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Book accessibility
Summary
Copyright exception for people with disabilities
Derogating from the general principle of non-reproducibility of a work without the author's consent, the exception in favor of people with disabilities is enshrined in article L. 122-5, 7° of the French intellectual property code (French intellectual property code). The purpose of this exception is to guarantee access to works for people whose disability prevents them from browsing the work in the form in which it was originally made available to the public.
In accordance with article L.122-5 7° of the French intellectual property code, publishers must make available to establishments open to the public (libraries, archives, documentation centers, etc.) digital files of the works they publish in a format facilitating the production of documents adapted to people suffering from "one or more impairments of motor, physical, sensory, mental, cognitive or psychic functions" by authorized organizations.
Such files are made available via a secure file exchange scheme set up by the Bibliothèque nationale de France (BnF): the Plateforme de Transfert des Ouvrages Numériques (PLATON).
Once a demand has been submitted to PLATON, publishers have a maximum of 45 days to upload their digital files to PLATON.
Under article L.331-31 of the French intellectual property code, Arcom is responsible for facilitating access for people with disabilities to copyrighted works and neighboring rights.
In application of this article, Arcom can :
- be seized by approved or registered organizations of any dispute concerning the transmission of printed texts in the form of a digital file;
- collect from publishers, BnF and approved or registered organizations, all relevant documents and information concerning the reproduction, representation and transmission of adapted works, and issue formal notice to publishers to comply with their obligations to deposit digital files of the works they publish.
Report: implementation of the mission to facilitate access to books protected by copyright or neighbor rights
Browse Arcom's report on the implementation of the copyright exception for people with disabilities, published on February 8, 2024, taking stock of the implementation of this scheme and an assessment of publishers' obligations to make available digital files of works that have been the subject of a demand on the PLATON platform.
Ebook accessibility
Directive 2019/882 on accessibility requirements for products and services, dated April 17, 2019, makes provision for digital books and specialized software published with effect from June 28, 2025 to be natively accessible. Digital books published before this date must be made accessible by June 28, 2030.
This directive was transposed by a law containing various provisions for adapting to European Union law, promulgated on March 9, 2023. The decision was made to reinstate Article 48 within Law no. 2005-102 of February 11, 2005 on equal rights and opportunities, participation and citizenship for the disabled.
This text was supplemented by Decree no. 2023-778 of August 14, 2023 on the accessibility of Ebooks and the software required to use them for disabled people, and the Order of August 14, 2023 incorporating the accessibility requirements applicable to Ebooks and specialized software resulting from Directive 2019/882.
These legislative and regulatory provisions are designed to improve the daily lives of all people with disabilities, whatever the nature of their handicap.
Since June 28, 2025, all newly published Ebooks and reading software must be accessible, with the exception of those :
- published by micro-companies (companies with fewer than 10 employees and less than 2 million euros in sales or balance sheet total) ;
- whose accessibility entails a fundamental change in their nature;
- whose accessibility would entail a disproportionate burden for the publisher.
The law has given Arcom responsibility for monitoring these new obligations. As such, the Authority can :
- verify that Ebooks and reading software comply with accessibility requirements;
- follow up on complaints concerning the non-conformity of Ebooks and reading software with accessibility requirements;
- verify that the economic operator has taken the necessary corrective measures to meet accessibility requirements.
Arcom's mission covers publishers, distributors and broadcasters of Ebooks, retailers of digital books and publishers of reading software.
Frequently asked questions
As of when do I have to make the Ebooks and reading software I publish accessible?
Ebooks and reading software published as of June 28, 2025 must be natively accessible. For those published before this date, there is a transition period: you will have until June 28, 2030 to make them accessible.
What criteria must Ebooks and reading software meet to be considered accessible?
To be considered accessible, Ebooks and reading software must meet all the requirements set out in theOrder of August 14, 2023.
For example: images must be described, Ebook files must allow for personalized display of content and alternative renditions of said content (for example, through voice assistance), digital rights management measures must not block accessibility features, Ebook metadata must contain information relating to content accessibility.
I've published an Ebook or reading software that meets the majority of accessibility requirements, but some requirements are not met. Can my book or software still be considered accessible?
To be considered accessible, your Ebooks and reading software must meet all the accessibility requirements defined by theorder of August 14, 2023. If certain requirements are not met, your books and software will not be considered accessible. In this case, you will need to declare an exemption - for fundamental modification or disproportionate burden - to Arcom, in order to justify the non-compliance with certain accessibility requirements.
What are my obligations as: an Ebook publisher; an Ebook distributor/broadcaster; an Ebook retailer; a reading software publisher?
- Ebook publisher
You must design Ebook files in compliance with the requirements of theAugust 14, 2023 decree, and fill in the metadata, particularly those relating to accessibility.
- Ebook distributor / broadcaster
You must not alter the accessibility features of the Ebook files transmitted to you, nor alter the associated metadata.
- Ebook retailer
You must not alter the accessibility features of the Ebook files transmitted to you. You must also faithfully render to consumers the metadata relating to the accessibility features associated with the files.
- Publisher of reading software
You must design and supply software that supports the accessibility features of Ebooks.
What form will Arcom's accessibility checks take? What happens if Arcom considers that I have not complied with my obligations?
Arcom carries out accessibility checks on Ebooks and reading software, both upon submission of a case before the court and on its own initiative. As part of this process, it may contact the operators concerned and ask them for any documents that may be useful for the investigation.
