Creating accessible documents in Word and PowerPoint: the checklist

Why does an accessible PDF start in the Word or PowerPoint file?

An accessible PDF starts in the source file because the export can only carry over the structure that has been set up in Word or PowerPoint. EN 301 549 V3.2.1 requires authoring tools that convert content into another technology to preserve accessibility information in the output where the target format supports equivalent mechanisms (clause 11.8.3 with note 2). If a heading is not marked up as structure in the source file, there is nothing for the export to preserve. Corrections you make only in the PDF will be missing again after the next export from the source file.

The standard for accessible PDFs does not prescribe a production route either. ISO 14289-1:2014 (PDF/UA-1) specifies how ISO 32000-1:2008 is to be used for accessible electronic documents. According to the ISO abstract, specific processes for converting paper or electronic documents into the PDF/UA format are outside the scope of the standard.

Clause 10 of EN 301 549 applies to documents that are not web pages and are not embedded in web pages, expressly including documents provided for download (clause 10.0). Among its examples the standard lists letters, spreadsheets and presentations (clause 10.0, note 1). The requirements also apply to documents protected by a signature, encryption, password or watermark when they are presented to the user (note 7). Which benchmark applies legally is explained in the article PDF/UA, WCAG 2.1 and EN 301 549.

Whether a legal obligation applies to a particular file is determined by the laws, not by the standard. The cut-off dates for office file formats differ by jurisdiction:

• EU, public sector bodies: Directive (EU) 2016/2102 exempts office files published before 23 September 2018, unless they are needed for active administrative processes (Art. 1(4)(a)).
• Austria, federal level: the WZG contains the same exemption for federal bodies and federally related institutions (§ 2(3)(a) WZG). For the federal provinces and municipalities, the respective provincial laws apply.
• Germany, federal level: the BITV 2.0 has no such exemption. Of the exemptions in § 2(2) BITV 2.0, only the one for archives is linked to a date: it covers archives that contain no content needed for active administrative processes and have been neither updated nor revised after 23 September 2019 (§ 2(2) no. 2 BITV 2.0).
• Companies: the BFSG and BaFG do not apply to office files on websites and in apps published before 28 June 2025 (§ 1(4) no. 2 BFSG for Germany; § 2(3) no. 2 BaFG for Austria).

Who exactly is obliged is explained in the guide to obligations, deadlines and exemptions. The requirements of the standard lead to this working order:

1. Structure the source file: styles, lists, table headers, alternative text, title, language.
2. Run the program's built-in accessibility checker, if it has one. Where such a checking function detects a failure against clause 9 or 10, the standard requires the tool to offer repair suggestions (clause 11.8.4).
3. Export as a tagged PDF, with the option for structure information switched on.
4. Check the PDF with an automated tool.
5. Check the manual items.
6. Record the result and any open items.

The checklist: test items with WCAG criterion and EN 301 549 clause

The table maps 14 test items for Word and PowerPoint to the relevant WCAG 2.1 success criterion, its level and the clause of EN 301 549 V3.2.1. Level AA means that all Level A and AA criteria are met, or a conforming alternate version is provided (WCAG 2.1, conformance requirements).

The list is not exhaustive. Clause 10 contains further criteria, for example on media, keyboard operation and input assistance (clauses 10.1.2, 10.2.1, 10.3.3). For reflow, the standard exempts parts of the content that require a two-dimensional layout for usage or meaning. Its examples include presentations and data tables (clause 10.1.4.10 with note 2).

What does exporting as a tagged PDF achieve, and what remains manual work?

An export with the tagging option can only carry over the structure that is marked up in the source file; the quality of the content remains manual work. EN 301 549 requires authoring tools to enable and guide the creation of conforming content (clause 11.8.2). Where they provide templates, at least one of them must support conforming content and be identified as such (clause 11.8.5). These requirements concern the programs themselves. Whether a particular program meets them is not answered by the standard.

