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The ASPIRE reference guide to writing accessibility statements.
Alistair McNaught + Huw Alexander
27 May 2024

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An accessibility statement is a window on a publisher’s content. It is a fantastic way to engage with users and showcase your commitment to accessible, inclusive publishing. The ASPIRE project reviews accessibility statements across the publishing industry and makes those reviews available to the public and particularly to librarians. The purpose of ASPIRE is to support publishers and platforms in creating transparency within the industry and promoting learning and reading.

This reference guide provides an overview of writing user-focused accessibility statements and the key elements of the ASPIRE review process.

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  • Part 1: Anatomy of a publishing accessibility statement

  • Part 2: The ASPIRE review process

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We’ve also mapped the contents and structure of the accessibility statement to the Publishing Accessibility Action Group’s accessible publishing charter.

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We hope this guide provides you with support and inspiration as you prepare your statements and engage with your readers.

PART 1: Anatomy of a publishing accessibility statement

  • Introduction.

  • Using the resource: Things that work well with the website / content / platform

  • How accessible is the product? Are there issues the user should know in advance?

  • What to do if you need better accessibility than currently available.

  • Embedding accessibility.

 

​We explain each element below and map each one to the PAAG Charter for Accessible Publishing that provides a framework for building an accessibility programme within a publisher.

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Section 1. The Introduction

If an accessibility statement sits on a website and is undiscoverable, is it really there? Make sure that your statement is prominently positioned and signposted on your website. Ensure that the statement is surfaced in Google searches. Your accessibility statement is an evolving document so make sure to identify and remove out of date information to reflect the updates you have made.

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Explain your commitment to accessibility standards and how this aligns with your company’s philosophy or vision statement. The accessibility statement is an opportunity to tell your story, acts as a powerful marketing tool, and creates a positive message of corporate social responsibility.

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Compliance with the PAAG Accessible Publishing Charter

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Section 1 applies to the following elements of the Charter for Accessible Publishing.

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  • Commitment 3: Publishing our accessibility policy on our website, including our commitment to this Charter.

  • Commitment 7: Advocating for accessibility standards and collaboration throughout the publishing supply chain from author to reader.

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Section 2. Using the resource: Things that work well with the website / content /platform

You cannot assume all users know how to make best use of an accessible file or interface. This section is a key marketing pitch to tell users what you have done for accessibility, what works, and how they can benefit from it.

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The content covered will vary depending on whether you are responsible for file formats, delivery interfaces or both. Where there are multiple file formats, you can provide guidance and insights on the different reading experiences afforded by each format
(such as EPUB vs PDF). Where functionality is not specifically available, but your product is compatible with other tools, you might suggest free tools or plugins to make the difference – for example, text-to-speech browser plugins, clipboard readers, colour changing tools etc.

The “Using the Resource” section will include information on the following:

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  • Magnification and reflow.

  • Personalization options such as colour/contrast, line spacing, margins etc.

  • Availability of image descriptions.

  • Navigation options, including tagging for headings and subheadings etc.

  • Keyboard-only navigation and operation.

  • Interoperability with assistive technology (this may be influenced by Digital Rights Management (DRM) decisions, so clarify this where applicable).

 

Compliance with the PAAG Accessible Publishing Charter

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Section 2 applies to the following elements of the Charter for Accessible Publishing.

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  • Commitment 6: incorporating appropriate accessibility features within our digital publications and platforms, according to the Web Content Accessibility Guidelines and other appropriate accessibility standards.

  • Commitment 7: Advocating for accessibility standards and collaboration throughout the publishing supply chain from author to reader.

  • Commitment 8: Utilising the accessibility metadata opportunities available to aid with the discovery of accessible content.

  • Commitment 9: Testing and validating content to ensure it is usable by people with print disabilities. Ideally this would include testing by persons with lived experience.

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Section 3. How accessible is the product? Are there issues the user should know in advance?

