What are the risks of publishing ebooks that are not accessible in the European Union?

06/2025

From June 28, 2025, the European Accessibility Directive will come into effect for publishers wishing to publish ebooks within the European Union, regardless of whether they are established in the EU or not. Does this apply to you? What are the accessibility requirements? And what are the risks in the event of an inspection?

What are the risks of publishing ebooks that are not accessible in the European Union?

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Who is required to make ebooks accessible?

Digital technology creates new opportunities for people with disabilities, and the book industry has a key role to play in ensuring content is accessible to all. This is the goal of the European Directive on accessible ebooks.

As the first link in the chain, publishers are directly impacted by this legislation. However, other stakeholders must also be involved:

  • Distributors and booksellers must ensure that readers are informed about available accessibility features and can determine whether a book meets their needs.
  • Software developers must provide reading solutions that support all accessibility features.

Initially, only new releases will be affected. Digital books published before June 28, 2025, will not be subject to this legal requirement until June 28, 2030.

What are the accessibility requirements for publishers?

All digital books published within the European Union must meet specific accessibility criteria, regardless of where you are based. These include:

  1. Including alternative descriptions for images that are useful for understanding the content;
  2. Using file formats that allows readers to customize the layout according to the their needs (font size, contrast, and so on), and that are compatible with assistive technologies, such as text-to-speech;
  3. Using anti-piracy measures for your files (DRM) that do not block or hamper accessibility features;
  4. Providing accessibility information in the metadata for each of your ebooks, so they can be more easily discovered by readers.

3 examples of exemptions from accessibility requirements

Does this apply to all publishers wishing to publish ebooks within the European Union? You may be eligible for an exemption from accessibility requirements under the following conditions:

Size of Your Publishing House

If your publishing house has fewer than 10 employees and an annual turnover or balance sheet total not exceeding 2 million euros, you may qualify for an exemption.

Fundamental Change to Content

An exemption may be granted if making a book accessible would require altering its content in a way that compromises its integrity. This applies to cases where content and form are inseparable, such as comic books.

Disproportionate Burden, assessed according to three factors:

  1. Proportion of Accessibility Costs: The share of total production costs represented by accessibility expenses, including ongoing costs (accessible production) and one-time costs (such as hiring, training, or implementing accessibility tools).
  2. Economic Potential of the Work: Factors such as genre, sales performance (both volume and value), and media exposure of the digital book.
  3. Financial Resources of the Publisher: A comparison of net compliance costs with the publisher's net revenue to determine the financial impact.

Exemptions based on fundamental content changes or disproportionate burden must be formally declared and justified in accordance with a procedure that, for the time being, is likely to be country-specific.

In the meantime, the next section will provide an analysis and updates on the practical application of the European Directive on accessible digital books, broken down by country.

How The Law Is Applied Across Europe

Although the legislative framework on the ebook accessibility applies throughout the European Union, the terms of its application can vary from country to country.

National enforcement bodies are gradually clarifying their enforcement procedures and potential risks. We’ve compiled key information from each of them into a summary table to give you a clear picture of how the law is being applied in each EU Member State.

You can also read our detailed article on how the Directive is being implemented in France.


Country
Supervisory Authority
Control process
Sanctions for non-compliance
Exemptions
Links and Notes
BELGIUM Belgian Web Accessibility (for the public sector)
  • Fundamental changes to content.

  • Disproportionate burden.

  • Size of the publishing house.


DENMARK Danish Safety Technology Authority
  • Routine inspections.

  • Inspections triggered by a complaint.
  • Fundamental changes to content.

  • Disproportionate burden.

  • Size of the publishing house.

FRANCE ARCOM
  • Routine inspections.

  • Inspections triggered by a complaint.
  • Fine of up to €7,500 per ebook.
  • Fundamental changes to content.

  • Disproportionate burden.

  • Size of the publishing house.

GERMANY Each German region must designate a competent authority. To date, only one region has done so (Hesse).
  • Ebooks may be removed from the market.
  • Fines ranging between €10,000 and €100,000 depending on the severity of the violation.
  • Fundamental changes to content.

  • Disproportionate burden.

  • Size of the publishing house.

Link to current legislation.
IRELAND

  • Fundamental changes to content.

  • Disproportionate burden.

  • Size of the publishing house.

Link to current legislation.
ITALY
  • Fundamental changes to content.

  • Disproportionate burden.

  • Size of the publishing house.


PORTUGAL
  • Fine between €12,000 and €44,891.81.
  • Fundamental changes to content.

  • Disproportionate burden.

  • Size of the publishing house.

Link to current legislation.
SPAIN
Each of the 18 autonomous communities and the autonomous cities of Ceuta and Melilla must appoint a supervisory authority. The national authority has not yet been designated, but it will probably be the General Directorate for Disabilities (Dirección General de Discapacidad), which operates under the Ministry of Social and Consumer Rights.

  • Fundamental changes to content.

  • Disproportionate burden.

  • Size of the publishing house.


SWEDEN Swedish Agency for Accessible Media (MTM)
  • Routine inspections.

  • Inspections triggered by a complaint.
  • Fine between 10,000 and 10,000,000 Swedish crowns (approximately €915,000 and €915,000).
  • Fundamental changes to content.

  • Disproportionate burden.

  • Size of the publishing house.

Due to a legal dispute, the accessibility law will not apply to ebooks until January 1, 2027. However, all reading-related software must comply with accessibility standards starting June 28, 2025.