Content Considerations and the European Accessibility Act
Date postedMay 14, 2024
This has been a busy year for all of us in publishing and digital conversion, with the rapidly approaching June 28, 2025 deadline for complying with the European Accessibility Act. The Act itself is an overarching piece of EU law, which will be implemented within EU nations under individual national laws enforcing the Act. While there is broad guidance (including prioritizing ebooks as requiring compliance) issued by the EU, we have yet to see how all individual countries will codify the Act’s requirements. To further complicate matters, there’s a general lack of consensus in the publications industry about whether ePubs—to wit, accessible ePubs—are a product or a service, which could impact how rapidly front and backlist content needs to be made compliant (by the 2025 launch date for the Act, or a potential 2030 window for other services). Some industry figures are suggesting that ePubs—including those in the backlist—may be allowed to drift into the 2030 window without being converted into a fully accessible file, while other opinions seem to be suggesting the 2025 deadline only applies to frontlist titles, while still others have voiced the opinion that all content needs to be compliant by June 28, 2025.
To be candid, I am not an attorney, and as an executive of a vendor that converts and makes ePub files compliant with GCA, WCAG, and DAISY guidelines, it would be easy to suggest that I have a vested interest in encouraging publishers to rapidly convert all of their list, all at once, at great expense.
All of that being said—no matter which of the above interpretations of the EAA you feel most comfortable with—there are a number of measures I would encourage you to take that will not cost a dime on conversion services, and can help open up meaningful, internal dialogue to address your content in advance of the EAA coming into effect.
- Speak with your attorney. To an extent, the above is philosophical at this point as without EU nations having enacted the Act or drafting their own policies you will likely need to keep monitoring and reviewing this with your counsel. But in the interim, you should open up some dialogue with your attorney or a legal professional about this pending impact on your business and ask them for guidance as to how to proceed in the absence of final legislation or the outcomes of any court cases that may be filed after the Act and any supporting national laws go into effect.
- Ask your Production managers to run some of your existing ePub files—both recent frontlist books as well as some deep backlist—through the ACE Checker from DAISY. ACE scores your ePub files for a number of factors, including the presence and length of alt text, tagging structure, and more. This will give you a baseline to show whether your current production practices are compliant, as well as how much work your backlist titles may need.
- Discuss how Alt Text is or can be created as part of your editorial process. While vendors can write alt text entries as part of ePub conversion or remediation, there’s a good argument to be made that—acquisitions allowing—it may make sense to ask authors to provide Alt Text entries for their images when supplying art. For some publishers adding any further tasks to an author’s plate is a bridge too far, so that task is falling to copyeditors or editorial staff. Regardless, like any change, map it out in your workflow. Who has the skills, what’s the hard or soft cost, and how best can you routinize this so that it’s not a question mark on each title when it gets to the final phases of production?
- A lot of these steps start to have an impact on metadata. If you have Alt Text in a title, if you’re classifying an ePub as ‘accessible’, these are things that you’ll want to add to your metadata for transparency, and frankly for discovery, too. While you’re cracking things open to see what metadata you can and should add to support people using adaptive technology, give some thought to how this metadata can be used in your marketing stream to emphasize that a book has an accessible edition available. This report from eBOUND Canada provides a thorough review of best practices for handling accessibility metadata.
- Don’t go it alone. A number of BISG member organizations have been very openly discussing these challenges on LinkedIn and at committee meetings, so you do not have to figure this all out on your own. Reach out to your network to see what they’re doing, engage with peer presses and members of the BISG Workflow Committee, explore becoming a DAISY member, participate in the Benetech GCA-certified program, or contact consultants like Bill Kasdorf, Laura Brady, and other trusted resources in the industry, such as Fondazione LIA.
While Westchester has released some further guidance on how we’re advising our clients to navigate the EAA, we realize that we are but one of many voices in the industry providing ideas and suggestions. I look forward to learning from all of you as to how you’re addressing things and your interpretation on the above, hopefully through upcoming BISG Workflow Committee or Metadata Committee meetings.