Inform users about any accessibility issues that have not yet been resolved – for example, if images lack descriptions or PDFs are not tagged for reading order or screen reader testing failed on the interface. Letting people know in advance is better customer service than ignoring the issue, letting disabled users waste time finding the problem and then trying to resolve it too late. DRM restrictions can have an impact on the tools the end user can use, so mention these where applicable. Examples include:

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  • ​EPUBs being tied to Adobe Reader and thus losing much of their accessibility,

  • Copying restrictions reducing functionality for text-to-speech tools that rely on reading the clipboard.

 

​By being transparent about what does not work you can discuss other options available and help manage expectations. You may be able to suggest alternatives such as:

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  • Accessing the content in a different way that has more closely matches the reader’s needs for example:

    • download a different format

    • read it online

    • read it in a Kindle edition on a phone or tablet.

  • Free tools or plugins that can make a difference. For example, colour personalisation tools or high contrast settings can compensate for a lack of colour change options in a delivery interface.

 

UK law regards the base level accessibility requirement as meeting the requirements of the EU accessibility requirements suitable for public procurement of ICT products and services in Europe (EN 301 549) – this is very closely aligned to Web Content Accessibility Guidelines 2.2 at AA level.

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The inclusion of a “Technical information about this website” section within the accessibility statement will allow you to list (and easily update) the legislation and guidelines that you have taken into consideration when developing your content and user interfaces. For instance:

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Explore accessibility legislation by country via this comprehensive list compiled by Inclusive Publishing.

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The PAAG resources pages feature a wide range of articles about the upcoming European Accessibility Act.

 

Compliance with the PAAG Accessible Publishing Charter

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Section 3 applies to the following elements of the Charter for Accessible Publishing.

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  • Commitment 3: Publishing our accessibility policy on our website, including our commitment to this Charter.

  • Commitment 7: Advocating for accessibility standards and collaboration throughout the publishing supply chain from author to reader.

  • Commitment 8: Utilising the accessibility metadata opportunities available to aid with the discovery of accessible content.

  • Commitment 9: Testing and validating content to ensure it is usable by people with print disabilities. Ideally this would include testing by persons with lived experience.

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Section 4. What to do if you need better accessibility than currently available and who to contact

If the options above still do not meet the needs of a disabled reader, they may need a more accessible option or a DRM-free version that their local alternative format team can help with. This is the place to describe your ‘support ecosystem’. For example, is there a dedicated email, phone number, helpdesk or internal role responsible for accessibility? Do you have your content distributed through the RNIB Bookshare collection or Bookshare, etc?

This information may already be in place, in which case you might simply add a link from the accessibility statement. This is a useful place for information on:

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  • Contact details

  • Licensing terms + conditions

  • Typical response times

 

Compliance with the PAAG Accessible Publishing Charter

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Section 4 applies to the following elements of the Charter for Accessible Publishing.

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  • Commitment 3: Publishing our accessibility policy on our website, including our commitment to this Charter.

  • Commitment 4: Designating and publicising a point of contact in our organisation to assist persons with disabilities to access alternate formats of our content.

  • Commitment 5: Partnering with national and international organisations that provide support for the availability of publications in accessible formats.

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Section 5. Embedding accessibility

This section is designed to demonstrate both confidence and competence, so it covers the following aspects focused on the development and testing:

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  • When the testing was done and when the accessibility statement was last updated. You should aim for annual updates of your accessibility statement to ensure you are telling the story of your commitment to accessibility. Always ensure that you have dated your statement and include the relevant update dates.

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  • What the testing involved, including which assistive technologies were used. You may have used a third-party vendor to audit your site – make sure to reference them. If you use automated testing, then include the name of the provider, such as Axe or Microsoft Accessibility Insights.

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  • Include an accessibility roadmap. The roadmap is a great way of communicating to your customers that you have identified issues and are seeking to address them. It is a strong sign of engagement and a proactive approach. The roadmap could include the following:

    • What the testing showed and whether it showed a need to make improvements. If it did, do you have a structured remediation plan with a timeline?

