This document is a work in progress as Rakuten Kobo is implementing accessibility.
Last update : July 4, 2025

Table of Content

Can we (publisher) send accessible content to Rakuten Kobo?
Can we (publisher) send accessibility metadata to Rakuten Kobo?
What accessibility metadata does Kobo Require?
Does Rakuten Kobo make use of accessibility metadata sent by publishers?
How do Rakuten Kobo will manage the metadata of digital books?
How do Rakuten Kobo Stores will inform customers of the accessibility features of digital books?
When will Rakuten Kobo show accessibility metadata on store?
What does Rakuten Kobo do to meet the accessibility requirements for e-readers?
What is the deadline to be compliant for the EAA (European Accessibility Act)?
What is the minimum level of conformance my EPUB should meet?
Does Kobo prefer ePub3 over ePub2?
Does my EPUB need to be certified to be considered as accessible?
Text-To-Speech Explainer and FAQ
What if my book is not accessible?
Does all of my catalog need to be regenerated to be accessible?
How do you ensure accessibility using technical protection measures?
Does this impact audiobook catalogues as well? Do we (Publisher) need to send accessible metadata and accessible content too?
Does this also impact partner platforms and are you preparing this together?
Suggested Technical Resources
- ONIX example for EPUB
- ONIX example for audiobook
Suggested Support by Geographical Area
- Where Does EAA Applies?
- Multilingual Resources
- Italy
- France
- Netherlands
- Canada
- Norway
- Germany

European Accessibility Act (EAA)
effective date

🏁 June 28, 2025

Can we (publisher) send accessible content to Rakuten Kobo?

Yes, Rakuten Kobo fully ingests and supports accessible content. EPUB should follow the current standards (see Suggested Resources section).

Can we (publisher) send accessibility metadata to Rakuten Kobo?

Yes, Rakuten Kobo does support accessibility metadata sent via ONIX. We ingest, store and display ONIX code list 196 and list 143.

What accessibility metadata does Kobo Require?

We suggest that you send as many accessibility codes as you can from list 196, where relevant to the title (e. g. code 17 from list 196 "Accessible math content as MathML" is relevant for Science or Math books).

Important note on code list 196 available for ONIX 3.0 VS ONIX 2.1:
Latest issue (Issue 65) of list 196 is only valid for ONIX 3.0.
If you're still using ONIX 2.1, you can use list 196 but only the codes available in issue 36 (limited list of codes)

Kobo will make use of all codes from the 196 list (and some additional codes from lists 79, 143 and 81 - see below) and will map them under higher-order headings for a better customer experience, based on the W3C suggestions (still a work in progress).

The current W3C groups for this mapping are :

Accessibility Summary
Additional accessibility information
Hazards
Conformance
Navigation
Supports non-visual reading
Charts, diagrams, formulas
Visual Adjustments
Pre-recorded audio
Additional accessibility information

Please note that Kobo's mapping will be standard to the W3C guidelines, however, the names and descriptions on the Kobo Store will be up to Kobo's own discretion and may not be exactly those listed above.

To follow the W3C guidelines, Rakuten Kobo will also support a few additional codes from lists 79, 143 and 81, you can use those codes if appropriate to your content:

Codelist	Value	Name
79	12	US CPSIA or other international hazard warning
143	13	WARNING - Flashing hazard
143	14	No flashing hazard warning necessary
143	15	WARNING - Sound hazard
143	16	No sound hazard warning necessary
143	17	WARNING - Motion simulation hazard
143	18	No motion simulation hazard warning necessary
81	10	Text
81	48	Mathematical content
81	19	Figures, Diagrams, Charts
81	45	Text within images
81	49	Images of Text
81	01	Audiobook

Does Rakuten Kobo make use of accessibility metadata sent by publishers?

Yes. We’re now displaying accessibility metadata on product pages of the Kobo Store.

How do Rakuten Kobo will manage the metadata of digital books?

We are accepting all accessibility metadata provided to us by our publishers and authors. That metadata is then loaded into our systems and used on the Kobo website to provide information to users though a variety of places, like search and item details pages.

How do Rakuten Kobo Stores will inform customers of the accessibility features of digital books?

We are adding accessibility metadata information to the item details pages of all books that provide that information to us on the site, and in mobile applications and ereaders. This information is also part of search, through a dedicated search filter, so users can look for accessible books. This accessibility information are also shared with our partners.

When will Rakuten Kobo show accessibility metadata on store?

Accessibility features are now displayed on store on product pages.

What does Rakuten Kobo do to meet the accessibility requirements for e-readers?

We are currently working on accessibility improvements and features for our ereader devices, mobile applications, and web reading platforms. The features will be released ahead of the deadline.

What is the deadline to be compliant for the EAA (European Accessibility Act)?

In Europe, by June 28, 2025, every new eBook would have to be natively accessible and discoverable. All new metadata files sent to Rakuten Kobo will have to include accessibility information, even if it's a non-accessible information.

What is the minimum level of conformance my EPUB should meet?

We recommend that EPUB publications must, at a minimum, meet WCAG 2.0 Level AA in order to conform to the EAA's standards.

You can check the list of required features for WCAG 2.0 AA here: https://www.levelaccess.com/wp-content/uploads/2024/02/The-Must-Have-WCAG-Checklist.pdf

Does my EPUB need to be certified to be considered accessible?

No. But we suggest you follow the above recommendations to meet the minimum level of conformance.

Does Kobo prefer ePub3 over ePub2?

From W3C: "Although the EPUB Accessibility specification was developed primarily for EPUB 3, it is designed to be applicable to earlier versions of the format. The requirements and techniques can be applied to make both EPUB 3-conformant and EPUB 2-conformant publications accessible.”

TTS Explainer and FAQ

What is TTS?

