The exemption property allows EPUB creators to indicate that an EPUB publication that does
not meet accessibility conformance requirements has an exemption under the applicable jurisdiction's
laws.
Status of This Document
This section describes the status of this
document at the time of its publication. A list of current W3C
publications and the latest revision of this technical report can be found
in the W3C technical reports index at
https://www.w3.org/TR/.
This is a draft document and may be updated, replaced or obsoleted by other
documents at any time. It is inappropriate to cite this document as other
than work in progress.
The
W3C Patent
Policy
does not carry any licensing requirements or commitments on this
document.
Some jurisdictions provide exemptions for meeting accessibility requirements. For example, the European
Accessibility Act [directive-2019/882] provides three exemptions to meeting its
requirements: to microenterprises that employ fewer than ten people and have an annual turnover not
exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million, when
accessible production would prove a disproportionate burden, or when making the content accessible
would require a fundamental alteration of the product.
Although it is possible to explain these exemptions in the accessibility summary for an EPUB publication, plain language statements are not easily processed by machines. A vendor may want to
know that a publication is exempt before allowing it in their bookstore without an accessibility
conformance claim, for example.
This document uses terminology defined in EPUB
3.3 [epub-33].
Note
Only the first instance of a term in a section links to its definition.
1.3 Conformance
As well as sections marked as non-normative, all authoring guidelines, diagrams, examples, and notes in this specification are non-normative. Everything else in this specification is normative.
The key words MAY, MUST NOT, and SHOULD in this document
are to be interpreted as described in
BCP 14
[RFC2119] [RFC8174]
when, and only when, they appear in all capitals, as shown here.
2. Accessibility conformance exemptions
When a jurisdiction provides specific legal exemptions for EPUB publications, EPUB creators whose
content fails to meet the requirements of the EPUB Accessibility standard [epub-a11y] (or any other
standard), can use the exemption property to indicate
when their publications fall under one of these provisions.
Note
EPUB creators do not have to include an accessibility conformance claim of "none" when
listing that a publication has an exemption from accessibility requirements, but it is best practice
to also provide this information. Reading systems that do not recognize the exemption might
otherwise list the accessibility status as unknown.
The property MAY be repeated to list exemptions for multiple jurisdictions and/or for multiple exemptions
within a single jurisdiction.
The EPUB Accessibility standard does not define exemptions for inaccessible publications. This property
only exists for jurisdictions where such exemptions are legislated.
The EPUB Accessibility standard [epub-a11y] reserves the prefix "a11y:" for use with
properties in the http://idpf.org/epub/vocab/package/a11y/# namespace. EPUB creators do not have to declare a prefix in the package document.
A.1 Definition
Definition of the exemption property
Name:
exemption
Namespace:
http://idpf.org/epub/vocab/package/a11y/#
Description:
Identifies the accessibility exemption the EPUB publication falls under.
Article 14 paragraph 1 of the European Accessibility Act states that its
accessibility requirements shall apply only to the extent that compliance: …
(b) does not result in the imposition of a disproportionate burden on the economic
operators concerned [directive-2019/882].
Use of the eaa-disproportionate-burden value indicates an EPUB publication
is exempt because it would require such a disproportionate burden to make
accessible.
EPUB creators are responsible for ensuring their publications meet the legal requirements
for this exemption.
eaa-fundamental-alteration
Article 14 paragraph 1 of the European Accessibility Act states that its
accessibility requirements shall apply only to the extent that compliance: (a) does
not require a significant change in a product or service that results in the
fundamental alteration of its basic nature [directive-2019/882].
Use of the eaa-fundamental-alteration value indicates an EPUB publication is
exempt because it would require such a fundamental alteration to make accessible.
EPUB creators are responsible for ensuring their publications meet the legal requirements
for this exemption.
eaa-microenterprise
The European Accessibility Act defines a microenterprise as: an enterprise which
employs fewer than 10 persons and which has an annual turnover not exceeding EUR 2
million or an annual balance sheet total not exceeding EUR 2 million
[directive-2019/882].
It further states in Article 4 paragraph 5: Microenterprises providing services shall be exempt
from complying with the accessibility requirements referred to in paragraph 3 of
this Article and any obligations relating to the compliance with those
requirements [directive-2019/882].
Use of the eaa-microenterprise value indicates that the publisher of an
EPUB publication that does not meet accessibility standards qualifies under the
definition of a microenterprise.
EPUB creators are responsible for ensuring they meet the legal requirements of a
microenterprise when using this value.
Note
To request new values, please open a new
issue. When requesting a new value, please provide a unique name that identifies both
the jurisdiction and the exemption. Requests must cite the legislation that defines the
exemption.