PDF UA, EN 301549, WCAG or BITV for accessible PDF – what is the standard you should meet

This document is intended to offer a decision-making aid for the question of whether and which standard should be met when providing accessible documents or PDFs.

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The possibilities of Microsoft Office and Libre Office

Since the 2007 version, MS Office has offered the option of creating relatively accessible documents. Among other things, it offers the following options:

  • The marking of headings and lists to make it easier for blind persons to find their way around in documents.
  • The alternative description of pictures for the blind.
  • The exporting in structured PDF - so-called tagged PDF - a prerequisite for blind persons to be able to work meaningfully with PDFs.

The standard PDF UA

PDF Universal Accessibility (PDF UA) has been the technical standard for accessible PDF documents since 2012. However, the actual standard for accessible PDF documents goes beyond PDF UA. For all public bodies in the EU, this is the EU standard 301 549. EN 301549 is an adaptation of WCAG 2.1 AA, especially with regard to documents and websites.

PDF UA does not contain any requirements for contrasts, but WCAG does.

PDF UA is essentially a standard that formulates technical requirements. It does not go into content-related requirements such as simple language or comprehensibility. However, these also only play a role in the WCAG from the highest level AAA.

PDF UA should therefore be understood more as a technical implementation aid for software providers. The actual standards in the EU are WCAG 2.x AA and EN 301549 for public institutions.

Possibilities to meet PDF UA

There are only a few programs to create fully pPDF-UA standard-compliant PDF documents. One of them is Acrobat Pro from Adobe.

Acrobat Professional is a tool to professionally edit PDFs. It is primarily aimed at graphic designers and desktop publishers.

With Acrobat, documents can be tagged later – i.e. made accessible.

Among other things, Acrobat offers the following options that are currently partly not available in MS Office:

  • Marking document components as "artefact". This means that screen readers ignore these elements. This is useful, for example, for headers and footers, page numbers and other elements that are not important for screen reader users when reading aloud.
  • – Subsequent editing of structure tags. This allows minor errors to be corrected that are caused by the Office programs when converting to PDF.
  • changing the reading and tab order

The problem with the standards for accessible PDFs

If you actively communicate that you are making accessible PDFs available, those who know the subject expect that PDF UA will be fulfilled. This will not be possible with MS Office for the foreseeable future. By definition, a PDF can only be described as accessible if a public standard is met.

The PDF Accessibility Checker tool shows some errors in documents created from MS Office, but these have no serious consequences in practice.

options for action

The following approaches are conceivable:

Efforts are being made to fully comply with the PDF-UA standard. In this case, it is necessary either to train several - or all - employees to use Adobe Acrobat Pro or to hand over the documents to a service provider. The publication does not seem realistic due to the high expenditure of time and the sometimes considerable costs. The advantage is that compliance with the standard is the easiest to communicate.

The organization communicates that the documents have been designed to be accessible using the options offered by MS Office. It can also be specifically communicated which measures have been taken, for example the insertion of alternative texts and other structure tags. So it doesn't say that a certain standard was met, only what was done to make the document more accessible. Strictly speaking, it could only be communicated that a certain standard was met anyway. Even a document that complies with PDF UA is not accessible for persons with learning disabilities or limited language skills. The phrase "accessible documents" could therefore create false expectations.

The document can be published in the original Microsoft format. Almost all devices have the ability to view Office documents. It is then up to the user whether to convert it to PDF or not. In this case, compliance with PDF UA does not apply, since it is not a PDF. There is currently no standard for Office documents. The only advantage of PDF is that it has established itself as a quasi-standard for sharing documents. In addition, it does not offer any advantages over Office formats for persons with disabilities. PDFs are intended to ensure that documents are displayed in the same way on all operating systems. On the other hand, adaptability to different display options is a basic requirement of digital accessibility. Tagged PDFs are designed to solve this problem. However, this only works if the viewer supports tagged PDF. Only Adobe Reader currently does this.

Our Recommendation

Our recommendation is to create PDF documents with Office and communicate this clearly. In practice, PDF UA brings few advantages. Most documents created with Office are perfectly adequate in this format.

Compliance with a specific standard is not necessary for internal communication. The same applies to documents that are not intended for the public but are sent to cooperation partners. The applicable standard can still be met for brochures and other documents for the general public.

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