If Arcom finds that you have failed to meet your obligations (for example, you have marketed an inaccessible Ebook, or you have not provided Arcom with the requested documents), it will enter into a dialogue with you and demand that you take the necessary corrective measures.
If you fail to respond satisfactorily within the allotted time, the Authority may refer the matter to the courts. In this case, you are liable to a 5th class offence, with a penalty notice of up to 7,500 euros.
I'm a foreign publisher. Am I affected by accessibility requirements?
If you market Ebooks or reading software in France, you must guarantee their accessibility in accordance with thedecree of August 14, 2023.
What economic data do I need to take into account to qualify for the "micro-business" exemption? Do I need to contact Arcom?
You can be exempted from accessibility obligations if, during the last financial year, the legal entity to which you are attached - identified by a SIRET number - employed fewer than 10 employees and/or achieved sales - or a balance sheet total - of less than 2 million euros.
All you need to do is meet one of these conditions to be exempt from accessibility obligations. You don't need to apply to Arcom to benefit from this exemption.
How do I declare to Arcom the Ebooks or reading software for which I claim an exemption for disproportionate burden and/or fundamental modification?
You are an Ebook publisher
You must declare each digital title for which you claim exemption for disproportionate burden or fundamental modification on an online portal developed by Arcom, according to the following schedule of declaration campaigns:
- the first campaign will take place in October 2025 for Ebooks published between June 28 and September 30, 2025;
- the second campaign will take place in January 2026 for Ebooks published between October 1 and December 31 2025;
- after these two campaigns, declaration campaigns will be held twice a year:
-in January for Ebooks published in the last half of the previous year ;
- in July for Ebooks published in the first half of the current year.
Only publishers subject to the law, i.e. those whose parent company employs at least 10 people and generates sales - or balance sheet total - equal to or greater than 2 million euros, have access to this portal. This means that if you have not been contacted in advance by Arcom, and you qualify for the "micro-business" exemption, you do not need to file a declaration under the exemptions for fundamental change or disproportionate burden.
Arcom provides model files for declaring exemptions and assessing fundamental changes or disproportionate burdens. To obtain them, please contact the Authority at accessibilite.livresnumeriques@arcom.fr.
You are a software publisher
You can declare, at any time, to the generic e-mail address accessibilite.livresnumeriques@arcom.fr the reading software for which you claim an exemption for fundamental modification and/or disproportionate burden. Arcom asks you to include the following information in your e-mail: the name of the software, the publisher, the date of publication or last update, the exemption claimed and the difficulties encountered in making the software accessible.
As a publisher, can I benefit from both exemptions at the same time for a work - disproportionate burden and fundamental modification? Can I make a single declaration for both grounds for exemption?
For the same digital work, you can combine the exemption for disproportionate burden and that for fundamental modification.
Only one declaration to Arcom is required: simply specify this in the exemption declaration file, by filling in column I of the template provided by Arcom. However, you will need to carry out two assessments: one for disproportionate burden and one for fundamental change.
What criteria must I take into account for an Ebook to benefit from the disproportionate burden exemption?
The exemption for disproportionate burden is based on the assessment of three cumulative criteria, defined by decree no. 2023-778 of August 14, 2023.
So, for your Ebook to qualify for this exemption, you need to assess :
- the cost of making it accessible, in accordance with the requirements set out in thedecree of August 14, 2023;
- its interest for the public, taking into account - for example - the quantity sold since its publication, the net sales generated, its presence in a ranking of the best digital sales, a prize won, the realization of an advertising campaign to promote the said book, its genre or the performance of digital sales for this genre - in volume and in value;
- the financial capacity of the company to which the brand publishing the Ebook belongs, taking into account its sales figures.
To assist you in this process, Arcom has developed an evaluation model. To obtain it, please contact the Authority at the following address: accessibilite.livresnumeriques@arcom.fr.
What criteria must I take into account for an Ebook to benefit from the fundamental modification exemption?
In the absence of any statutory criteria, Arcom has identified an array of clues to help assess whether the content and form of the Ebook are so inseparable that making it accessible would significantly alter the work.
To ensure that your Ebook qualifies for this exemption, you can take the following factors into account (but this list is not exhaustive): file format, number of figures, layout characteristics, whether the layout is essential to understanding the content, and whether the content has been distorted.
To assist you in this process, Arcom has developed an evaluation model. To obtain one, please contact the Authority at accessibilite.livresnumeriques@arcom.fr.
Are certain types of Ebook (comics, textbooks, etc.) automatically eligible for an exemption for disproportionate burden or fundamental change?
No exemption is automatically granted on the basis of the genre of the Ebook. Arcom will assess the merits of exemptions on a case-by-case basis.
Dans le cas où je relève un défaut de conformité aux exigences d’accessibilité sur un livre numérique ou un logiciel de lecture dont je suis en charge, que dois-je faire ?
Vous devez, d’une part, prendre les mesures correctives nécessaires pour mettre en conformité votre livre numérique ou votre logiciel de lecture et, d’autre part, en informer l’Arcom à l’adresse suivante : accessibilite.livresnumeriques@arcom.fr.
I've bought an Ebook and/or downloaded reading software but I'm having accessibility problems. How can I report this to Arcom?
You can report any accessibility defect found in an Ebook or reading software to Arcom via :
- the generic e-mail address: accessibilite.livresnumeriques@arcom.fr
- the alert form available on its website
- or by post to the following address:
Arcom
9 rue Brahms,
CS 12603,
75131 Paris Cedex 12, France