Sweden’s DOS Act and public-service PDFs

Sweden’s DOS Act applies to digital services provided by public actors. This includes more than central and local government; certain other organisations may also be covered. Check the statutory definitions for the organisation concerned.

The Act includes accessibility requirements and an accessibility statement with a feedback route. PDFs used in the digital service therefore need to be included in the organisation’s content assessment.

Sources: [1]

State and municipal authorities are included, as are municipal and regional decision-making assemblies. The Act also covers bodies governed by public law and certain associations. A body must meet the statutory conditions concerning needs in the general interest that are not industrial or commercial in character, together with public financing, control or board appointments; merely working with a municipality is not enough.

Certain private actors are also treated as public actors. These include specified professionally operated education, healthcare, dental-care and social-care activities receiving some public funding. There is also a provision for certain private higher-education providers with degree-awarding powers and predominantly state-grant funding.

Assess both the organisation and the particular service. The Act contains organisational and content exceptions. In education, for example, essential administrative functions matter to the scope of the exception. “We are an independent school” or “we are a limited company” does not settle the position of every published PDF.

Sources: [1]

Digg’s current guidance references EN 301 549 V3.2.1 and WCAG 2.1. For documents, translate requirements into assessable features: image alternatives, heading and table structure, meaningful reading order, contrast, language and working links or forms where present.

Saving with a “tagged PDF” option does not establish those properties. Ask the reviewer to describe both technical findings and user barriers. For an application attachment, a decisive task may be finding eligibility conditions, understanding the required information and reaching the submission link.

If both HTML and PDF are published, decide how the editions remain consistent. A better web page is often valuable, but an HTML alternative is not a general waiver for every PDF supplied alongside it.

Sources: [2]

The Act allows disproportionate-burden exceptions in certain circumstances. This requires a reasoned assessment; a large document collection is not a blanket exemption. Provisions for supplying accessible information on request can remain relevant even for exempt content.

Sources: [1]

The accessibility statement should reflect the service and its known limitations. A general ambition to “strive for accessibility” does not replace information about what fails. For documents, explain which material has problems and how people can obtain assistance.

Section 13 requires a way to report barriers and request accessible information. Barrier reports must receive a response as soon as possible. For the exceptions listed in section 15, a justified and reasonable request must be met without unnecessary delay. Someone whose such request is refused wholly or partly can request a written decision giving reasons.

This needs an operational process. Who reads the request? Who can obtain the source? Who decides whether to provide a repaired PDF, an accessible web page or another suitable format? Record the response and follow up the reported problem. Digg supervises compliance; responsibility for the service remains with its provider.

Sources: [1], [2]

The Swedish Parliament’s consolidated text can show both current and future provisions. This overview uses the rules in force at the source-check date, not an amendment that has yet to take effect. Technical requirements also need to be read alongside applicable regulations and standard references.