PDFs in the UK public sector

GOV.UK guidance addresses the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018. It specifies WCAG 2.2 AA and a published accessibility statement. These rules sit alongside existing Equality Act obligations and Northern Ireland disability discrimination legislation.

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A public body needs to assess documents forming part of its website even when a consultant wrote or designed them. Outsourcing does not automatically transfer responsibility for publication. Specify accessibility requirements before delivery and agree how defects will be corrected.

The regulations include organisational and partial exemptions. GOV.UK describes particular arrangements for schools and nurseries, while content needed to use their services remains important. Labelling a file “school material” therefore does not create a general exception for every document.

Start by identifying the provider, the service and the task the reader needs to perform. That assessment precedes technical examination of the PDF.

Certain older PDFs may be exempt, but age alone is insufficient when a document is needed to use a service. A form still required for a service therefore needs specific assessment.

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Disproportionate burden is a qualified provision requiring an actual assessment. GOV.UK identifies factors including resources, cost and benefits to disabled users. Lack of time or knowledge is not sufficient by itself, and changed circumstances require reassessment.

For a PDF archive, base that assessment on the material. How many files exist, what do they contain and which support current services? A large total says little about the cost of repairing the handful essential to an application. Low download numbers also do not establish that a document is unimportant to someone who needs it.

Keep an exemption assessment separate from work prioritisation. Planning a repair in three months does not automatically exempt the document today. Record real defects and relevant exceptions in the accessibility statement and provide a working route to request usable information.

Suppose a family needs an older form to provide dietary requirements. Start with the task: can they find, understand and submit the information? An old folder location does not answer that question. Also map how someone requests an accessible alternative.

Identify whether the customer is a public sector body and which documents are included. Separate the legal assessment from the tests the supplier must perform. This overview does not address every private business obligation or every regulatory exception.

A useful commission can identify a report series, specify WCAG 2.2 AA according to current guidance, and request content review plus documented testing. List tables, charts, forms and languages so the supplier can scope the work.

Request a delivery record understandable without specialist knowledge: what worked, what failed, what changed and what remains? That supports statement updates and responses to readers. A technical report can be attached, but should not be the only explanation.