    • Outline how internal workflows and quality assurance processes have incorporated accessibility.

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  • Provide information about the staff training that you have undertaken. Provide an outline of what processes and training you have implemented within your company. Talk about your accessibility working groups or dedicated accessibility-focused departments/staff. Highlight your involvement with external taskforces or committees.

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  • Discuss the ways in which your content development processes embed accessibility.

 

  • Encourage your users to provide feedback that can help you to identify issues, successes, and inform your future decision-making.

 

Remember your accessibility statement is not a one-off exercise. You are expected to update the statement annually and reduce ‘disproportionate burden’ claims as your expertise and awareness improves. Your accessibility statement is an evolving document – you are having a conversation with your users and customers and showcasing the improvements and innovations you have implemented.

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Compliance with the PAAG Accessible Publishing Charter

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Section 5 applies to the following elements of the Charter for Accessible Publishing.

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  • Commitment 1: Raising awareness among, and providing training for, relevant staff.

  • Commitment 2: Nominating a company “accessibility champion” who can bring together key stakeholders to discuss potential accessibility improvements and act as a liaison for all accessibility information.

  • Commitment 7: Advocating for accessibility standards and collaboration throughout the publishing supply chain from author to reader.

  • Commitment 9: Testing and validating content to ensure it is usable by people with print disabilities. Ideally this would include testing by persons with lived experience.

  • Commitment 10: Monitoring our progress in this area and regularly assessing the accessibility of our digital publications and platforms.

PART 2: The ASPIRE review process

​The ASPIRE service has been designed to help publishers to write user-focused accessibility statements that tell the publisher’s story and improve the user experience. The ASPIREreview assesses the statement based on 3 distinct categories:

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  • Communication.

  • Content.

  • Interaction.

 

The ASPIRE criteria provide a framework that enables you to create a user-focused statement that provides a positive, sustainable, and inclusive message about your content and your values as a company.

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Section 1. Communication

The Communication section assesses the accessibility statement based on its provision of information and level of contact information availability. The section contains 4 main ASPIRE criteria as follows.

ACCESSIBILITY INFORMATION: DISCOVERABILITY

The publisher’s website should include easy to find accessibility information. Ensure that your accessibility statement is easily found when browsing your website or through a search engine. Include a link to your accessibility statement in the footer of your web pages and make sure that the statement is clearly linked from your home page. Also consider ensuring that your company information, including imprints, is up to date on the free searchBOX directory of accessible publishing contacts for librarians.

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ASPIREreview criterion

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Is the accessibility information discoverable on the publisher website?

  • Accessibility information is easy to find [2]

  • Accessibility information is difficult to find. [1]

  • Accessibility information not found. [0]

ACCESSIBILITY INFORMATION: CURRENCY

Make sure that your accessibility information is up-to-date and state clearly when the page was last updated. Retaining outdated information in the statement may undersell any subsequent improvements and undermine the work you have done.

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ASPIREreview criterion

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When was the information last updated?

  • Last updated within the last year. [2]

  • Last updated more than a year ago. [1]

  • No information available. [0]

CONTACT INFORMATION

The accessibility help page should include contact details, for instance, a telephone number, an email address, or a web form, so users experiencing difficulties can request support or request a file in an accessible format. Allow your customers to easily ask questions and ask for feedback, both good and bad. Accessibility is an ongoing conversation.

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ASPIREreview criterion

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What level of contact information is provided by the publisher?

  • Contact details include specific options (e.g., named person/phone number/dedicated accessibility email). [2]

  • Contact details include a generic contact option (e.g., main switchboard number). [1]

  • No contact details available. [0]

RESPONSE TIMES

The accessibility information should indicate how long it will take to receive a response to an accessibility query or an accessible file request for a disabled learner. The response time stated should be reasonable, e.g., days rather than weeks, given that the user is likely to have a limited timeframe in which the title will be useful for their studies. Since these requests are vital to student study needs and learning outcomes, response times should be based on the likely time to fulfil the request, not the time it takes for an automated email-responder system to deliver a holding email.

