Sector guide · Publishing
BFSG for e-books and reading apps
The law names e-books, the software that reads them and the shops that sell them — three different products with three different sets of obligations, usually owned by three different teams.
- File, reader and shop are all in scope
- EPUB Accessibility 1.1 is the working standard
- Metadata is a requirement, not a nicety
Three products, not one
- The e-book file itself: structure, reading order, alternative text, navigation
- The reading software or app: everything a normal application has to do, plus not breaking the file’s own accessibility
- The shop that sells it, which is an e-commerce service in its own right
- The accessibility metadata that tells a reader, before buying, whether the book will work for them
- Fixed-layout titles, which are where the honest answer is usually "this one is not accessible"
Sector guide · Publishing
Where publishing fails
-
Fixed-layout EPUBs
A cookbook or a textbook exported as fixed layout has no reflow and often no real text. The fix is a production decision, not a post-processing step.
-
Images carrying the content
Diagrams, tables and equations shipped as pictures with no alternative — in a textbook, that is the content itself.
-
No accessibility metadata
Without the `schema:accessibilityFeature` fields, a reader cannot tell before buying whether the book is usable. The shop cannot display what the file does not declare.
-
DRM that blocks assistive tech
Protection that prevents text-to-speech turns an accessible file into an inaccessible product.
Criteria that carry over to the shop and the reader
The file follows EPUB Accessibility; the shop and the reading app follow the same WCAG criteria as anything else. Each links to a plain-language page on that criterion: what it asks for, how it fails in practice, and how far an automated check can get.
Where to start
-
Fix production, not the backlist
Every title you make accessible in the workflow is one you never remediate. Start with the templates your typesetter uses.
-
Declare what is true
Fill in the accessibility metadata, including where a title falls short. A customer who knows before buying is not a complaint.
-
Check the shop separately
The shop is an e-commerce service under the same law, with its own checkout, its own search and its own failures.
-
Test with a real reading app
A file that validates can still be unusable. The reading experience is the product.
Questions publishers ask
Do we have to remediate our whole backlist?
The obligation attaches to what you place on the market after the deadline. That makes production workflow the priority: a title fixed at source stays fixed, and the backlist can be prioritised by what actually sells. Where a title genuinely cannot be made accessible, the disproportionate-burden route exists — but it has to be documented and reassessed, not assumed.
Can an automated tool check an EPUB?
Partly. Validators like Ace by DAISY check structure, metadata and the mechanical requirements. Whether an image description conveys what the figure means, or whether the reading order matches the argument, is a judgement — the same split as on the web.
Written to be useful, not to be legal advice. It reflects our reading of the BFSG and EN 301 549 as of 2026-09-13; for a binding assessment of your obligations, ask a lawyer.
See what this finds on your site
Send a URL. We scan up to 100 pages, run the agent protocol on one key journey and send you the report — free, once, no strings.