What guidelines are there for an accessible PDF?

Important note if you use the testing tool PAC 2024 already know and use: Just because the PAC2024 Checker delivers a positive test result does not mean that your PDF document is barrier-free according to legal requirements!

In the previous post you learned what an accessible PDF actually is. So that you can later create and/or check an accessible PDF properly, you should first familiarize yourself with the accessibility requirements. There are many different requirements for accessible PDFs in German-speaking countries. Some of them are binding, some are not. And then an initially non-binding requirement (e.g. standard EN 301 549) can of course also become binding if it is referenced in legal acts (e.g. BITV2.0). This often raises the question of what is actually valid and relevant.

In this article you will learn:

• what requirements there are
• how all these requirements are related,
• which specifications are relevant for you, or which criteria your PDF documents must meet, and
• how to check as efficiently as possible whether your documents comply with the requirements

Time pressure? Simply use the table of contents to jump directly to the section “How can the relevant requirements be checked efficiently?”. This way you won’t get all the details, but you will get the most important information in the shortest possible time.

specifications

Before the interrelationships between all specifications are presented, the general contents of the specifications are first explained.

 

SUPPLEMENT: (EU) 2019/882

The (EU) 2019/882 is a guideline for the “accessibility requirements for products and services” which was published in 2019. In Germany, for example, it is implemented via the Accessibility Strengthening Act which comes into force on June 28, 2025. The EU directive and the derived national laws further tighten the scope of the existing requirements and also introduce new/increased penalties. It is therefore all the more important that the following requirements are observed.

 

(EU) 2016/2102

What is (EU) 2016/2102?

The (EU) 2016/2102 is a directive "on the accessibility of websites and mobile applications of public sector bodies", which was published in 2016. As an EU directive, it obliges EU member states in Article 12 paragraph 1 to "bring into force the necessary laws, regulations and administrative provisions" to meet the requirements of the directive. The deadline for implementation was September 23, 2018, and since June 23, 2021, all requirements of the directive must be met (Article 12 paragraph 3). It is also important to know that Article 8 of the directive obliges member states to monitor and report. This means that websites and mobile applications of public sector bodies are actually checked.

Summary: The directive sets minimum requirements for accessibility in digital areas at the overarching EU level. These requirements must therefore be met by all EU member states at a minimum.

 

scope

Article 1 paragraph 2 defines the scope of application to websites and mobile applications of the public bodies of the EU member states. Documents are to be seen as the content of websites. The term "public bodies" is precisely defined in Article 3 number 1.

Non-governmental organisations are explicitly excluded from the scope of application in Article 1 paragraph 3 letter b) provided that they do not "provide services that are essential to the public or services specifically addressed to or designed for the needs of people with disabilities". In Article 1 paragraph 5, the directive also gives EU member states the option of excluding "schools, kindergartens or crèches from the scope of application".

Summary: In the EU member states, the directive applies to websites and mobile applications of public bodies (with the exception of a few institutions) and thus to the lowest level of the administrative structure (in Germany, for example, municipalities). Institutions under public law, such as local health insurance funds and chambers of commerce, are also considered public bodies.

 

Requirements regarding PDF documents

(EU) 2016/2102 sets a minimum level of accessibility requirements. Article 4 stipulates that "public sector bodies shall take the necessary measures to make their websites and mobile applications more accessible by making them perceptible, operable, understandable and robust". The terms "perceptible", "operable", "understandable" and "robust" are the four basic principles for web accessibility worldwide. However, the basic principles alone cannot be objectively verified. Article 6 therefore specifies that the requirements of Article 4 (and thus also the basic principles) are deemed to be met if the criteria of the harmonized standard EN 301 549 are met.

Summary: PDF documents must comply with the requirements of EN 301 549 in order to meet the requirements of the directive

 

EN 301 549

What is EN 301 549?

The EN 301 549 is a harmonized European standard for the accessibility requirements for information and communication technology (ICT) products and services, which was published in its first version in 2014. The standard is referenced by the (EU) 2016/2102 Directive. The accessibility requirements of the directive are considered to be met if the standard is complied with.

 

scope

Since a standard itself is not binding, it cannot force countries or parts of an administrative structure to comply. However, if it is referenced by other directives (as is the case in EU 2016/2102) and compliance with the standard is required in those directives, then the standard is binding indirectly via such directives.
The scope of the standard is limited to ICT products and services. Clause 1 specifies that the standard applies to both web-based and non-web-based technologies, software, hardware and services. There are separate clauses in the standard for the different types of ICT products and services.