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​Supplying an accessible file (or an unrestricted file which the library/disability team can make accessible) is usually the responsibility of the publisher, but aggregators/platform providers may also get these requests and have their own arrangements for responding. It is very helpful to have an indicative response time in an accessibility statement.

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Some requests ("Please supply the raw PDF, so we can add semantic headings ourselves") may be quicker to fulfil than others ("Please supply a fully marked up version of this PDF"). Some requests are unreasonable ("Please provide this in Microsoft Word format"). The accessibility statement should provide a realistic assessment of the turnaround time for typical requests. It is reasonable that it might include caveats for more complex requests.

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ASPIREreview criterion

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Does the publisher specify target fulfilment times for provision of accessible content (i.e., not just an email auto-responder acknowledgement)?

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  • Accessibility information includes target fulfilment times of up to 5 business days. [3]

  • Accessibility information includes target fulfilment times of 5 - 10 business days. [2]

  • Accessibility information includes target fulfilment times of 11+ business days [1]

  • No information available on response times. [0]

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Section 2. Content Information

The Content Information section assesses the Accessibility Statement for the level of information provided about content files and user permissions. The Content Information section contains 7 ASPIRE criteria as follows.

DIGITAL RIGHTS MANAGEMENT (DRM): COMMERCIAL CONTENT

Be clear about any usage restrictions you place on your content and outline your approach to supplying DRM-free copies to eligible readers. The accessibility information should clearly state whether your files are protected by Digital Rights Management (DRM). If they are, the restrictions should be clearly explained to avoid users wasting their time with trial and error. For instance, “Files can only be opened using Adobe Digital Editions” or “It is not possible to copy text.”

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ASPIREreview criterion

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Does the publisher employ DRM for sales of their titles through third parties?

  • Content is signposted as DRM-free. [2]

  • Digital rights management (DRM) restrictions are clearly explained. [1]

  • There is no information on DRM. [0]

DIGITAL RIGHTS MANAGEMENT (DRM): CONTENT REQUESTS

Do you supply DRM-free digital files upon request from an institution or customer? This may be handled internally by your permissions department or by a third-party such as the RNIB Bookshare service. If you have a partnership with an accessibility service, make sure to highlight this as it sends a positive message about your commitment to provide inclusive content.

 

ASPIREreview criterion

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Does the publisher supply DRM-free eBook files upon request for accessible copies?

  • Yes, DRM-free files are available upon request. [2]

  • No, DRM-free files are not available. [1]

  • No information on file supply. [0]

AVAILABLE FORMATS

Be clear about which formats (such as EPUB or PDF) you make available in the market. ​The accessibility information should state which format the publisher’s files are provided in, e.g., PDF, EPUB2, EPUB3. Guidance should also be given on using these formats. This should include any software required to open the files and a link to download it, along with information on how to modify accessibility settings (or links to this information on the software provider’s website). For example:

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“To open PDF files, you will need a PDF viewer such as Adobe Reader. Please see the following guide for advice on using the inbuilt accessibility features of Adobe Reader: Reading PDFs with reflow and accessibility features.”

 

ASPIREreview criterion

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Which ebook formats are made available by the publisher?

  • Available formats are listed (e.g., PDF, HTML, EPUB2, EPUB3) with accessibility recommendations. [2]

  • Available formats are listed (e.g., PDF, HTML, EPUB2, EPUB3) but no accessibility recommendations. [1]

  • There is no information on the formats supplied. [0]

IMAGE DESCRIPTIONS

The inclusion of image descriptions, especially for academic content, greatly increases the accessibility of your content. Be honest about how you are approaching image description and state clearly what the customer can expect from your content.

