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A person reading an e-book. Photo.

European Accessibility Act: implementation regarding e-books

Together with the Danish consultancy KANT, we have carried out an assignment for the Danish Library for people with print disabilities; NOTA. The task included mapping and analysis of the current status of the implementation of the European Accessibility Act (EAA) and to provide inspiration for implementation options that can be transferred to a Danish context.

The assignment included desk research, an online survey and interviews. We considered the EAA provisions on the definition of the e-book and dedicated software, the general accessibility requirements for services (Annex I Section III) and the additional accessibility requirements related specifically to e-books (Annex I Section IV).

We also checked whether the provisions deviate from the EAA in a way that is, or can be, relevant. We carried out a limited conformity check, concentrating on directly visible differences, considering also that the machine translation used has limited reliability when the analyst does not master the original language of the legislation.

Strategies for transposition

Some Member States adopt an act that follows the directive very closely, both by structure and content. Other Member States may transpose a directive in two measures: an Act on the obligations and a decree type measure on the technical details (e.g., technical requirements, supervision).
In Member States aiming to integrate the new provisions into the existing legislation, this of course depends on the content and structure of the existing legislation. For the transposition of the EAA it may mean amending the consumer protection law to cover the market surveillance aspect, the electronic communication or the audiovisual act to accommodate the requirements related to electronic communication or audiovisual media products and services, and the public procurement act if the legislator decided to set requirements in that area as well. This can result in the notification of a significant number of measures. Some Member States notified a great number of laws (often over 15, and even up to more than 30).

Of the Member States that notified transposing measures to the European Commission, the following result was noted. As there are ongoing infringement processes with all Member States, we have decided not to list the names.

  • Two followed the EAA very closely, but with notable deviation from its e-book related content.
  • Two have small, seemingly technical deviations, e.g., the definition of the e-book and the dedicated software are separated.
  • One use a different definition for e-books.
  • Two seemingly fail to mention and thus, cover dedicated software.
  • One seemingly fail to transpose part of the generic accessibility requirements for services.
  • Two have additional requirements (in one case regarding the findability of the accessibility information, in another case requiring self assessment before issuing an e-book on the market).
  • One extend the scope to additional services.
  • Three transposed only the general obligations with the scope of the EAA, and detailed technical measures might follow.
  • A handfull hadn’t transposed e-book related provisions, or have not, actively transposed the EAA in their notified laws, or have not yet notified any measures.

All in all – considering also the above overview – we couldn’t identify crucial differences among the existing provisions among Member States that have substantially transposed the EAA. It is highly probable that the adoption of the missing technical decrees, addressing the technical requirements in Annex I will not create big differences either.

The approaches to transposition show many similarities to that of the Web Accessibility Directive between 2018-2020, and we expect that the missing measures will be addressed and remediated well in time before the 25 of June 2025.

About Nota

Nota is the Danish Library and Expertise Center for people with print disabilities.

Nota’s collection of accessible digital books holds more than 50.000 audio books, e-books and Braille books. Nota offers fiction and non-fiction, study books and school books.

Nota produces, buys and sells audio books, e-books and Braille books, but also develops synthetic speech and offers to produce audio books, magazines and newspapers for external partners.