Earning certification by building accessibility into ebook production

Problem and constraints

Colleges and schools preparing for the ADA Title II deadline were scrutinizing publishers’ accessibility claims. Norton had VPATs for its digital products, but VPATs describe one product at one point in time. There was no independent evidence that Norton’s ebooks were accessible by default, across the list, season after season.

Benetech’s Global Certified Accessible (GCA) program certifies exactly that: a publisher’s process for producing accessible EPUB ebooks, not a single title.

I initiated the relationship with Benetech, negotiated the agreement, served as Norton’s primary contact for certification, coordinated the work with Digital Production and Publishing Tools, and led the announcement. Digital Production owned the content remediation.

The first-round audit gave Norton a Born Accessible score of 47%, against an 80% threshold. The score combines automated testing with DAISY Ace and a manual evaluation with DAISY’s SMART tool, scored against the GCA criteria. The gap wasn’t one problem but six, spread across the production process: non-text content, structure, color contrast, link purpose, language of parts, and metadata.

• The fixes had to change the process, not the files. Certification is about the workflow, so these weren’t one-off fixes to individual books. They meant changing the actual production workflow, for the long term.
• It took two years and three rounds. Over a two-year evaluation, Benetech audited three sample titles from our workflows, one title per round. Each round took between two and five iterations before the title cleared the threshold.
• It competed for attention. Certification ran alongside the product VPAT work, and it had to land in time to matter to schools facing the Title II deadline.

Decisions and implementation

1. Made the case to leadership for process-level certification alongside product VPATs.
2. Negotiated the agreement with Benetech, including legal redlines.
3. Coordinated remediation and re-audits with Digital Production and Publishing Tools, organized around the six areas the first round found.
4. Turned the findings into production standards, tooling, vendor requirements and training, so they applied to every future ebook, not just the samples.
5. Drafted and ran the announcement, from Benetech review to legal approval and release.
6. Built the certification into Norton’s accessibility website and its sales and marketing materials.

Making the case

The argument I made in 2023 had two parts. Certification covers the production process, while VPATs cover individual products, so the two answer different questions for buyers. And the audit itself would improve Norton’s workflows, whatever the score. That second point mattered: it framed certification as a way to fix the process, not only as a credential.

Iterating with Benetech

The first-round result was the most useful thing in the project. It turned “make our ebooks accessible” into six named categories of fixes, each one something Digital Production could own.

From there it was an iterative, conversational process with Benetech: three rounds, one for each sample title, each with two to five iterations. Later rounds needed fewer iterations, which suggested the workflow changes were carrying over from one title to the next. The same kinds of issues kept needing remediation: headings, lists, tables, figures and ARIA labels. That repetition was the signal. A problem that recurs from book to book isn’t a book problem; it’s a workflow problem.

From fixes to production standards

The changes went into the workflow itself:

• Semantic markup rules. Heading hierarchy, ARIA roles and labels, EPUB types and landmarks, lists, tables with header cells and scope, captions, glossary and index markup, and how to treat decorative images were all written up as production standards, not left as fixes applied to individual books.
• Presentation moved into CSS. Text set in all caps or small caps is now written in normal case, with CSS handling how it looks, and drop caps moved to CSS instead of extra markup. That stops the same defect recurring in every book.
• Alt text became a production step, added during production with a validation step, not left for the end.
• Accessibility metadata became a deliverable. Accessibility metadata templates were added to the production templates, with a step for the team to fill them in accurately. Over time this grew into a broader system: accessibility features, hazards, access modes, and conformance and certification information are stored for each ISBN and distributed in EPUB metadata, ONIX and other channels.
• Checks moved into production. The team began running DAISY Ace as part of the production process, and a per-title accessibility checklist, including Ace and EPUBCheck, is being built from what certification taught us.
• Tooling, not just people. Improvements were pushed upstream to Publishing Tools, such as document roles and landmark lists, metadata management, and automated page-list markup, rather than relying entirely on producers fixing things by hand.
• Vendors and producers got the new rules. The production documentation was updated, vendors were notified of the new requirements, the changes were passed upstream to manuscript preparers, and producers were trained on them. The standards are expected to apply to all future ebook projects, not just the three certification samples.

Launching it carefully

I drafted the press release and coordinated review by Benetech, feedback from Communications, quotes from leadership, legal approval and release logistics, and recommended media outlets for each stakeholder group. On Benetech’s guidance, the release positioned Norton as part of a community of certified publishers rather than claiming to lead it alone. I was also the press contact, and my quote in the release was about what the process gave us:

Results and limitations

• Norton is a Global Certified Accessible publisher. The Born Accessible score rose from 47% to 88%, and both the print-priority and digital-first workflows were certified, announced on April 7, 2026, ahead of the Title II deadline.
• From remediation to prevention. Accessibility requirements now live in production specifications, vendor instructions, templates, markup conventions and quality checks, instead of being found and fixed at the end.
• From manual checking to tooling. Ace, Publishing Tools automation, reusable markup patterns, checklists and metadata automation began replacing reliance on spotting issues by hand at the end.
• From a few accessible books to an accessible workflow. The standards apply to ongoing production, not just the titles that were audited.
• Buyers have third-party evidence. The certification sits on Norton’s accessibility website and in sales and marketing materials, alongside the product VPATs.
• Validation continues. Benetech reviews a representative ebook each year for recertification, and sends certified publishers technical bulletins so workflows keep up as standards change.
• Still in progress or proposed: the per-title checklist is being built. A post-certification review proposed checks at more stages of production, from manuscript preparation through ebook assembly, reusable components for recurring problems, and accessibility reviews at the start of projects. That last idea is the basis of a newer accessibility action plan workflow, meant to find risks early.
• Certification covers the process for new ebooks. It applies to Norton’s ebook creation process for college and high school, with an accelerated initiative underway to include backlist titles. It vouches for the process using a few titles, not every book, which is why I built scanners to check the whole catalog.
• Not measured: any effect on adoptions or renewals.

What I would change

Plan earlier for checking every title. External certification and checking every title answer different questions. Certification tells you the process is sound; checking every title tells you where each book actually stands, and gives you a big-picture view of progress. I’d plan for both from the start, with the title-by-title checks adding to Benetech’s validation, not replacing it.

Further reading

• W. W. Norton & Company Achieves Global Certified Accessible Certification (press release, April 2026)