No export dialog decides these points for you:

• Whether an alternative text serves the same purpose as the image (1.1.1).
• Whether headings describe the topic or purpose (2.4.6).
• Whether the reading order follows the meaning (1.3.2), especially on slides with several text boxes.
• Whether changes of language are marked up (3.1.2). Some document technologies offer no way of doing this that is supported by assistive technologies (clause 10.3.1.2, note 1).
• Whether the tags in the PDF match the meaning of the content. The PAC publisher expressly names this question as a task for human review (FAQ).

Where a document contains its own non-standard structure types, the standard describes mapping them to standard structure types as best practice (clause 10.1.3.1, note).

How do you check the PDF automatically, and where are the limits?

An automated checker such as the PDF Accessibility Checker (PAC) shows whether the machine-testable requirements are met, nothing more. According to the publisher's FAQ, PAC supports both PDF/UA and WCAG. However, not all requirements of the two sets of rules can be checked automatically; additional checks by a person are always required. According to the FAQ, the test result is not legally binding but an indicator. Green ticks on the PDF/UA and WCAG tabs only mean that all automatically testable requirements are met.

Pay attention to the PDF version of your export. According to the FAQ, PAC currently processes files in PDF 2.0 format on a “best effort” basis; full support exists only for PDF 1.7. In some cases this can lead to errors or less reliable results. According to the publisher, full support for PDF 2.0 and PDF/UA-2 is planned; no date is known.

For confidential material, a further point from the FAQ is relevant: according to the publisher, PAC does not access the internet in any way.

Which items do you check by hand?

You check by hand everything that concerns meaning and relationships. Annex C of EN 301 549 specifies the test type “Inspection” for document criteria such as non-text content and info and relationships: the test is whether the document does not fail the relevant WCAG criterion (C.10.1.1.1, C.10.1.3.1).

1. Compare the heading structure in the tag tree with the visible document (1.3.1).
2. Go through the reading order with a read-aloud function or a screen reader (1.3.2).
3. Read the alternative texts: do they describe purpose and content (1.1.1)?
4. Check table headers and their association with the data cells (1.3.1).
5. Measure contrast with a contrast tool (1.4.3).
6. Reach links and form fields with the keyboard (2.1.1, clause 10.2.1.1).
7. Check title and language in the document properties (2.4.2, 3.1.1).

Which document failures do the monitoring bodies find?

The reports of the monitoring bodies show large gaps in PDF documents: in Berlin in 2024, only a small share of the tested PDFs passed the automated test, and in 2025 the FFG named missing or incorrect tags as a common failure.

Germany (State of Berlin)

In 2024, the monitoring body of the State of Berlin checked a total of 117 services of Berlin public bodies: 108 websites in simplified monitoring, 4 websites in in-depth monitoring and 5 apps. Of 114 tested PDF documents, 7 passed the automated test with PAC, a compliance rate of 6.1%. In 2023 the rate was 0% (88 documents), in 2022 it was 2.7% (73 documents). For the requirements from clauses 9 (web) and 11 (software, excluding 11.5 to 11.8) of EN 301 549, only 5 of 117 services met criterion 1.3.1 Info and Relationships in 2024 (4.3%).

Austria

In its 2025 interim monitoring report, the FFG lists untagged or incorrectly tagged PDF documents as a common failure under criterion 1.3.1: PDFs with no or an inadequate tag structure, that is without headings, lists and tables. As an extreme example it cites PDFs created from scans, which convey no structure information at all. Under criterion 2.1.1 it lists links and form elements in PDFs that cannot be reached by keyboard; for that, PDFs must be tagged correctly. In 52.5% of the accessibility statements checked, a disproportionate burden was claimed, several times on the grounds that PDF documents could not be published accessibly as standard. When this exemption holds is explained in the article on disproportionate burden.

How the bodies draw their samples is described in the article on monitoring by the monitoring bodies. If you need to convert a stock of Word, PowerPoint or PDF files, you can have accessible documents prepared by Compliance-Kit.