Penguin Random House | Munich, 07/02/2025

Making e-books more accessible for visually impaired people

Nina Pick and Hannes Frisch on the implementation of legal requirements by the PRH publishing group.

On June 28, the Accessibility Enhancement Act (BFSG) came into force in Germany. The aim is to remove the barriers that still exist in many areas for people with disabilities and enable them to participate more fully in society. For publishing houses, the law means, among other things, that the entire content of e-books must be made accessible to visually impaired or blind people and that steps must be taken to ensure that the content can also be found. At the Penguin Random House publishing group, Nina Pick, Senior Manager Product Data & E-Book Operations in Product Management, and Hannes Frisch, Digital Producer in Digital Production, have set up a project group to implement this. In an interview with Isabelle Nentwich from the publishing group they report on how they went about it.

You two are the leaders of the "Accessibility" project group at the publishing group. Where did you start? And how did things progress from there?

Hannes Frisch: We have been dealing with accessibility in the publishing group for quite some time. Armin Köhler, Head of Digital Production, was keeping an eye on the latest developments even before the BFSG, and we repeatedly discussed the topic with external experts in relation to e-books. So when the law came into force, it wasn't completely new territory for us.

Nina Pick: About a year and a half ago, we reached the point where we knew when the legislation would come into force and that we had to clarify what it meant for us and how we would implement it in practice. At that point, many issues were still unclear: For example, what would we do with illustrated books? And in the area of metadata, we first had to find out what information was important for visually impaired and blind customers and how we could include this information in the e-book in ONIX. Clarifying all of this took a lot of time at the beginning. Once we were able to make concrete statements last fall, we involved other colleagues and departments. We then spent the last nine months working together on the implementation.

What exactly had to be implemented?

Hannes Frisch: For an e-book to be accessible, it must meet three basic requirements. The first is functional, structured navigation and semantic markup within the e-book file. This allows blind or visually impaired people to have an e-book or PDF read aloud by a screen reader in a way that makes sense to them, find entry points, and navigate through the text using the table of contents. We have developed a standardization for this, which has enabled us to meet this requirement for some time now. The second requirement is alternative text. This is relevant for illustrated e-books. We have to provide image descriptions that can be read aloud by screen readers. This allows people with visual impairments to imagine and understand the images in the text. We take care of both of these things during production. And the third requirement concerns metadata.

Nina Pick: That's where I come in. I work in product management and am responsible for product and metadata in e-books, among other things. We have ensured that customers can see that the product is accessible before they buy it. We take the relevant information on the accessibility of the e-book from various sources, such as the e-book metadata, and display it automatically in our internal systems. From there, it is transferred to the corresponding ONIX file and the information is transmitted to our distribution partners and made available to our end customers.

A few months ago, a digital workshop on alternative texts was held for publishing group employees by experts from the German Institute for the Blind (Blista). Did you also bring in external experts on the subject for the project?

Nina Pick: Hannes is in the "E-Book" working group and I'm in the metadata working group at the Börsenverein, and we're both part of the "Accessibility" task force. There are also members from Blista. We already had some exchanges with the experts beforehand. We developed our best practices in consultation with these experts, which was of course very helpful. And we are still in contact with our colleagues at Blista after the BFSG came into force and are eager to hear their feedback.

All new publications must be accessible by the date the BFSG comes into force. What about backlist titles?

Hannes Frisch: Our backlist currently comprises around 20,000 available e-books. At this point in time, there are no official regulations regarding an obligation to make them accessible. However, we are still committed to gradually making the backlist accessible within the scope of our possibilities. Our sales department has drawn up a priority list for this purpose. Older titles that are still selling well or are currently relevant for other reasons are naturally at the top of the list. We are now working through this list step by step.

Nina Pick: Our colleagues in the industry and we ourselves assume that it will simply not be technically feasible to implement accessibility in the backlist by June 28—if only because of the sheer volume.

Can AI help with the implementation of accessibility measures?

Hannes Frisch: Yes, we are already testing AI in collaboration with our Tech & Data team to generate alternative texts for the numerous backlist titles. At the moment, however, it is still necessary to check the AI-generated alternative texts and correct them if necessary. This is, of course, an enormous amount of time and effort. But we are convinced that AI is becoming increasingly accurate and that we will gradually be able to reduce the amount of checking required for alternative texts. For our illustrated new releases, we are currently relying on alternative texts written by selected proofreaders. We have established this workflow together with our proofreading team.

The law states that the "essence of the product" must not be altered by accessibility measures. What does this mean for illustrated books?

Hannes Frisch: Providing alternative texts for all illustrated books would not be practical. For titles with a lot of layout or images, you have to take a closer look to see whether barrier-free implementation makes sense. That's why they tend to be lower down in the backlist prioritization list mentioned above, while pure text volumes are at the top. However, we have already discussed the titles by Walter Moers, for example, which are a mixture of both. This raises the question of whether it is even possible to convey the essence of the illustrations, especially the humor, through alternative text. In principle, however, it is of course our plan to provide all e-books with alternative text where it makes sense to do so.

Nina Pick: In individual cases, however, the decision may be made that we cannot make the title accessible. This decision must then be stored internally in the system at so that the information is documented. It is still unclear whether and how this must be communicated to the future new reporting office.

The law applies not only to e-books, but also to e-commerce, including the publishing group's website penguin.de. What needs to be done here?

Nina Pick: In principle, information on accessibility must be available wherever purchases can be made. Visually impaired or blind customers must be able to clearly see whether an e-book is accessible to them. We are currently clarifying with the marketing team exactly how we will implement this for penguin.de. However, we don't just want to provide information about the product on the website, but also general information about accessibility. We have set up a FAQ section for this purpose.

That sounds like an extensive project. What was the biggest challenge?

Nina Pick: As I mentioned briefly at the beginning, it was very unclear at first what the law actually required of us. It's about implementing an EU regulation that makes a lot of sense, but isn't something we can just implement overnight. The interpretation of such a regulation also varies from country to country. We were faced with the challenge of not having any clear guidelines for practical implementation at first. Working this out for was a great experience. I am very grateful to the Börsenverein for setting up the Accessibility Task Force. We were in regular contact with colleagues in the industry and worked together to prepare the ground. This gives me the feeling that we are well positioned.

Hannes Frisch: For manufacturers, the very heterogeneous data situation was a major challenge. We published our first e-books in 2010. In some cases, it is difficult to bring them all up to the same technical standard as today so that, for example, alternative text can be added. But we have found suitable software that can update our backlist titles. During the process, we realized that it is much more difficult to retrofit a product to make it accessible. However, we have now established processes for the future to ensure that our e-books are designed and implemented to be accessible from the outset. In technical jargon, this is called "born accessible."