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​It is important for images and diagrams that convey information to have meaningful text descriptions to avoid excluding readers from key information. There are various ways this can be achieved, including adding a description to the alternative text HTML attribute (alt=) attached to the image, fully describing the image within the surrounding text, or including a detailed description in the image caption. Decorative (i.e., purely aesthetic) images do not require a text description and should have a null attribute (alt=“”) to save screen readers reading the image filename aloud.

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The accessibility information should state whether images included in the publisher’s files have meaningful descriptions and provide detailed information about the form of these descriptions. If the publisher’s files do not include any images, this should also be stated in the accessibility information.

 

ASPIREreview criterion

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Does the publisher provide information about the inclusion of image descriptions in their ebooks?

  • Detailed information on image descriptions (e.g., Alt text / Long Descriptions / Captions). [3]

  • Generic information on image descriptions. [2]

  • Image descriptions planned for next 6 - 12 months. [1]

  • No information on image descriptions. [0]

NAVIGATION

Outline the navigation tagging structure and reading order that you have implemented within your ebooks. Publishers put huge effort into developing accessible files - tell the story of your efforts.

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The accessibility information should state whether the publisher’s files have been structured for accessibility so that they can be navigated by screen reading software, meaning they are accessible to blind and low vision users. The accessibility information should also specify whether platforms can be navigated by keyboard only (for non-mouse users) as well as which structural accessibility features the publisher’s files have. Structural accessibility features may include navigational tagging (e.g., heading levels, hyperlinks) or reading order. Dyslexic readers also benefit from well-structured headings in files. Built in tools (e.g., Adobe Acrobat Reader’s ‘Bookmark’ panel) or browser plugins (e.g., HeadingsMap) let readers quickly identify sections of interest.

 

ASPIREreview criterion

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Does the publisher provide information about navigational tagging and reading order in their ebooks?

  • Information is available on navigational tagging (e.g., heading levels, hyperlinks) AND reading order. [3]

  • Information available on structural tagging OR reading order. [2]

  • Navigation options are planned for next 6 - 12 months. [1]

  • No information available on heading structure or reading order. [0]

MAGNIFICATION + REFLOW

The ability for users to alter the text to a size they can comfortably see is an important accessibility feature. Magnification is particularly useful for people with visual impairments, older people with declining eyesight and people with dyslexia, who may find small font sizes difficult to read.

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The accessibility information should state whether the text size can be changed in the publisher’s files, and if so, instructions for doing so (or a link to external instructions) should be provided.

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When text is magnified, it should automatically reflow, i.e., re-wrap to fit the page. If reflow does not work and the page is simply enlarged within a frame, the user must scroll left and right to read the entire line, which presents a huge barrier to efficient access.

The accessibility information should state whether text in the publisher’s files will reflow when the zoom level is changed, and if so, instructions for activating the text reflow setting (or a link to external instructions) should be provided.

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Reflow and magnification capability may vary with file format. Where multiple formats are on offer, guidance should be available on any format-based accessibility differences.

 

ASPIREreview criterion

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Does the publisher provide information about magnification and reflow in their ebooks?

  • Information available on magnification and reflow. [3]

  • Information available on magnification. [2]

  • Magnification and reflow options are planned for next 6 - 12 months. [1]

  • No information is available on magnification and reflow. [0]

COPYING + PRINTING

Within an academic context, the ultimate purpose of reading an eBook is to use it for a curriculum related use. Users are likely to want to export text extracts or diagrams into their own notes or directly into assignments, and allowing copying supports this.

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The accessibility information should state whether it is possible to copy text from the publisher’s files, and any limitations on this, e.g. “It is possible to copy up to 10% of each file”.

The ability to print from an eBook is a useful feature for people who prefer to process information in printed rather than electronic format.

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ASPIREreview criterion

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Does the publisher provide information about copying and print limits in their ebooks?

