Do I really need to check the accessibility of my documents?

25/03/2014 10:33pm

At Web Key IT, we are regularly asked for advice and assistance in creating accessible documents, particularly by organisations striving to host these documents on their websites.  Most website owners are aware that any content you host on your website needs to meet the Web Content Accessibility Guidelines, Version 2.0 (WCAG 2.0) (W3C, 2008). These guidelines have been created by the World Wide Web Consortium, known as W3C. In Australia this normally means meeting Level AA of WCAG 2.0. Basically if you need an Internet connection to reach the document, and this includes email of course, the document must be accessible. If the document is in printed copy only, these requirements do not apply.

The first question that usually arises is whether documents in Portable Document Format (PDF) are accessible. In WCAG 2.0 terms, this comes under the section regarding Conformance Requirements:

Only accessibility-supported ways of using technologies are relied upon to satisfy the success criteria. Any information or functionality that is provided in a way that is not accessibility supported is also available in a way that is accessibility supported (W3C, 2008 Paragraph 4).

The Australian Human Rights Commission (AHRC) which administers the Disability Discrimination Act, 1992 states that:

PDF cannot be regarded as a sufficiently accessible format to provide a user experience for a person with a disability that is equivalent to that available to a person without a disability, and which is also equivalent to that obtained from using the document marked up in traditional HTML (Australian Human Rights Commission, 2010 Section 2.4.2 The Portable Document Format (PDF) and Accessibility).

AHRC also provides the following advice regarding risk for relying on PDF only:

Accordingly, organisations that publish documents only in PDF risk complaint under the DDA unless they make the content available in at least one additional format and in a manner that incorporates principles of accessible document design. Additional formats should be published simultaneously with the PDF version, and at least one such format should be downloadable as a single document if the PDF version is available as a single download (Australian Human Rights Commission, 2010 Section 2.4.2).

Additionally, the AHRC state that while content authors should not be relying solely upon documents in PDF, they should be incorporating as many accessibility features as possible into their PDF documents such as using a logical reading order, making sure all images have meaningful alternative text, making sure tables are correctly marked so that they can be read in the correct sequence and have table headings provided, and correctly using paragraph, heading and list tags.

This advice has been corroborated by the Australian Government’s Web Guide which applies to government agencies. This states “Agencies are reminded that it is still a requirement to publish an alternative to all PDF documents (preferably in HTML)” (Australian Government, 2013 Accessibility: Alternative Formats). The Web Guide confirms that agencies must abide by the previously mentioned AHRC Disability Discrimination Act Advisory Notes.

The W3C has provide a document Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies (WCAG2ICT) to assist organisations in creating documents that are as accessible as possible (W3C, 2013). This document will assist organisations familiar with WCAG 2.0 to map the different Success Criteria to document requirements. Additionally, the document How to Meet WCAG 2.0 is a quick reference guide that specifically shows PDF techniques and failures (W3C).

Of course, PDF is not the only issue with regard to accessible documents. Documents originate in many different formats from Adobe InDesign to Microsoft Word and many others.Most new versions of these programs include accessibility- checking features that are well worth exploring. While Adobe Acrobat Pro includes accessibility features, there are also free tools such as PAC to assist in checking your PDF document (Zugang für alle, 2009)). The best procedure is to work on making the document in its original source accessible before converting it to PDF (if that is the intention). While remediation work can be done within PDF, there is still the issue of the accessible or alternate version as described above.

In future posts, we will be dealing with some of the typical issues encountered in making your original documents accessible and also performing remediation work on those documents as well as their PDF versions.



Australian Government. (2013). Web Guide. Retrieved. from

Australian Human Rights Commission. (2010). World wide web access: Disability Discrimination Act advisory notes: version 4.0. Retrieved August 13, 2014. from

W3C. (2014). How to Meet WCAG 2.0: A customizable quick reference to Web Content Accessibility Guidelines 2.0 requirements (success criteria) and techniques.   Retrieved August 13, 2014, from

W3C. (2008). Web Content Accessibility Guidelines (WCAG) 2.0.   Retrieved August 13, 2014, from

W3C. (2013). Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies (WCAG2ICT).   Retrieved August 13, 2014, from

Zugang für alle. (2009, 2014). PDF Accessibility Checker (PAC 2).   Retrieved August 13, 2014, from http://www.access-for-