Publishing@W3C: September 2021 Seminar

Hi everybody, I am Cristina Mussinelli, I'm the Secretary General of the LIA Foundation, and the co-chair of the Publishing Business Group in W3C.

I've been requested to provide you a brief overview of the European Accessibility Act that is an European directive on accessibility of product and service.

The directive has been approved in 2019, every member state should implement it in its national legislation by June, 2022.

And then the directive will enter in force by June, 2025.

The goal of the directive is to create an accessible ecosystem, removing all the obstacles that are now existing due the different and divergent requirements in the different member states.

The directive will apply not only to European organizations, but all organizations willing to sell product and service in Europe.

This means that also the international organizations in our field like Amazon, Kobo, or every international publisher, willing to sell in Europe should comply with the requirement of the legislation.

The directive is quite wide and includes a lot of product and services.

That means, for example, the ticketing services, bank, ATM machine, software, and operating system for smartphone, tablet, and different devices.

But what is really relevant for us, is that include eBooks, eCommerce, and reading solution, either devices and software reading solution.

The directive both for product and service foresee three main elements.

The compliance with defined accessibility requirements, the possibility of conformance, and the possibility to have authorities for the enforcement and the penalty who will control the implementation of the legislation.

In particular, slide four.

The compliance will be on the compliance for the requirements, the compliance for the product with the requirements of Europe in particular, they should have the CE mark that demonstrates that they are fully accessible.

Then in the directive there already are some high-level requirements for example, for the accessibility of product and service, there are examples of what accessible means.

And there are also some information about the conformity of products and the assessment of what is called Disproportionate Burden.

That is a possibility to demonstrate that, to be compliant with the directive will be too complex or too costly.

But these should be demonstrated in relationship with the advantage of the final end user and should be approved by the Commission.

There are information that are related with the standard, and in slide five, and there are different standards that are included in the directive related with the publishing industry.

There are five formats.

So the kind of file format that is used to produce eBooks, the website, and the platform format, there is the hardware and software in each solution standard.

And there is also the metadata standard because the directive requires that every product and service they've described in a detailed way, which has the accessibility features.

In this field we have done a specific work in W3C, and also with other organizations to demonstrate that there already exist standards available in the publishing sector, in particular EPUB for the format, ONIX and Schema.org for the metadata, are compliant with the directive.

If you want more detail on what has been done, you can look at the presentation of Avneesh Singh.

And he explained what we have done in W3C.

In slide six, eBooks are considered as a service.

This means that all the actors in the value chain should comply with the requirement, not only publishers who need to produce digital books, but also distributors, retailers, aggregators, eCommerce websites, and also the mobile versions of all these organizations.

Software and reading solutions, DRM solutions, DRM should not impede the possibility to disabled user, to access content and metadata, as I explained before, should be not only produced by the publisher, but should be displayed to the end user in the retailer website.

This is a brief description that we have created in the LIA Foundation to highlight the role of the actor and to describe which are the main activities that every actor should do.

There are enforcement and penalties.

and enforcement and penalties will be defined at national levels, so right now I cannot provide you more information on that, but I'm quite sure that by 2022, when the legislation will be implemented in every nation or country, we'll have more information.

Slide nine, there are some exemption.

So it will be possible for micro-enterprises not to be compliant with the legislation for micro-enterprises in Europe these are considered organizations with less than 10 employees or with a turnover lower than 2 millions euros.

There is another option that is the Disproportionate Burden.

That means that as I explained before, if it's too costly or too complicated to produce an accessible product or service, you should demonstrate to the Commission why and which are the reasons and advantage in comparison with the benefit to disabled people.

There is another possibility, that is the fundamental alteration of the product and the service, I don't think this will apply in a precise way to the publishing industry, because there is no alteration in producing accessible content or websites for the publishing industry.

There are some kind of books that the directive considers more complicated at the state of the art of the standard and the technology that can be less accessible than others.

They should be accessible at the state of the art.

And these kind of books are comics books, illustrated books for children, and art book.

For illustrated books, I should say that they are considered only books where the instruction is prevailing.

Why, if you have a book for children that is most mostly text and some images, I think that should not be considered as an exemption because you can at the state of the art of the technology make them accessible.

Last, but I think a relevant information slide 10 is that there are illegitimate reasons.

So some reason that you should not consider as possible exemptions, and they are lack of time, lack of priority, and lack of knowledge.

So I really suggest you that you start considering accessibility and start the move now because accessibility is a journey.

If you don't start, you will never arrive.

Thank you very much, and bye.