cover this too?

Metadata is covered by the act, though not with much specificity on format. The act is focused on discoverability, compelling publishers to provide extra metadata informing readers about the accessibility properties of a publication before they commit to acquiring it. Whilst format isn’t stated in the act, the generally accepted answer (and the one most likely to be adopted in any ‘harmonised standard’ from the EU) is the ONIX format that most publishers in the UK are already using. There is a specific subset of ONIX codes specially for accessibility, along with a few codes in other code lists. EPUB also has its own accessibility metadata within the EPUB itself, though these can be mapped across from the ONIX values to save too much doubling up of work.


In our Campus event next week, we’ll also be hearing from Leanne Dobson, UX Designer, Frontiers, Simon Holt, Senior Product Manager, Elsevier and Achim Bosse Chitty, Head of Production at Bloomsbury Publishing Plc, about their accessible publishing journeys, along with expert input from Simon Mellins. You’ll get a hands-on view of what compliance really means and where to focus the precious time we have left.

Register to join us on Wednesday 12 February from 5:00–6:00 p.m.

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