Text-to-speech (TTS) is a reading system feature that allows users to listen to book content through computer-generated audio. TTS is an essential feature for many readers with disabilities, particularly those with vision or cognitive disabilities.

How does TTS work?

TTS is built into the reading system as an optional feature for users to activate and customize to their needs. When TTS is turned on, the underlying engine ingests the book content and generates an audio version of the content that is then read out on the device. The audio version of the content is generated on the device and only when requested by the user. The audio version is not saved, it is always generated as needed.

In Kobo's implementation, we will be using the voice options provided to us by the platforms the applications are built for. This means our iOS app will use the default voices built into iOS, Android will use the voices built into Android, and so on. This method will give us the best opportunity to support a wide variety of languages and preferences, as most platforms have built in voice options for multiple languages and locales. This method also means this feature will be able to work online and offline.

Could we manage text-to-speech at title level?

As per the below extract of the Marrakesh treaty, disabling TTS will be prohibited in EU.

From the Official text of the Marrakesh Treaty – EAA (European Accessibility Act):

« The interoperability in terms of accessibility should optimize the compatibility of those files with the user agents and with current and future assistive technologies. […] It is recognized that persons with disabilities continue to face barriers to accessing content which is protected by copyright and related rights, and that certain measures have already been taken to address this situation for example through the adoption of Directive »

And, in the section “Accessibility requirements for Products and Services” (Section I):

« (ii) | e-readers shall provide for text-to-speech technology; » 

And, in section IV “Additional accessibility requirements related to specific services:

« (ii) ensuring that e-book digital files do not prevent assistive technology from operating properly; […] (iv) allowing alternative renditions of the content and its interoperability with a variety of assistive technologies, , in such a way that it is perceivable, understandable, operable and robust; | (v) | making them discoverable by providing information through metadata about their accessibility features; | (vi) | ensuring that digital rights management measures do not block accessibility features. »

As such, you can manage TTS at the title level only outside of EU, using:

<EpubUsageConstraint> for Onix 3.0 (List 145 and 146)

 <EpubUsageConstraint>
     <EpubUsageType>05</EpubUsageType><!--List 145 - ProductContentType = Text-To-Speech-->
     <EpubUsageStatus>01</EpubUsageStatus><!--List 146 - Permitted unlimited -->
            </EpubUsageConstraint>

NEED MORE INFO?
For more details about Text-to-speech, the difference between TTS, SMIL and Screen Reader and a TTS demo, please go to the detailed TTS documentation here.

What if my book is not accessible?

Even if your book is not accessible, it's important that the metadata reflects it. In such cases, please choose the most appropriate code from list 196:

08 "Unknown accessibility"
09 " Inaccessible, or known limited accessibility"

Please not that it is extremely important that customer is aware of the non accessibility of your book. We emphasize that these codes should not be neglected.

Does all of my catalog need to be regenerated to be accessible?

No. Starting June 2025, only all new releases have to be accessible. However, even if you don't have to modify all of your EPUB files for now, metadata should be updated accordingly.

For your back catalog titles which are not accessible, this needs to be specified as explained in the previous section, with code 09 " Inaccessible, or known limited accessibility".

How do you ensure accessibility using technical protection measures?

For books within the Kobo ecosystem where publishers have asked for DRM protection, purchased from us and downloaded onto our ereader devices, web reading platform, or mobile applications, our internal DRM does not block or prevent the use of assistive technology. For books outside of our ecosystem, such as those from libraries or other book stores, we support Adobe DRM, which does not block accessibility features but has poor usability due to Adobe software. We are actively working on supporting LCP DRM, which is growing in popularity, and provides a much more accessible and usable experience for readers.

Does this impact audiobook catalogues as well? Do we (Publisher) need to send accessible metadata and accessible content too?

Although audiobook content is not included in the EAA (European Accessibility Act) compliancy requirements, we still recommend that you send accessible metadata and content for audiobooks when available. Much of the accessibility support that Kobo will have in place for ebooks will also benefit how customers experience audio titles and the accessibility features displayed on store.

List 196 https://ns.editeur.org/onix/en/196

The values from list 196 are not only for the EPUB format, but can apply, if relevant to any digital format described in the ONIX <ProductForm> and <ProductFormDetail>. Of course a lot of the values in 196 would simply not be relevant for an audiobook but when they are, they can be used.

Here are some key codes that are useful in their application to audiobooks:

Code 11 - “Table of contents navigation"

Code 29 - "Next / previous structural navigation"

If there are any other forms of navigation included in a digital audio book made available to the public you could use any relevant code from list 196 if it applied to audio

Code 28 - "Full alternative audio descriptions”

Code 51 - "All non-decorative content supports reading via pre-recorded audio"

Thus is a confirmation that the whole product made available to the end listener is fully accessible to readers who rely on hearing only.

If the product had any other type of content then this would also need to be described from list 81 and then confirmed as being accessible by using the relevant codes form list 196.

A common instance of this would be the inclusion of a cover image, which either needs an alternative description or should be marked as a decorative image. An ONIX file for the audio product should include either code 07 or 46 from list 81 to indicate there is an image. If it is 07, you should be seeing a notification from list 196 that the image has an alternative description, code 14 or 15 from list 196, as e-commerce websites still need to have images with an alternative description or a notification for screen readers that it is a decorative image of the audiobook cover.

List 81 https://ns.editeur.org/onix/en/81

Here are some key codes that are useful in their application to audiobooks:

Code 01 "Audiobook"

Does this also impact partner platforms, and are you preparing this together?

This law applies to everyone in Europe, so our retail partners are also impacted. Partners are working to develop support on their side, and when everyone is ready, we will send them the metadata publishers have provided us with and they will include them on their item detail pages.