Summary: The standard is relevant for ICT products and services.

 

Requirements regarding PDF documents

The basis of the document is clause 4. For groups of people with disabilities, this clause derives functionality requirements (e.g. "use without sight"). These requirements serve to ensure that the affected groups of people can find, identify and use functions of ICT products and services despite their limitations. All subsequent clauses of the standard are based on the needs of the users, which lead to the functionality requirements (e.g. perceiving content without sight).

According to clause 3.1, PDF documents are non-web documents. Clause 10 deals exclusively with this type of document. The requirements of clause 10 are therefore relevant for PDF documents. It is structured according to the basic principles (mentioned in EU 2016/2102) of “perceivable”, “operable”, “understandable” and “robust” and also according to the guidelines that are derived from the basic principles. The guidelines in turn contain the testable success criteria. It should be noted that the clause is almost exclusively based on the testable success criteria of the Web Content Accessibility Guidelines (WCAG) (it also has two criteria of its own for subtitles and audio, which are generally irrelevant for PDF documents). If the criteria for PDF documents are met, these documents conform to the standard.

Summary: PDF documents must meet the criteria of clause 10 and thus also partially meet the criteria of the WCAG in order to be compliant with the standard.

 

 

WCAG

What is WCAG?

The WCAG is a guideline for accessible web content, the first version of which was published in 1999. It is regularly updated and is currently available in version 2.2. Since the guideline was World Wide Web Consortium (W3C) and was not created by a legislative body, it is not binding in itself. However, it should be noted that the directive (currently version 2.1) is referenced in EN 301 549, for example, and that due to this reference, certain contents must be complied with.

 

scope

The WCAG applies to web content on desktop PCs, laptops, tablets and mobile devices. However, it should be noted that other regulations, laws, standards, etc. can also refer to the WCAG for non-web documents (e.g. PDF documents). This means that certain contents of the WCAG also apply to non-web documents. In EN 301 549, for example, the WCAG is referenced in the clause for non-web documents. The background to this is that PDF documents (and other non-web documents) can often be downloaded from websites. And since such documents are usually part of the content of the website, accessibility requirements are also set for these documents.

Summary: The guideline is designed for web content, but it is also referenced by other norms and standards for non-web documents.

 

Requirements regarding PDF documents

Like clause 10 of EN 301 549, the WCAG is also divided into the four basic principles of "perceivable", "operable", "understandable" and "robust" (the European standard has adopted the structure of the WCAG here). These principles each contain 12 guidelines that serve to ensure that the principles are met. To ensure that the guidelines can be objectively tested, they in turn contain testable success criteria.

Clause 10 of EN 301 549 defines exactly which WCAG success criteria are relevant. These must then be fulfilled, as they are the prerequisite for conformity with EN 301 549. Since the list of criteria is relatively long, reference is made here to Clause 10 of EN 301 549.

Summary: PDF documents must meet all WCAG success criteria as listed in clause 10 of EN 301 549.

 

DIN ISO 14289-1

The (DIN) ISO 14289-1 is an international standard, the first version of which was published in 2012. It describes "how electronic documents can be represented in PDF format in such a way that the file is accessible without barriers". PDF documents that meet this standard are also referred to as PDF/UA compliant.

 

scope

Compliance with the standard (like any other standard), whether international or not, is initially voluntary. Legal bindingness is only achieved if laws or regulations refer to the standards. However, compliance with a standard can of course also be agreed between contractual partners. In practice, the PDF/UA standard is now so widespread that it is applied even without laws, regulations or contracts and barrier-free documents are almost only accepted if they conform to PDF/UA.

Summary: The standard was created explicitly for accessible PDF documents and compliance with the standard is assumed in common practice.

 

Requirements

Clause 7 lists specific technical “requirements for the file format”. If these requirements are met, a PDF document is standard-compliant / PDF/UA compliant.

 

connections

Now that you have become familiar with the individual requirements, we can take a closer look at the connections.

As you can see from the graphic above, the directive (EU) 2016/2102 the overarching legal act for the German-speaking area. This directive itself does not contain any requirements for accessible documents, but references the harmonized European standard EN 301 549EN 301 549 therefore represents the minimum requirements for the scope of the directive.

As an EU directive, the requirements of the directive are incorporated into the national legislation of Germany (BITV2.0) and Austria (WZG) and therefore these two countries automatically reference EN 301 549. In this case, the EN 301 549 standard is not explicitly referenced, but rather generally harmonized standards to which EN 301 549 belongs. For so-called “non-web documents”, including PDF documents, EN 301 549 almost always refers to parts of the WCAG 2.1.

