Accessible PDFs and documents: obligations, deadlines and exceptions for public bodies and companies

Are PDFs and office documents part of an accessible website?

Yes, unless an exemption applies. Downloadable documents are legally part of the website and are subject to the same accessibility requirements as the web pages themselves. Directive (EU) 2016/2102 expressly counts downloadable documents and forms as content of websites and mobile applications (Recital 19).

Recital 26 explains what office file formats are: documents that are not primarily intended for use on the web and that are included in web pages, such as PDF, Microsoft Office documents or their open source equivalents. The Styrian Web-Zugangs-Gesetz adopts the first part of this definition without the format examples (§ 2 no. 3 StWZG).

Germany

§ 2a(1) BITV 2.0 states it in so many words: integrated content in different formats, for example documents, videos and audio files, forms part of websites. The same applies to mobile applications (§ 2a(2)) and to electronically supported administrative processes, including electronic record keeping (§ 2a(3) and (5) BITV 2.0).

Austria

The WZG (Web-Zugänglichkeits-Gesetz) exempts files in office formats only if they were published before 23 September 2018 and their content is not needed for ongoing administrative procedures (§ 2(3)(a) WZG). PDFs and office files published later are therefore subject to the requirements of § 3 WZG, unless another exemption under § 2(3) WZG applies, for example for archives (§ 2(3)(i)) or for content where compliance would impose a disproportionate burden (§ 2(3)(j)). The state laws cited here contain the same exemption for older office files (see the table below).

Technically, the standard EN 301 549 V3.2.1 draws a distinction: clause 10 applies to documents that are provided with web pages but are neither embedded in them nor rendered together with them, in other words downloadable documents. For documents that are embedded in web pages and rendered with them, clause 9 applies (clause 10.0).

Who is obliged to provide accessible documents?

Public sector bodies are obliged under the laws transposing Directive (EU) 2016/2102, and companies under the laws transposing the European Accessibility Act for products and services after 28 June 2025. Public sector bodies are the State, regional or local authorities, bodies governed by public law and associations formed by one or more such authorities or bodies, provided those associations were established for the specific purpose of meeting needs in the general interest, not having an industrial or commercial character (Art. 3(1) Directive 2016/2102). Excluded are websites and apps of public service broadcasters and of NGOs that provide neither services essential to the public nor services specifically addressing the needs of persons with disabilities (Art. 1(3)).

Austria: federal level, federal states and municipalities

The WZG applies only to websites and mobile applications of the federal government and of federal-related bodies that were established in the general interest, have at least partial legal capacity and are mainly financed or supervised by the federal government (§ 2(1) nos. 1 and 2 WZG). Federal states and municipalities are covered by the state laws. The state laws cited here expressly name municipalities:

• Styria: § 1(1) StWZG (state, municipalities, municipal associations)
• Upper Austria: § 15b(1) Oö. Antidiskriminierungsgesetz
• Lower Austria: § 12(1) NÖ Antidiskriminierungsgesetz 2017
• Burgenland: § 59(1) Bgld. Gleichbehandlungs- und Antidiskriminierungsgesetz
• Vienna: § 10a(1) Wiener Antidiskriminierungsgesetz in conjunction with § 1(2) (sovereign administration and private-sector administration of the state and the municipality)

According to the FFG, all nine federal states have transposed the Directive into state law. For Salzburg, the FFG names the Salzburger Teilhabegesetz; it was not part of the material reviewed. A comparison of the eight state laws reviewed can be found in the article Accessible websites and documents in municipalities.

Germany: federal level and federal states

The BGG and BITV 2.0 bind the federal public bodies: holders of public authority as well as other institutions governed by public law and associations that meet the criteria of § 12 nos. 2 and 3 BGG, for example because they are mainly financed by the federal government. They make their websites and mobile applications, including the intranet, accessible (§ 12a(1) sentence 1 BGG), and their electronically supported administrative processes since 23 June 2021 at the latest (§ 12a(1) sentence 2 BGG). The BGG and BITV 2.0 do not apply to bodies of the federal states (Länder) and local authorities. The Länder report to the federal monitoring body every three years on the websites and apps of their public bodies (§ 12c(2) BGG). This guide does not cover the laws of the Länder.

Companies in Germany and Austria

The BFSG covers products listed in § 1(2) and services for consumers under § 1(3): telecommunications services, elements of passenger transport services, banking services, e-books and e-commerce services (nos. 1 to 5). Microenterprises that offer or provide services are exempt from § 3(1) (§ 3(3) BFSG). The BaFG contains a parallel catalogue (§ 2(1) and (2) BaFG, e-commerce in (2) no. 6) and a corresponding exemption for microenterprises (§ 6(1) BaFG). Details: BFSG for companies and BaFG for companies.

Which cut-off dates and exemptions apply to documents?

