EAA Compliance Checklist for Self-Published Authors
A practical, five-point checklist for indie authors selling ebooks into the EU — what the European Accessibility Act actually asks of your file, and how to check it before you publish.
By Magnus | Published 2026-10-29 | Category: Accessibility
The European Accessibility Act has applied to ebooks sold to EU consumers since 28 June 2025 — it's not a future deadline anymore. If you're an indie author rather than an enterprise publisher, the legal explainers aimed at "publishers" can be hard to translate into "what do I literally need to check in my file." This is that checklist: five questions, in order, that cover what actually matters for a self-published book.
1. Does the EAA Apply to You?
The European Accessibility Act began enforcement on 28 June 2025. If you sell ebooks to consumers in EU member states — directly from your own site or through a retailer like KDP, Apple Books, Kobo, or Google Play — your books are in scope. It applies to business-to-consumer sales; it doesn't currently extend to business-to-business-only products.
Small and micro-enterprises (fewer than 10 employees and annual turnover or balance sheet below €2 million) are exempt from EAA requirements for services, though not necessarily for products — and in practice, many solo authors fall well under that threshold as a business. That doesn't make this checklist irrelevant, though: major ebook retailers are independently tightening their own content ingestion requirements to reflect EAA obligations, so you may need to meet a version of these requirements to list your book at all, regardless of whether your business personally qualifies for an exemption.
This article summarises publicly discussed requirements for a general audience. It is not legal advice for your specific situation. If EAA compliance is a hard legal requirement for your business, engage qualified counsel.
2. Does Your EPUB Have a Live, Structured Text Layer?
This is the question that trips up the most visually designed books. A page that's actually a flattened image of text — common output from some conversion paths — has nothing for a screen reader to read. It looks correct to a sighted reader and is invisible to anyone using assistive technology.
Advanced Live Text has a real, live, searchable text layer and EPUB Accessibility 1.1 metadata, but its fixed-layout page geometry cannot meet WCAG 2.1 AA's text-resize and reflow requirements, so full WCAG/EAA conformance is never claimed for it, regardless of alt-text completeness. Reflowable EPUB can carry a full WCAG 2.1 AA conformance claim, but only for a specific export with a reliable text layer and complete alt text on every image, not an unconditional property of the mode. Visual Perfection produces image-based pages with no text layer — it carries no text-based accessibility claim. Which of these matters for your book depends on whether a fixed page design or a full conformance claim matters more to you.
3. Do Your Images Have Alt Text?
Every meaningful image — your cover, diagrams, illustrations, any image that carries information rather than pure decoration — needs a text description a screen reader can announce. Where you stand here depends on your source format. For a Word-sourced manuscript, MJ Convert Systems generates AI descriptions automatically for any image missing alt text during conversion — reviewing and correcting them yourself is always more accurate than trusting an automatic guess, but you're not starting from nothing. For a PDF-sourced fixed-layout export, interior-page alt text is currently a generic "Page N" placeholder; real descriptive generation for that specific pipeline is still in active development, so check interior images in a PDF-sourced export yourself rather than assuming they're covered.
Either way, if your source file already carries real alt text on its images, a correct conversion preserves it — that's the most reliable path, and it's worth adding alt text in Word's Alt Text pane or your design tool's equivalent before you convert, not after.
4. Is Your Reading Order and Heading Structure Correct?
A screen reader relies on real heading markup (an actual Heading 1 for your chapter title, not 24pt bold text that merely looks like one) and a logical reading order through the page. In a visually designed book — a sidebar, a pull quote, a multi-column layout — the order a sighted reader's eye takes isn't necessarily the order the underlying content is structured in, and that gap is exactly what breaks for a screen reader user.
This is also, not coincidentally, one of the most common causes of KDP rejecting a designed ebook in the first place — the automated audit that flags structural issues before conversion checks for exactly this.
5. Have You Published an Accessibility Statement?
The EAA's expectation isn't that every book claims perfect conformance — it's that publishers disclose their real position rather than staying silent or overclaiming. A per-project Accessibility Statement that honestly states which mode your book was exported in and what that mode does and doesn't claim is the practical way to meet that expectation without guessing. MJ Convert Systems generates one automatically for every converted project, scoped to that specific export rather than a blanket statement about every book you've ever made.
- Meeting EAA 2026 standards for fixed-layout ebooks
- Ebook accessibility laws: EAA, ADA, AODA and more
- Why KDP keeps rejecting your eBook
- Run a free compliance check on your manuscript
- See more guides on converting PDFs and Word documents to Kindle
Frequently Asked Questions
- Does the EAA apply to a single self-published author, or only big publishers?
- It applies by what you sell and to whom, not by company size in most cases. If you sell ebooks to consumers in the EU, your books are in scope from the EAA's enforcement date of 28 June 2025. There is a micro-enterprise exemption (fewer than 10 employees and under €2 million turnover) for services, but it doesn't necessarily cover products, and major retailers are tightening their own ingestion requirements regardless of whether you personally qualify for an exemption. This is a summary, not legal advice — check your specific situation with qualified counsel.
- Do I need to redesign my book to comply with the EAA?
- Usually not. The requirements are about the EPUB's underlying structure — a real text layer, alt text, correct reading order, metadata — not the visual design. A correctly built fixed-layout or reflowable EPUB can keep your design exactly as it is while meeting the structural requirements.
- Can MJ Convert Systems make my book fully EAA/WCAG compliant automatically?
- No single click makes any book automatically conformant, and no fixed-layout mode can ever carry a full conformance claim. Advanced Live Text has a real, live, searchable text layer and EPUB Accessibility 1.1 metadata, but its fixed-layout page geometry cannot meet WCAG 2.1 AA's text-resize and reflow requirements, so full WCAG/EAA conformance is never claimed for it, regardless of alt-text completeness. Reflowable EPUB can carry a full WCAG 2.1 AA conformance claim, but only for a specific export with a reliable text layer and complete alt text on every image, not an unconditional property of the mode. For a Word-sourced manuscript, AI alt-text descriptions are generated automatically for images missing it, but reviewing them yourself is more accurate than trusting an automatic guess. For a PDF-sourced fixed-layout export, interior-page alt text is currently a generic "Page N" placeholder — real descriptive generation for that pipeline is still in active development.
- What does MJ Convert Systems actually check for free?
- Upload your PDF or Word manuscript and run the automated audit — free, no account required. It flags structural and image issues before conversion. Each project also has a downloadable Accessibility Statement once converted, disclosing the real, per-mode accessibility position of that specific export rather than a blanket claim.
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