The EU Web Accessibility Directive and PDFs

The Web Accessibility Directive underpins national rules for public sector websites and mobile apps. Its scope reaches beyond the home page: documents used in a service also need assessment. It includes provisions for accessibility statements, feedback and monitoring.

Sources: [1]

A directive sets an outcome for Member States and is implemented through national rules. The Web Accessibility Directive supplies a shared foundation; a Swedish document owner also needs the DOS Act and its supporting rules. Those make national scope, supervision and requests for accessible information concrete.

The main group consists of public sector bodies: the state, regional and local authorities, and certain bodies governed by public law and associations. An organisation’s name alone does not determine coverage. Publicly controlled or financed organisations need assessment against the definitions and national legislation.

For PDF work, publication context matters. A PDF forming part of an authority’s website belongs in the content assessment. An outside supplier’s involvement does not automatically make it exempt third-party content; the conditions for that exception need separate consideration.

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For each PDF, record the publisher, location, publication date and purpose. Distinguish a historical report from a form needed to apply for support today. An old publication date alone does not determine whether a document is exempt.

Article 1(4)(a) addresses office file formats published before 23 September 2018. It does not exempt content needed for active administrative processes relating to the public body’s tasks. PDF is among the relevant formats. Age is therefore a condition to investigate, not the whole assessment.

Imagine an old report about a completed municipal project and an equally old attachment still required with an application. The report may be historical material; the attachment may be essential to a process used today. Putting them in the same folder does not change their different functions.

A separate exception concerns archived websites under specified conditions. Calling a folder “Archive” does not automatically satisfy those conditions. Nor does “old PDF” mean the same thing under every accessibility law: EAA document transitions use other dates and conditions. Keep the regimes separate during inventory.

Sources: [2]

Use the inventory as an editorial working record. Identify owner, version, publication location and the tasks readers must complete. Separate legally exempt documents from covered documents awaiting repair. A place in the work queue does not create an exemption.

Also decide who handles feedback. Someone unable to use a form needs a workable next step, rather than repeated referrals between web staff, communications and a supplier. Clear ownership and a documented response process turn the duties into daily practice.

• Identify the national law and supervisory authority.
• Record the reasons for any claimed exception.
• Prioritise documents people need for current services.
• Make the statement and feedback route reflect the actual barriers.