We tried to make our eBooks accessible
In August 2023, thus just under two years ago, we wrote an article on this blog about accessible eBooks. Now, with the Decree coming into force on 28 June 2025, we can tell you about our experience in publishing them.
A step back: EEA and WCAG 2.0 Level AA
The former stands for the European Accessibility Act, issued by the European Union on 17 April 2019. It is a Decree that dictates the accessibility requirements for digital and audiovisual products and services in the European market, including eBooks. The second refers to the Web Content Accessibility Guidelines. The WCA Guidelines were developed by the W3C (World Wide Web Consortium), the international body responsible for setting web standards with regard to the principles of accessibility, internalisation, privacy and security. There are three levels of compliance, identifiable by the A number: the one required by most standards, including the EEA, is the second.
How it works outside the EU
We do not know exactly what warnings Amazon’s KDP covers, as they have long since been banned for publishing explicit content, but there are Accessibility Guidelines in the Help Centre.
As far as Kobo is concerned, for now there are no obligations or ticks.
Not so for Lulu, which requires one to fill out an “Accessibility Declaration” in which one self-declares the conformity/non-conformity of one’s eBooks with the WCAG 2.0 Level AA standard. The latter, even though it only applies to eBooks sold in the European Union, is necessary for the completion of the publication. Lulu undertakes to seal each compliant/non-compliant eBook with a special sticker. If the above declaration is falsified, it immediately suspends distribution.
How it works in Italy
A preliminary remark must be made here. All eBooks published before the deadline of 28 June 2025 can be distributed until 2030 without modification. Despite this, our team has rolled up its sleeves and decided to republish over 120 eBooks (online from 2014 to the present) to make them accessible. In the meantime, extensive revisions were also made to them, which we will discuss in the next article.
We therefore purchased the monthly subscription of StreetLib Write that allows you to ‘create your own accessible eBook from scratch’.
How it works is simple. A clickable icon appears inside each text section of the book to check for any accessibility errors. Alternatively, at the top of the screen, a complete analysis of the entire eBook can be started. Any errors are marked on the side and can be easily corrected within the text itself or in the spaces provided by StreetLib. Switching to different sections of the book (e.g. from “book tab” to “contents”) invalidates the accessibility process and in order to export the “correct” eBook, the analysis must be performed once more.
As far as our products are concerned, only one type of error was detected, namely the absence of meta-tags (a kind of alternative description) for images. This problem, although very easy to solve, is handled in a rather basic way: in the metadata space you can write anything, even “pincopallo”. The correctness of the alternative description to an image therefore relies very much on the intellectual honesty of the person filling in the fields.
The first problem: languages
Once the ePub has been exported, it must be uploaded back into the publishing hub. Here we will find a section, marked with the same icon as Write, in red or green, depending on the analysis carried out by the system during publication. It goes without saying that if the one performed in Write was positive for accessibility, it will also be positive during this last phase.
But no. As far as eBooks in Italian and English were concerned, everything went smoothly. But when we tried to load Spanish, French and Chinese ePubs, the accessibility analysis always returned a specific error: the lack of the ‘metadata-accessibilitysummary’. In other words, even if the Spanish, French and Chinese books are perfectly accessible inside Write, when exporting, the system does not create the accessibility summary within the document. Specifically, the ‘schema:accessibilitySummary’ is used to inform users which accessibility features are available.
This is a relatively easy error to correct, so we immediately took steps to contact StreetLib’s technical team. The problem was that, in a month, not only was the error never resolved, but the only response we received (even after numerous reminders) was that the ticket was still being processed. Eventually, in order to remedy the error ourselves, we re-uploaded all the language files by initialling them as eBooks in English and manually translating all the relevant parts into French, Spanish and Chinese.
The doubt that has arisen for us is that StreetLib does not really provide a universal system for creating accessible eBooks, but has only activated the option for English and Italian ePubs (probably their biggest market). Considering that the subscription costs almost €9 per month, this is no small disservice.
The second problem: comics
Once all the stories had been republished, we moved on to the comics. And here a completely different chapter opened up. In fact, eBooks in Fixed Layout (which contain “pages” that are pasted in rows without the possibility of editing, more or less like PDFs) do not include an accessibility check. In these types of eBooks, often comics, the images (which are to all intents and purposes pages) cannot have an alternative description. This is the reason why, to date, ePub Fixed Layouts are excluded from the obligation to comply with accessibility standards.
The problem is that it is very easy, with free online tools, to turn an ePub into a PDF and then upload it to Write as a Fixed Layout. We did this too, as far as publications that include the comic and the story together are concerned. It was a well-considered choice, which does not detract from the pleasantness of the textual reading, but greatly enhances the quality of the images of the drawn panels. eBooks containing only a limited number of images, on the other hand, were left in Reflowable format.
What if, to get around the system, we used this method for all our publications? A very convenient shortcut for those who want to do ‘Accessibility washing’, without lifting a finger towards more inclusive reading.
The third problem: publication
Once we had finished reviewing and exporting each comic, we returned to the publishing hub. A few days earlier, we had written to StreetLib’s support and received confirmation that eBooks of this type were published without the accessibility check (already not present on Write).
To our surprise, however, the old publication forms not only had the appropriate section, but marked everything in red (understandably). At that point, we wrote back to support, who advised us to disable the previous publications and create them from scratch, with new ISBNs. In addition to the immense amount of work, therefore, we also found ourselves in the position of having to wipe out years of our comics’ placements in the stores with a flick of the wrist. Not to mention the fact that the number of ISBNs available on StreetLib is limited…
Here the last problem arose, namely that the system does not always recognise Fixed Layouts as such. It’s a bit of a conundrum. Even when opening a new publication tab, the accessibility function is sometimes activated when loading content. In that case, you must also disable the new tab and create a new one.
After this, the system automatically recognises the new publication as a clone. And we wonder why: if the ISBN is new, even if the book has the same details, how do they check that the edition is not different? We therefore have to write to support again and politely ask them to unblock the eBooks by hand. Hopefully, as happened to us, the customer care person is not on holiday for a fortnight…
Conclusion: is it worth it?
For our part, we are very happy to have implemented the possibility of more inclusive reading and we hope that in the future our comics will also be accessible to all and sundry. But the strong feeling we have had in these months of labour is that not everyone would be interested in such a “journey”. Ways around the system are “accessible” (pardon the pun) to everyone. Not least, even those who provide the accessibility tools do not really seem interested in solving the problems that may arise. As if it were just a bland marketing operation.
We will just have to wait and see what the future of digital publishing holds in store for us: but we leave this experiment with the bitter taste of disappointment in our mouths.