  • Specific information available on copy/print limits (e.g., pages or percentages). [2]

  • Generic information available on copy/print limits. [1]

  • No information available on copy/print limits. [0]

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Section 3. Interaction

The Interaction section assesses the accessibility statement for the details it provides regarding the publisher's engagement with accessibility services and their licensing terms. There are 3 ASPIRE criteria as part of the Interaction section.

ENGAGEMENT WITH ACCESSIBILITY SERVICES

Many publishers have partnered with services such as the RNIB Bookshare to help disseminate content. Make sure that you tell this positive story.

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The accessibility help page should specify whether the publisher makes their content available to disabled learners via services such as RNIB Bookshare (UK), or Bookshare (US). If so, information should be given on the publisher’s level of engagement with the service, e.g., they may have made only a selection of their titles available this way, a significant number of titles or their entire back catalogue. They may also have a direct upload feed to the service supplying ongoing newly published titles; this ensures they are made available to disabled learners as quickly as possible. Advertising this information can reduce the helpdesk requests you receive and forge strong relationships with your librarian customers.

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ASPIREreview criterion

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Does the publisher work with accessibility services to provide accessible content?

  • Deeply engaged with multiple international accessibility services (such as RNIB Bookshare or Bookshare (US)) (e.g., large number of titles or automated supply service). [4]

  • Some engagement with national accessibility services evidenced. [2]

  • Currently in negotiation to provide content to accessibility services. [1]

  • No mention of any services. [0]

LICENSING TERMS + CONDITIONS: AVAILABILITY

When a disabled learner needs to use a publisher’s file and it is not accessible to them, an accessible version of the file needs to be obtained from the publisher. This is sometimes requested by the learner themselves, but most often it is requested by their institutional library or disability support staff on their behalf. When the publisher supplies the file, they may provide accompanying terms and conditions detailing how it can be used and any limitations on its use, e.g., that it can only be supplied to the specific student it was requested for, or that it must be deleted after a specified period of time.

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If a publisher has specific licence terms and conditions for the supply and use of their accessible files, these should be clearly stated within the accessibility information. We advise publishers to check that their licences are compliant with the Copyright and Rights in Performances (Disability) Regulations 2014 legislation and the Marrakesh Treaty which enshrined a right for Higher Education Institutions to share accessible “intermediate copies” of textbooks.

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ASPIREreview criterion

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Does the publisher provide up to date licence terms and conditions (T&Cs) on their website?

  • Licence terms are clear and easy to meet. [2]

  • Licence terms are clear but include inappropriate elements. [1]

  • No licence terms are available. [0]

LICENSING TERMS + CONDITIONS: PERSONAL INFORMATION

Some licenses to obtain accessible content include a requirement to provide personal details about specific medical history. We live in a GDPR world now. Remove any requirements of this type and improve your ASPIREscore.

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ASPIREreview criterion

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Do the licence terms and conditions on the website include the level of private data required from the disabled student?

  • Licence terms and conditions require minimal or no personal details. [3]

  • Licence terms and conditions require personal details acceptable to the learning provider. [2]

  • Licence terms and conditions require intrusive personal details. [1]

  • No licence terms or conditions available. [0]

Conclusion

We hope that this guide to the ASPIREreview process illustrates how the ASPIRE criteria can be used as a checklist as you write your statement. Writing user-focused and user-friendly statements is an art, but it is central to engaging with your audience. Think about your accessibility statement as a marketing tool - you are telling the positive story of your platforms and content, and listening to the needs of your readers. An accessibility statement is a single page, but it is a page of critical importance. Make sure you are an open book about your accessibility.

 

Learn more about the ASPIRE project.

Explore the ASPIRE list for publishers.

Explore the ASPIRE list for platforms.

Contact ASPIRE: aspire@textboxdigital.com

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© Alistair McNaught Consultancy + textBOX Digital, 2024

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