Since Switzerland is not part of the EU, it is not obliged to implement the requirements of the EU Directive in national legislation. Nevertheless, a standard has been established in Switzerland (eCH-0059) which does not reference EN 301 549, but also WCAG 2.1.

In none of the German-speaking countries is the ISO 14289-1 referenced in the legal regulations. In common practice, however, compliance with the standard is expected when talking about accessible PDF documents. The reason for this may be that it is technically much more specific than all other specifications and thus testing for accessibility is much more objective.

Summary: Finally, all German-speaking countries indirectly reference parts of WCAG 2.1 in the current legislation and standards in connection with PDF documents. In addition, compliance with ISO 14289-1 for accessible PDF documents is common practice and expected.

 

What requirements must be met for an accessible PDF?

In Germany and Austria, the requirements of clause 10 of EN 301 549 and the requirements of clause 7 of ISO 14289-1 must be met for accessible PDF documents. However, since clause 10 of EN 301 549 refers almost exclusively to parts of WCAG 2.1, In the end, WCAG 2.1 and ISO 14289-1 are relevant, which also applies to Switzerland.

Fortunately, the criteria of WCAG and ISO 14289-1 overlap, so it makes sense to first compare the two guidelines.

 

Difference between WCAG and ISO 14289-1 (PDF/UA)

The WCAG is primarily intended for web content and is therefore not designed purely for PDF documents. However, it does contain specific requirements/instructions that PDF documents must comply with. However, the requirements are not yet technically implemented. An example of this is the requirement for alternative texts:

"All non-text content presented to the user has a text alternative that serves an equivalent purpose, except as set out below."

With this requirement, there would now be various correct options for technical implementation, but a unified implementation should always be sought.

ISO 14289-1 (PDF/UA), on the other hand, contains information on uniform technical implementation and was created specifically for accessible PDF documents. Where the WCAG only specifies that alternative text is required, the ISO standard for graphics specifies, for example:

“In contrast to text objects, graphic objects must be tagged with a figure tag […], figure tags must contain an alternative representation or replacement text that represents the content marked with the figure tag […]”

In terms of content, the PDF/UA standard is technically more precise and clear. However, the ISO standard covers most of the WCAG criteria, but not all of them. In the past, the AIIM US Committee has PDF/UA standard compared with WCAG 2.0 and found that the following WCAG 2.0 criteria are not covered by the ISO standard:

It should also be noted that with the new version of WCAG 2.1, further criteria have been added, which have also been adopted into EN 301 549 and must therefore be met:

In summary, this means that if your document already meets the requirements of ISO 14289-1, you must also check the following WCAG criteria that are not covered:

How can the relevant requirements be checked efficiently?

Manually checking a PDF document for the aforementioned requirements is extremely time-consuming. For this reason, various organizations have provided tools to facilitate the checking and thus the adaptation of accessibility standards.

 

Matterhorn Protocol

The Matterhorn Protocol is a list of all error conditions that lead to non-compliance with the ISO 14289-1 standard. If none of the error conditions apply to a PDF document, it is PDF-UA compliant.

A major advantage of the protocol is that it differentiates between error conditions that can be checked by machine (M) and those that require human checking (H). The protocol thus serves as a basis for automated checking software that can assess the criteria that can be checked by machine. One well-known software is the PDF Accessibility Checker PAC2024.

 

PAC 2024

The PAC 2024 is a software that supports the checking of PDF documents for accessibility. PAC stands for PDF Accessibility Checker. Compared to its predecessor PAC2021, the PAC2024 also carries out quality checks, which should simplify the manual checking of the (H) error conditions somewhat. This makes the tool extremely helpful for checking both PDF/UA and EN 301 549 conformity. If the PAC2024 shows that all machine-checkable criteria are met, the PDF documents (with the support of the tool) only need to be checked for the (H) error conditions of the Matterhorn protocol and the extended WCAG criteria.

Of the additional WCAG criteria mentioned above, PAC2024 covers the following criteria:

So the criteria that remain are:

For checking a PDF document in German-speaking countries, this means that if a document:

• successfully passed the PAC2024 review process,
• no (H) criteria of the Matterhorn Protocol apply to the document anymore and
• the WCAG remaining criteria from Table T5 are met,

The document complies with ISO 14289-1 and EN 301 549 and therefore meets all the requirements for an accessible document.

You now know which guidelines you must follow when creating accessible PDFs. Now take a look at which software you need to create it.