The European Accessibility Act Is in Force. Is Your Backlist Ready?

The European Accessibility Act came into effect on June 28, 2025. It is not approaching. It is here.

For publishers with titles on sale in EU markets, that date marks the point at which accessibility compliance for digital content became a legal obligation rather than a recommended practice. And while the conversation in publishing has focused heavily on frontlist titles and new production workflows, the more urgent and commercially complex challenge sits in an entirely different place: the backlist.

What the EAA Actually Requires

The EAA establishes that products and services sold in the European Union, including eBooks, must meet standardised accessibility criteria. For publishers, this translates to WCAG 2.1 Level AA conformance as the core technical standard, with the EPUB Accessibility 1.0 specification applying specifically to eBook files.

The scope is broader than many publishers initially assumed. The EAA applies regardless of where the publisher is based. A publisher headquartered in the United States, India, or Australia selling titles into EU retail platforms is within scope. Geography of incorporation does not determine applicability. Geography of sale does.

The supply chain obligation is equally important. Distributors and retailers, including Amazon KDP, Apple Books, and Kobo, are responsible for ensuring that the products they sell comply. In practice, this means major EU retailers have been tightening their automated quality checks, with Amazon quietly flagging non-compliant EPUBs since late 2024. A publisher whose titles fail these checks risks suppression or removal from EU storefronts, with no formal warning process.

There is a micro-enterprise exemption: organisations with fewer than 10 employees and under two million euros in annual turnover are not required to comply where doing so would constitute a disproportionate burden. For most commercial publishers, this exemption does not apply.

The Backlist Question

The most contested area of EAA interpretation is the backlist.

Any eBooks sold in the EU, including backlist titles, after June 2025 must comply with EAA standards. Publishers unable to make older titles compliant may need to temporarily or permanently remove them from EU sale to avoid penalties.

Several member states, including France and Italy, have provided a transition period until 2030 for backlist titles already on the market in 2025. But publishers should not treat this as a blanket EU-wide grace period. It applies only where national legislation has specifically provided for it, and only covers content already on the market before June 2025.

The practical risk is immediate. Remediating older eBooks can generate significant costs due to the complexity of different content categories and the difficulty of converting titles created before accessibility standards were built into production workflows.

The publishers who will be in the strongest position are those treating the ambiguity not as permission to wait, but as time to act systematically.

A Practical Backlist Strategy

The scale of most backlists makes a simultaneous, all-titles approach neither practical nor necessary. What is needed is a structured, risk-ranked programme.

• Audit before remediating. Run every EPUB in your backlist through an automated accessibility checker such as DAISY Ace. Automated tools will catch a meaningful proportion of issues and give you a clear picture of where your titles stand before any remediation work begins. Do not assume titles produced to earlier standards are compliant. Most will not be.

• Prioritise by commercial exposure. Not all backlist titles carry equal EU market risk. Titles actively selling into major EU retail platforms, titles with institutional library distribution in Germany, France, the Netherlands, or the Nordics, and titles in high-demand academic subjects should be at the front of the remediation queue. These represent both the greatest compliance risk and the greatest commercial consequence if they are flagged or removed.

• Separate frontlist from backlist workflows immediately. Publishers should immediately start producing all new titles as "born accessible". Every title added to your catalogue from this point forward should be produced as a reflowable, accessible EPUB3 that meets WCAG 2.1 AA from the point of creation. This prevents the backlist problem from compounding further and is the single highest-impact workflow change any publisher can make right now.

• Document your programme. Even where full compliance on the backlist is not yet achieved, a documented, credible remediation plan with clear timelines and priority logic provides meaningful protection in the event of a compliance inquiry. Regulators across EU member states have been clear that the enforcement approach will evolve, and demonstrable good-faith effort carries weight.

The Commercial Upside

The risk framing is necessary, but it is not the whole picture.

An estimated 87 million people in the EU have some form of disability. Accessible eBooks serve this audience directly, and accessible metadata improves discoverability across library platforms,

institutional aggregators, and AI-powered discovery engines. The commercial case for accessibility runs alongside the compliance case, not separately from it.

Where S4Carlisle Fits

S4Carlisle is a Benetech Global Certified Accessible (GCA) vendor. Our accessibility services cover frontlist born-accessible EPUB3 production, backlist remediation at scale, and VPAT/ACR documentation. We combine AI-assisted automated triage with specialist human review across standard and complex content types.

The EAA is in force. The question for every publisher with EU distribution is not whether to act. It is how quickly a systematic programme can be built.