All individual citizens have the right to access all types of
government information; both in analog and digital form.
Barriers that prevent interaction with or access to digital
documents or websites can be considered as discrimination.
If a digitalt document cannot be read and navigated by everyone,
including individuals with vision impairments or other disabilities,
then it is not a digitally accessible document.
It is also not a useful document for everyone.
For a digital document to be useful for everyone
it is required that it is at least designed and published
as a digitally accessible document.
Sweden as a nation is bound by international and Swedish
regulations to ensure accessibility for everyone:
- the UN Declaration on Human Rights,
- the UN Convention on the Rights of Persons with Disabilities,
- the Swedish Anti-Discrimination Act,
- the Swedish Public Procurement Act,
- the Work Environment Act,
- the Swedish Language Act,
- the EU Web Accessibility Directive implemented as
the Swedish Act on Access to Digital Public Services,
SFS 2018:1937 & SFS 2018:1938.
Note! This Act also applies to older digital documents if they are
needed in order for the authority to be able to carry out its mission.
SFS2018-1938 says:
"2 § of the Act (2018:1937) on accessibility to digital public services
is not applicable to digital service consisting of
1.file format for documents published before
September 23, 2018, if such content is not needed for
to carry out the active administrative procedures which
follows from the relevant public actor's charter,..."
In addition,
according to the Digital Administration Authority's (DIGG's) interpretation:
"Regardless of whether there is an accessible alternative in the form of an
e-service documents used in the business shall comply with
the requirements for accessibility."
- Upcoming: The European Accessibility Act (2025)
Declarations, conventions, directives and acts that are technology-neutral.
Swedish authorities are thus since long bound to comply with
and apply these regulations in their daily operations.
Authorities are also in the role of employer responsible for that
employee work material is accessible and well functioning.
What is Digital Accessibility?
Digital accessibility means complete barrier-free access to
all information available through a computer or mobile device.
So whether it is a website, mobile app, webinar or a document,
everything should be accessible for everyone.
PDF vs Web - Key Differences to Consider
Today HTML-based web pages are more capable and dynamic than ever,
but they are no more "documents" than they were when
the World Wide Web was launched back in 1990s.
Since the launch of the Portable Document Format (PDF) in 1993,
the usage of PDF and the number of PDF applications continue to grow.
That’s because PDF technology; as a self-contained,
reliable and flexible portable document format,
is key to digital transformation.
PDF does what other web technologies do not.
Accordingly, PDF does not compete with HTML;
PDF complements HTML.
W3C/WCAG is a wide range of recommendations for
making web content more accessible for everyone.
W3C/WCAG is technically neutral, and generally deals with web content;
WCAG does not directly address offline documents, making direct
application of WCAG rules and techniques on PDF less obvious.
As WCAG is fundamentally oriented towards web content rather than
web-independent content, WCAG can be difficult to apply to PDF,
so it's useful to begin by reviewing fundamental distinctions:
- A website generally consists of one or more webpages consisting of
multiple HTML files, CSS, database entries, scripts and other sources.
Although links facilitate presentation of webpages as part of a
whole body of content, each webpage is an independent entity
defined by its URI.
- A PDF document, by contrast, is a single file containing from
one page to thousands (or even millions) of pages of
text, graphics, annotations and other content.
Can a PDF be Accessible for Everyone?
Yes, of course!
- A fully PDF/UA compliant PDF can be just as
accessible as a WCAG compliant website!
File type techniques like PDF and HTML are not by default accessible.
A PDF can be made an accessible PDF,
just like an HTML-based web page can be made accessible.
The reality is that accessibility is not dependent on the file type,
but the work done to make it accessible.
Neither PDF documents nor HTML pages become accessible
because of their ability to become accessible.
They become accessible because of the trained work put into it.
An HTML page without that work is inaccessible regardless of its capability.
Of course so is PDF.
The PDF specification provides robust support for accessibility.
The accessibility of any individual PDF file depends on
how well the author prepared the file for accessibility.
The accessibility of the experience for the end user depends on
how well the PDF viewer application supports
the accessibility features in the specification.
Achieving accessible PDF or accessible HTML
typically requires special tools and skills;
see more below.
PDF is since 2012 adopted to support digital public services
PDF has since 1993 served many millions of users and businesses
as the globally preferred digital document format.
The PDF technology is today even more developed and is since 2012 adopted to
also meet today's requirements for accessibility for all to digital public services;
see more under "Accessible PDF" below.
Right now, the reliability and robustness of PDF technology,
based on a fixed layout page-description model, is merged with
the agility, flexibility and elegance of Web and HTML technologies;
in order to provide the best possible user experience
(such as support for reflow) on each type of device and use case.
What is Accessible PDF?
A digital or electronic media, that is available on computer screens,
on mobile devices, or other assistive technologies,
is accessible when it is easily opened, read, understood and
can be navigated by everyone, with or without disabilities.
