The European Accessibility Act and PDFs

The European Accessibility Act (EAA), which the EU adopted in 2019, sets accessibility requirements for a wide range of digital services and products. While discussions often focus on websites, this article focuses on an essential but often overlooked component: digital documents, particularly PDFs.

This guide explains how the EAA affects PDFs, outlines the relevant standards, and describes what organizations must do to comply.

Video Guide

What Is the European Accessibility Act?

The European Accessibility Act outlines minimum accessibility requirements across the EU to eliminate barriers for people with disabilities. It promotes inclusivity through universal design principles.

Services Covered by the EAA

The EAA applies to:

• E-commerce platforms
• Banking and financial services
• Electronic communication services
• Passenger transport systems
• Audio-visual media services
• Self-service terminals
• Ebooks and digital publishing

These categories cover daily life services, making accessibility essential for equal participation.

How the EAA Applies to PDFs

Although the EAA doesn’t list every document type, it covers all informational materials tied to in-scope services. That includes:

• User manuals in downloadable formats
• Bank statements
• Invoices delivered as PDFs
• Ebooks

Since these documents support service delivery, they must meet the same accessibility standards as the websites or platforms that host them.

Specific Mention of Ebooks

The EAA explicitly includes ebooks as a covered category, which confirms that digital formats like PDFs and EPUBs must also meet accessibility requirements.

Accessibility Standards for PDFs

To comply with the EAA, organizations must ensure their documents meet recognized accessibility standards. Two key frameworks provide guidance:

1. WCAG 2.1 AA (Web Content Accessibility Guidelines)

WCAG, originally designed for websites, applies to documents as well. It relies on four core principles:

• Perceivable: Users must be able to perceive the content in various forms.
• Operable: Users must be able to interact with all interface components.
• Understandable: Content and operation must be clear and predictable.
• Robust: Content must work reliably with assistive technologies.

2. PDF/UA (PDF Universal Accessibility)

PDF/UA provides a framework to create accessible PDFs. It ensures that assistive technologies like screen readers can properly interpret and navigate PDF content.

Role of EN 301 549

EN 301 549, the EU’s standard for ICT accessibility, serves as the EAA’s technical reference. It incorporates WCAG 2.1 AA criteria and expands them to cover:

• Software applications
• Non-web documents, such as PDFs

When organizations follow EN 301 549, they align their digital systems—websites, apps, and documents—with EAA requirements.

Why Document Accessibility Matters

Organizations must prioritize document accessibility to meet legal standards and provide inclusive user experiences. People with visual, motor, or cognitive impairments depend on assistive tools like screen readers, switch controls, and magnifiers.

Common Accessibility Features in PDFs

• Tagged structure to maintain reading order
• Alternative text for images
• Logical use of headings
• Navigation bookmarks
• Searchable, text-based content (not just scanned images)

Visual Appearance vs. Functional Accessibility

Accessible documents look the same as regular ones, but their internal structure supports assistive technologies. Accessibility improves usability without affecting layout or design.

Updating Document Workflows

Organizations must update their document production and management workflows to prioritize accessibility.

Actionable Steps

• Use tools that support PDF/UA-compliant output
• Train staff in accessibility best practices
• Audit existing documents for compliance gaps
• Remediate non-compliant PDFs
• Test documents with real assistive technology

The European Accessibility Act extends digital accessibility requirements beyond websites to include all documents associated with covered services. PDFs, ebooks, and downloadable materials must comply with standards like WCAG 2.1 AA and PDF/UA. By incorporating EN 301 549 guidelines and updating document workflows, organizations can ensure accessibility, fulfill legal obligations, and promote digital equity for all users.

Let me be your champion for inclusion. I offer tailored solutions (and self-paced courses!) to ensure your documents meet and exceed compliance expectations. For more detailed insights, tutorials, and in-depth discussions on accessibility and related topics, don’t forget to check out my YouTube channel: The Accessibility Guy on YouTube. Subscribe for regular updates!