EAA 2026: What Publishers Must Do About PDFs

The European Accessibility Act (EAA) took effect on June 28, 2025. If your organisation publishes ebooks, reports, or digital documents sold in EU markets and you are still distributing PDFs, you are likely out of compliance.

The EAA applies to any company — regardless of country — that sells digital publications to EU customers. Member states are empowered to enforce it with fines and sales bans.

What the EAA requires

The EAA incorporates WCAG 2.2 Level AA. For digital publications, this means:

1. Reflowable text — content must adapt to font size and screen without losing meaning
2. Reading order — logical sequence must be programmatically determinable
3. Navigation — navigable table of contents, headings, and page landmarks required
4. Language — primary document language declared in metadata
5. Images — non-decorative images need alt text
6. Tables — accessible headers must be marked up

Why PDFs fail

PDF is a print format. It encodes text at fixed coordinates on fixed-size pages. This creates unavoidable failures: no true reflow, scrambled reading order in multi-column layouts, missing navigation landmarks. The EU's own guidance explicitly identifies EPUB3 as the reference format for accessible digital publications.

What publishers need to do

Option 1 — Convert existing PDFs to EPUB3: toolkit.bot converts in ~30 seconds with built-in verification. Output includes semantic HTML structure, a navigation document, correct reading order, and language metadata. After conversion, validate with the free ACE by DAISY checker.

Option 2 — Export to EPUB3 from source: For new titles, export to EPUB3 directly from InDesign, Word, or LaTeX. PDF should be secondary for print.

Option 3 — Professional remediation: For complex documents (illustrated books, academic journals). Costs £5–£50+ per document.

Scope and penalties

Practical checklist

• Audit current catalogue — which titles are PDF-only?
• Convert PDF-only titles to EPUB3
• Validate with ACE by DAISY (target: 0 critical errors)
• Test with a screen reader (NVDA + Firefox, or VoiceOver on iOS)
• Update product metadata to declare accessibility conformance
• For new publications: export EPUB3 first, PDF second