The aim of a barrier-free and accessible PDF document
is to ensure that all users, regardless of their personal limitations,
have equal access to the content of the PDF document
(possibly with the support of assistive technology),
and have equal opportunity to act on it and make own decisions
without the help or participation of others.
Barrier-free access and accessible PDF content is all about
universal design; i.e. accessibility through design.
Good design for digital accessibility for everyone ensures
no subsequent adjustment is required for the needs of
a specific target group of individuals.
Note!
The tricky thing about digitally accessible and inaccessible
PDF documents is that they, in most cases, look the same.
In other words, they are often visually identical.
Therefore, it’s almost impossible for most users to tell
whether the PDF they are looking at is accessible
by merely looking at their physical view.
WCAG's recommendations on accessibility for everyone to digital
web content emphesizes the need good visual and editorial web design.
However, digitally accessible PDF (according to PDF/UA) is not about
visual appearance or editorial design, but about applying digital
accessibility standards to define an internal technical description of
the contents of the PDF document so that accessibility devices can
accurately manage, navigate, and reproduce the content.
Digital Accessibility Standards.
Compliance with WCAG is required for
all content on accessible websites.
For PDF documents,
compliance with the ISO Standard PDF/UA is also required.
The overall purpose of the WCAG recommendations and
the PDF/UA standard respectively is to facilitate the creation of
digitally accessible web pages and PDF documents.
Websites are technically built with HTML and CSS code supplemented
with digital information content of mainly these media components:
- text
- pictures
- sound
- video
- documents and presentation slides, and
- graphic illustrations
Regardless of technology (web/HTML, text, .png, .jpeg, mp4, PDF, .docx, .key,...)
used to publish a digital web-based service, the media type used must be
published in a form that it is accessible for everyone in the community.
Website owners often refer to:
- "We focus on making the HTML-based content accessible".
- "We prioritize our regular business"
- "To make the website accessible, including all documents,
requires too much time and work/unreasonably burdensome,
and we don't have the budget for that"
- "We have no disabled visitors on our website"
- "We intend to do that when we rebuild our website next time
(ie, at some unspecified time far into the future)"
However, according to the EU's Web Accessibility Directive,
which is technology neutral, that is no longer a valid excuse.
The website owner cannot continue to publish inaccessible
PDF documents.
DIGG states that "unreasonably burdensome" is an exception provision;
i.e. an unacceptable reason for an authority not to accessibility adapt
the authority's inaccessible documents.
To ensure unrestricted access to PDF-based information in
every respect, PDF files must meet certain requirements.
This also applies to cases where website content
(such as web pages, articles, blogs, etc.)
is converted to PDF that in turn is
published or shared with others.
Accessibility standards ensure that even PDF documents
work well with screen readers and other assistive technology.
For a PDF to be considered digitally accessible it shall at least
be compliant with the digital accessibility standard ISO PDF/UA and
applicable parts of the W3C/WCAG 2.x AA recommendations,
(and in the USA, ADA and Section 508).
For files based on PDF-technology,
universal accessibility requirements are since 2012 defined by:
Successful e-government presupposes that all
digital government information is accessible for all citizens
- the success is dependent on "Accessible PDF":
WCAG and PDF/UA complement each other.
The Web Content Accessibility Guidelines (WCAG)
are the internationally recognized guidelines for accessible web.
Many national or supranational regulations (eg at EU level)
on the accessibility of web sites refer to WCAG.
The WCAG recommendations emphesize good visual and editorial web design.
All information on a website must be accessible for everyone based on
four main principles which state that content must be "POUR":
- Perceivable,
- Operable,
- Understandable, and
- Robust
PDF/UA is a required complement, not an alternative, to WCAG.
PDF/UA is consistent with WCAG, but far more technically specific,
and provides a clear-cut means of affirming that a given
PDF document meets high standards for digital accessibility.
Compliance with PDF/UA is important for digital accessibility for everyone.
PDF/UA defines the technical requirements that must be considered
when a PDF document must be universally accessible for everyone;
with or without disabilities.
The PDF/UA standard specifies HOW relevant PDF content
(such as semantic content, text content, images,
form fields, comments, bookmarks, and metadata)
shall be used in PDF/UA compliant documents.
Properly tagged ("well-tagged") PDFs are essential and
a prerequisite for accessibility so that screen reader devices
for visually impaired people or reading software for
users with learning disabilities can provide
rich access to a PDF’s content.
PDF tags are also an effective method to improve
Search Engine Optimization (SEO).
Even automated extraction of information/text content from
PDF documents is easier to execute with well-tagged PDF:
Inaccessible PDF vs Accessible PDF
Relations and dependencies between
PDF, PDF/UA, WCAG, Usability and Accessibility / Accessible PDF.
To meet PDF accessibility requirements is like a "mountaineering expedition".
The reach of a camp builds on the reach of all previous camps.
