Accessible PDFs
Since 2018, PDFs and other non-HTML content have been effectively outlawed online by public sector accessibility guidance.
PDF problems
PDFs and other non-HTML formats have been more or less outlawed online by public sector accessibility guidance since 2018.
There are lots of reasons for this, but the main issue is that PDFs can lock some users out of some or all of your content, especially people who use assistive technologies, like screen readers, to browse the web.
Public sector bodies shouldn't publish content in PDFs unless there's a specific user need for it.
Here's our list of PDF problems - some of which are outlined in the NHS Digital Service Manual:
PDFs cannot meet the full range of users' accessibility needs, for example, users cannot change colours, font size or translate into different languages
PDFs often give users a poor experience, especially on mobile devices
many browsers, tools and extensions do not work with PDFs – which can cause problems with zoom, scroll, audio, image and keyboard navigation
PDFs can make it more difficult for users to navigate to the rest of your website
PDFs can take users away from your website, opening in a new tab, window or software
it's sometimes hard to copy or share information from a PDF
sometimes users are forced to download PDFs to their device storage, instead of reading them online
some PDFs are poorly optimised and have an unreasonable file size, which can discourage users with limited data
Not all users have the right software to open PDFs
PDFs are hard to maintain and update, so users may get out of date and unreliable information
PDFs found in search results often come without any supporting context or material, such as who the publisher is
search engines often do not rank PDFs as highly in search results as HTML pages
it's difficult to collect data on how people use PDFs, and that makes it harder to identify problems and improve them
User rights are protected in law by the Equality Act. Government Digital Service (GDS) auditors actively check public sector websites for non-compliant PDFs.
You may be asked to make improvements, replace or delete PDFs if they find non-compliant content.
New PDFs
Any new PDF you create and publish online will be subject to accessibility regulations.
If you can't avoid creating a new PDF, it must meet World Content Accessibility Guidance (WCAG) standards to AA level.
Your PDF must have:
a logical structure based on tags and headings
meaningful document properties, for example, a descriptive title for assistive technology
readable body text
strong colour contrast
text alternative for images
If you follow the gov.uk guidance for publishing accessible documents and save it in PDF/A (archiving) format, it is possible for it to meet the relevant standards.
However, there is still no guarantee that your PDF will meet the accessibility needs of all your users.
There are rare cases where you might need a PDF, such as:
for niche audiences, where there is a clear user need for special formats (like Easy Read or foreign language leaflets designed to be printed out)
for other downloads designed for printing, such as posters
downloads of reports or publications designed to be published on paper
where there's a legal or regulatory requirement to have a formal, signed document
to preserve a permanent record for the future
In these cases, best practice is to provide a HTML version of the document alongside it.
We always recommend publishing new content in structured HTML web pages, which meet the highest standards of accessibility and are generally more cost effective to update should there be any issues in the future.
Existing PDFs
PDFs created before 23 September 2018 are not subject to accessibility regulations, as long as you don't use them for business processes or essential services.
Any PDFs that your organisation has published or still uses for business processes since 23 September 2018, are subject to the regulations. Most public sector bodies have a large quantity of non-compliant PDFs published since the regulations came into force.
In these cases, the guidance asks you to:
replace them with a HTML web page: or
publish a HTML alternative; or
remove the PDF
It is possible to edit your PDFs to comply with accessibility regulations. Sometimes it's easier and more cost effective to create a new version of your document in structured HTML web pages - and in almost all cases this approach will be better for your audience.
Get help
New and existing PDFs, especially in large public sector bodies, may be the biggest hurdle you face when working towards better compliance.
Editing PDFs to comply with accessibility regulations can be complicated and time consuming.
Our accessibility experts can help you understand and overcome these issues. We can:
audit and diagnose accessibility problems in your PDFs or other non-HTML documents (Powerpoint, Word etc).
edit your PDFs to make them accessible
translate your documents to structured HTML webpages, meeting the highest accessibility standards
help refine your processes and develop your team so that you can meet a higher standard of accessibility now and into the future.
