Accessibility Metadata Working Group

Accessibility Resources (under development)

Current situation

Accessibility metadata for ebooks is essential because it ensures that digital content is discoverable and usable by individuals with disabilities. By including detailed information about the accessibility features of an ebook—such as text-to-speech compatibility, alternative text for images, or navigation aids—readers with visual, auditory, or cognitive impairments are empowered to select content that meets their needs. It promotes inclusivity, helping to create a more equitable reading experience for all users. Further, accessibility metadata supports compliance with legal standards, such as the European Accessibility Act (EAA) and the Americans with Disabilities Act (ADA). 

THE EUROPEAN ACCESSIBILITY ACT (EAA)

The publishing industry faces a June 28th, 2025 deadline for complying with the European Accessibility Act (EAA). Officially adopted in April 2019, the EAA aims to ensure accessible services (such as ebooks and ecommerce sites) and products (such as ereaders) are widely available to persons with disabilities and the elderly through the creation of a more inclusive marketplace with baseline accessibility standards. To this end, the EAA has been implemented within EU nations through Member States’ individual national laws. These laws will apply to any entity distributing ebooks (whether by selling them or by making them freely available) both within, and into, the EU.

While broad guidance is available, some ambiguities in interpretation remain, especially regarding backlist titles. Under the EAA, ebooks are defined as a service; this definition affects how the EAA is applied and is relevant to when compliance is required for backlist titles. The blog post Content Considerations and the European Accessibility Act by Tyler Carey (Westchester Publishing Service) is helpful in providing additional detail. Compliance involves specific formatting and compatibility for screen readers, accessible navigation, and clear labeling of interactive elements, helping to create a more inclusive digital marketplace.

To support compliance, the Accessible Backlist Ebooks Laboratory (ABE Lab) project is researching cost-effective methods and workflows for updating backlist titles. Their findings suggest that remediation costs may vary by content type and complexity, with the EU estimating an average of 400 euros per title. Since the backlist includes millions of titles, the directive’s implementation without support may lead to publishers withdrawing non-compliant works, potentially reducing cultural diversity across European markets. Industry guidance, like that from DAISY and other accessibility advocates, emphasizes prioritizing high-demand backlist titles and evaluating available open-source and commercial tools for efficient, scalable compliance​. More information is available on the European Commission's website. 

THE AMERICANS WITH DISABILITIES ACT (ADA)

Additionally, the publishing industry must prepare for compliance with new requirements in Title II of The Americans with Disabilities Act (ADA), which will go into effect beginning April 2026. The ruling requires that state and local governments’ web content and mobile apps meet Web Content Accessibility Guidelines (WCAG) Version 2.1, Level AA. The WCAG is an international technical standard maintained by the W3C. This article, published in November 2024 by Inclusive Publishing, is a helpful overview; so too does this article from Level Access.

Under the new Title II ADA requirements, public entities, including publicly funded book publishers, must ensure that all digital content they provide or make available meets accessibility standards. This applies not only to content published directly on their platforms, but also to materials distributed through third-party organizations under contracts, licenses, or other agreements. Publishers must ensure digital books are accessible to individuals with disabilities, supporting formats compatible with assistive technologies like screen readers. This is especially relevant to academic publishers seeking course adoption of their books. 

As these deadlines approach, BISG has received increasingly frequent questions from across the book industry supply chain on where to look for clarification, what metadata must be communicated, how to communicate it, and what must be publicly displayed at the retailer level. After considerable discussion within BISG’s Metadata Committee and Workflow Committee, this working group was launched as a joint effort between both committees to amplify existing resources and educate the industry ahead of the compliance deadlines. 

Objectives

• Educate the industry on standards and best practices around the inclusion, communication, and display of accessibility metadata in accordance with the EAA
• Amplify the work of organizations specializing in accessibility metadata
• Recommend one or more approaches to accessibility metadata workflows for the US market
• Identify or recruit organizations that can assist in the development, implementation, and communication of accessibility metadata by US suppliers.
• In concert with the Metadata Committee, serve as the US national body and voice of authority on metadata in communication with EDItEUR

Stakeholder Impact / Benefits

Effective management of accessibility metadata in compliance with the EAA and ADA will help operators in the US book industry by: ensuring uninterrupted sales within, and into, the European Union; avoiding noncompliance penalties enforced by EU Member States; increasing the discoverability of titles; remove barriers to course adoption, improving sales of academic titles; enhancing relationships with readers, connecting them to the content they're seeking; making strides regarding inclusivity of content; creating a baseline that eases pain points across the metadata supply chain; creating more robust product pages that attract deeper readership; reducing frustration/disappointment for readers,  ensuring the content they want is accessible; and increasing discoverability of backlist titles.

Deliverables

The working group will:

• Monitor and share information about how the EAA and ADA change metadata requirements and workflows in the North American market. Here, the working group will review regulations (based on general principles), specifications (actionable direction), and available guidelines (e.g. WCAG).
• Monitor and share information about how EU Member States will codify and enforce the EAA, and explain where needed EAA definitions and compliance deadlines.
• Identify potential consequences of failing to conform, where applicable.
• Amplify the work being done by organizations such as DAISY, Benetech, and Fondazione LIA on accessibility metadata, such as the mapping work between the EAA and WCAG.
• Educate the US book industry on providing appropriate metadata as required under the EAA through thoughtful programming, posts, and publications. Identify areas of overlap and difference with other, North American regulations, including the ADA.
• Inform BISG’s work as the national metadata body and provide resources for supplying accessibility metadata in ONIX
• Identify and recommend workflows for developing, communicating, and displaying accessibility metadata (order of operations, removing duplicative efforts, and more)
• Raise awareness of implementation across the library space, potential update to MARC / collaborate with IFLA group
• Raise awareness of the W3C best practices with service providers, including libraries
• Amplify white paper produced by PDF group on accessibility metadata for PDF and static formats

Blockers

Resources already exist to support the efforts of this working group. To be successful, the working group must reach out to publishers, retailers, accessibility specialists, international standards organizations, and others to gather a wide perspective. In some cases, participants may not be currently involved with BISG, so finding the right volunteer in each organization may take time. Further, while ebooks are clearly identified as a service and not a product, there is still some pushback within the industry on the distinction. Additionally, there is confusion on how to approach backlist titles.