The route goes from PDF (Camp 1), via PDF/Universal Accessibility (Camp 2),
Relevent Accessibility Parts of WCAG (Camp 3), and PDF Usability (Camp 4),
to the mountain top, a PDF that is Usable and Accessible for All Users:
- Camp 4: Usability
- Camp 3: WCAG - Web Content Accessibility Guidelines, ISO 40500
- Camp 2: PDF/UA - Universally Accessible PDF, ISO 14289
- Camp 1: PDF - Portable Document Format, ISO 32000
PDF documents complying with PDF/UA
are universally accessible for everyone.
In order to create a document that is as accessible as possible to everyone,
one needs to focus on all potential user groups and their needs.
One should never succumb to the temptation to optimize a
PDF document for a specific user group.
The consequence of this could be that such a document is then
very readily consumable for this one group of users,
but may be more disadvantageous than beneficial for others.
Important!
How well a PDF document is "accessible for everyone"
depends on how the document is created.
The level of accessibility according to current accessibility standards
is determined by both the execution of the editorial content of
the document AND of its internal technical structure.
Often, this insight is neglected by many, which can lead to significant
problems when it comes to fixing inaccessible documents.
Digital documents provided for download on a web site are
also covered by WCAG per se and must meet the applicable
success criteria to comply with WCAG (Level A, AA or AAA).
It is definitely best to first conduct an editorial accessibility check of
the design and content according to the WCAG recommendations.
The editorial content of the PDF document must be WCAG compliant
before it is tested with respect to PDF/UA, the technical requirements
for "accessible PDF".
But, WCAG's recommendations alone are not enough
to make a universally accessible PDF.
Note!
For the technical implementation of accessible PDF,
compliance with the ISO Standard PDF/UA is also a requirement;
a PDF file can be compliant both with WCAG and PDF/UA.
A fully PDF/UA compliant PDF can be just as
accessible as a WCAG compliant website.
A successful validation of a PDF document for compliance with
PDF/UA and WCAG 2.x AA, always requires the PDF document
to pass at least two stages of validation before it is
published or shared with others:
- a programmatic syntax test,
which can be performed by a trusted software, and
- an interactive semantic test,
manually carried out by a human.
Successful barrier-free access to content within PDF documents
depends not just on PDF/UA compliant documents, but also on
requirements for PDF/UA compliant programs and assistive technology:
- a PDF/UA compliant document
(according to standards and guidelines),
- a PDF/UA compliant display or processing program,
- a PDF/UA compliant assistive technology,
(such as a "PDF/UA-Ready" screen reader)
Please be aware:
W3C/WCAG clearly says:
Organizations requiring all web content to only use
W3C’s published techniques are wrong!
"W3C recommends that the only thing that is required
is meeting the WCAG 2.x success criteria."
"The basis for determining conformance to WCAG 2.x is
the success criteria from the WCAG 2.x standard - not the techniques."
"W3C’s Techniques for WCAG 2.x document is informative
(that is, not required, non-normative)."
Thus, it is not the assistive technologies, nor popular software tools such as:
MS Office, Adobe InDesign, Adobe Acrobat, Google Docs, Apple iWork,...
that define what is an accessible web or an accessible PDF.
Never adapt PDF documents to a specific assistive technology or software.
Instead, always adapt PDF documents to its digital accessibility standard:
All you have to do is to create ONE version of a PDF/UA compliant document,
and the manufacturers of the relevant programs and assistive technologies are
in turn responsible for complying with this global digital accessibility standard.
This results in ONE PDF:
that anyone can use,
regardless of functional ability and/or need for
special technical aids to be able to consume
the content and navigating the information, and
over time you only need to maintain/update ONE document,
instead of many different variants of the same document,
which in turn saves many working hours.
- Furthermore, WCAG and PDF/UA are entirely complementary:
- WCAG provides requirements regarding content accessibility;
- PDF/UA provide requirements
that ensure accessibility in the PDF context.
The best practice for document authors
producing accessible PDF files is to:
- consider WCAG’s requirements
when designing and creating content;
- use software capable of meeting
PDF/UA requirements to produce the PDF files.
Barrier-free also means multi-channel-capable
The demand for universally accessible information
is not restricted to the needs of disabled individuals.
Content now must also be generated and
made available as intelligently as possible.
That also includes the language
(comprehensibility, syntax, multilingualism).
In other words, the demand is also for documents with meaningful data
that can be extracted and linked as desired, for example to conduct
highly complex and targeted information research:
PDF on Mobile Devices / Small Screens
Based on the premise of a fixed layout, the PDF page-description model
was developed during a time where documents were exclusively viewed
on desktop monitors, or printed.
Recent years advent of much smaller screens, and screens of many sizes,
presents a variety of challenges and opportunities in the PDF paradigm.
The global IT industry and the global PDF industry are now, as we speak,
implementing innovative solutions (like the Adobe Liquid Mode for Acrobat Mobile)
to accommodate this challenge:
Interesting?
