Is Your STEM Backlist EAA-Compliant? A Publisher’s 2026 Remediation Checklist
The European Accessibility Act (EAA) has been in force since 28 June 2025. Frontlist workflows adapted quickly. The backlist is where the real exposure now sits — thousands of older titles, still on sale in the EU, built long before accessibility was a legal requirement.
Here is the short version, for anyone who needs an answer before the meeting: any e-book you sell into the EU after 28 June 2025 — backlist included — must meet EPUB Accessibility 1.1 and WCAG 2.1 Level AA, or you must stop selling it there. For STEM publishers there’s a second, harder truth: the backlist is also the most expensive tier to fix, because the maths, tables and figures that automation handles worst are exactly what your catalogue is full of.
This is a practical checklist to work through in order — whether the rules apply to you, what a compliant title actually needs, and how to triage a backlog so your budget lands where it matters.
Step 1 — Confirm whether the EAA applies to you
Before spending a rupee or a euro, establish your real obligation. Work through these:
- Do you sell e-books to EU consumers? If yes, the EAA applies no matter where you’re based. A US, UK or Indian publisher selling into the EU is fully in scope, and non-EU operators are expected to appoint an EU-based authorised representative.
- Are you a microenterprise? The one clear exemption is for microenterprises — fewer than 10 employees and under €2 million annual turnover — and even then it is written for services, not products. Most commercial publishers do not qualify.
- Can you claim disproportionate burden? Article 14 lets an operator argue that compliance is disproportionately costly relative to the benefit — but it is not a blanket escape hatch. You must document the assessment against the EAA’s Annex VI criteria, keep it available for regulators, and reassess it periodically. Invoking it incorrectly can itself trigger a penalty. And note what does not count: lack of time, lack of priority and lack of knowledge are explicitly not legitimate reasons.
- Does a transition period buy you time? Some member states — France and Italy among them — allow a transition until 2030 for backlist titles already on the market in 2025. Treat this cautiously: it is not an EU-wide grace period, it applies only where national law provides it, and only to content already on sale before June 2025.
The penalties are real, not theoretical. In France, the regulator ARCOM can fine €7,500 per breach — for selling a non-accessible e-book, for failing to describe a title’s accessibility, or for not correcting problems once flagged — and can make the names of those fined public.
Step 2 — Know what a compliant STEM title actually needs
“Accessible” is specific, not a vibe. For an EPUB to meet EPUB Accessibility 1.1 and WCAG 2.1 AA, confirm each title has:
- Real text, not page images. Scanned-image EPUBs fail on the first check.
- Equations as MathML, not pictures. This is the STEM dealbreaker: an equation saved as an image cannot be read or navigated by assistive technology.
- Meaningful alt text for every informative figure, with decorative images correctly marked as decorative.
- Correct reading order and heading structure, so navigation follows the logic of the content.
- Properly structured tables with header associations — not tables used for visual layout.
- Working navigation: a real table of contents, and a page list where print page numbers matter.
- Declared language, including inline language changes.
- Accessibility metadata (the Schema.org accessibility fields) so retailers and readers can see a title’s accessibility features before they buy.
- An accessibility conformance report, produced with a tool such as ACE by DAISY, plus a published accessibility statement.
Accessibility metadata deserves special attention here. Retailers and the major reading platforms increasingly surface these fields (including through ONIX feeds), so a title with complete, honest accessibility metadata is easier to sell as well as to defend — while a compliant file with empty metadata still looks inaccessible to a shopper filtering for it.
Miss any one of these and the title is not compliant. For STEM backlist, the equations and tables are almost always where it breaks.
Step 3 — Triage your backlist by cost, not alphabetically
You cannot remediate everything at once, and you shouldn’t try. Sort the catalogue into tiers:
- Green (cheap): reflowable, text-only titles with few images. Mostly automated fixes plus metadata. Do these first — fast compliance wins at low cost.
- Amber (moderate): titles with structured images, standard tables and some figures. Manual, but predictable.
- Red (expensive): heavy-maths STEM, complex tables, chemistry, scanned figures, multi-column layouts. Real specialist effort — and your most valuable scholarly titles usually live right here.
A fast way to build these tiers at scale is to run every title through ACE by DAISY and sort by the number and type of errors it reports — image-only equations, missing alt text, table-structure failures. That error profile correlates closely with remediation cost, so it does most of the tiering for you. Pair it with your EU sales data, and the priority order almost writes itself.
Then sequence by EU revenue × ease of fix. Remediate titles that still sell into the EU and are cheap to fix first; schedule the high-revenue red titles next; and for low-revenue red titles, make a deliberate decision — remediate, withdraw from EU sale, or build a documented disproportionate-burden position. The goal is simple: spend remediation budget where compliance protects real revenue.
Step 4 — Understand why STEM backlist is the costly tier
Three things drive the cost, and naming them keeps your forecasts honest. Equations in older files were almost always saved as images, so they must be rebuilt as MathML. Complex tables were frequently coded for visual appearance rather than meaning, so their structure has to be reconstructed. And figures — graphs, schematics, chemical structures — are often low-resolution scans that need redrawing before they can carry meaningful alt text. None of this is work a bulk automated converter finishes correctly, which is exactly why it’s the tier publishers most often under-budget.
There is a strategic upside to touching these files, though. If you fix the maths in the source as MathML rather than patching the EPUB alone, the same correction flows into every future output — EPUB, HTML and PDF/UA. Approached that way, a backlist remediation isn’t only a compliance cost; it’s an investment in cheaper, born-accessible frontlist production for years afterwards.
Step 5 — Don’t lean on the things that won’t save you
A few cautions from what we see in practice. A transition period in one country does not cover your sales in another. “We’ll get to it” is not a documented disproportionate-burden assessment. And a title that merely has alt text on its equations is not compliant if that alt text is an unnavigable sentence standing in for real MathML. Compliance is judged on the actual file, not the intention behind it.
Frequently asked questions
Does the EAA apply to non-EU publishers? Yes. If you sell e-books to EU consumers you must comply regardless of where you’re based, and non-EU operators are expected to appoint an EU-based authorised representative.
Is there really an exemption for small publishers? Only for microenterprises — fewer than 10 employees and under €2 million turnover — and it is written for services, not products. Most commercial publishers do not qualify.
Do we have until 2030 for the backlist? Only in member states whose national law grants a transition period (such as France and Italy), and only for titles already on sale before June 2025. It is not an EU-wide grace period.
What proves a title is compliant? An accessibility conformance report — for example from ACE by DAISY — confirming EPUB Accessibility 1.1 / WCAG 2.1 AA, together with complete accessibility metadata and a published accessibility statement.
Are journals covered? This is less settled than books; some larger publishers understand journals are not the current enforcement focus. Treat it cautiously and take specific advice for your programme.
Where to start
If you don’t yet know how much of your backlist is red-tier, the fastest way to find out is to have your hardest title assessed and a sample remediated properly. Send us your most equation-heavy backlist EPUB and we’ll return a free sample remediation with an ACE by DAISY report — so your triage begins from evidence, not guesswork.