Whether a document has to be accessible depends on its publication date, its purpose and the legal framework. The most important difference: in Austria, office files of public sector bodies published before 23 September 2018 are exempt if they are not needed for ongoing administrative procedures. Federal bodies in Germany have no such exemption; the Directive allows stricter national rules (Art. 2 Directive 2016/2102).

The cut-off date of 28 June 2025 for office files is set by Directive (EU) 2019/882 (Art. 2(4)(b)). Third-party content that the body or company neither funds nor develops nor controls is also exempt (Art. 1(4)(e) Directive 2016/2102, § 2(3)(e) WZG, § 1(4) no. 4 BFSG, § 2(3) no. 4 BaFG). In Germany, content of public bodies published on third-party websites must be made accessible as far as possible (§ 12a(8) BGG).

In addition, there is the disproportionate burden exemption (Art. 5 Directive 2016/2102, § 2(3)(j) WZG, § 12a(6) BGG). The body carries out the initial assessment itself (Art. 5(3)), taking into account the size, resources and nature of the body, the estimated costs and benefits, and the frequency and duration of use (Art. 5(2)). If it relies on the exemption, it explains in the statement which requirements could not be met (Art. 5(4)). More on this in the article Disproportionate burden.

Which standard applies: EN 301 549, WCAG 2.1 or PDF/UA?

The laws link the presumption of conformity to harmonised standards whose references have been published in the Official Journal of the EU: Art. 6(1) Directive 2016/2102, § 3(2) WZG, § 3(2) BITV 2.0, § 4 BFSG and § 5(1) BaFG. § 3(2) StWZG treats conformity with these standards as sufficient for compliance. As long as no references have been published, the Directive names EN 301 549 in version V1.1.2 as the benchmark (Art. 6(3)). According to the FFG, version V3.2.1 (2021-03) lists WCAG 2.1 level AA and some additional criteria.

WCAG 2.1 via clauses 9 and 10

For web pages, conformance with WCAG 2.1 level AA is equivalent to conformance with clauses 9.1 to 9.4 and 9.6 (clause 9.0). For downloadable documents, clause 10 refers to the WCAG 2.1 success criteria or adopts them in a version adapted to documents, including:

• Non-text content, in other words alternative text (10.1.1.1, WCAG 1.1.1)
• Info and relationships, in other words structure such as headings and tables (10.1.3.1, WCAG 1.3.1)
• Meaningful sequence, the reading order (10.1.3.2, WCAG 1.3.2)
• Contrast (minimum) (10.1.4.3, WCAG 1.4.3)
• Keyboard (10.2.1.1, WCAG 2.1.1)
• Document titled (10.2.4.2) and Language of document (10.3.1.1, corresponding to WCAG 3.1.1 with “document” in place of “web page”)

PDF/UA as a technical route

PDF/UA is the standard ISO 14289. Part 1 (2014) specifies how ISO 32000-1 is to be used to create accessible documents, and Part 2 (2024) does the same for ISO 32000-2. The standard does not cover processes for converting paper or electronic documents into PDF/UA. None of the laws mentioned names WCAG or PDF/UA explicitly. PDF/UA is therefore a technical route to implementing the criteria of clause 10 in a PDF.

The FFG points out that version 4.1.1 of EN 301 549 was published in September 2026. For the presumption of conformity, what matters are the standards whose references have been published in the Official Journal of the EU (Art. 6(1) Directive 2016/2102). The article PDF/UA, WCAG 2.1 and EN 301 549 explains the details.

What must the accessibility statement contain, and how quickly must you respond?

Every obliged public sector body publishes a statement containing the mandatory content of the model statement and responds to feedback on shortcomings within the statutory deadline. The accessibility statement explains content that is not accessible, with the reasons and, where appropriate, alternatives, describes and links to the feedback mechanism, and links to the enforcement procedure (Art. 7(1) Directive 2016/2102). The mandatory content is set out in section 1 of the Annex to Implementing Decision (EU) 2018/1523:

• compliance status: fully, partially or not compliant
• non-accessible content with the reason: non-compliance, disproportionate burden or outside the scope
• accessible alternatives
• date of preparation and method used
• feedback mechanism with contact details
• enforcement procedure with link and contact details of the enforcement body

For documents, this means: PDFs that are not accessible must be listed as non-accessible content, with the reason and, where appropriate, an alternative. The explanatory notes to the Annex recommend reviewing the accuracy of the statements regularly, at least once a year.

Germany

The statement must be published in an accessible and machine-readable form and must be reachable from the home page and from every page (§ 7(1) BITV 2.0). The mandatory content from section 1 of the Annex to the Implementing Decision must be included (§ 7(4)). The statement is based on an actual assessment; it must state whether a third party or the body itself carried out the assessment (§ 7(5)). It must be updated annually and whenever there is a significant change (§ 7(6)). An electronic means of contact and a reference to the conciliation procedure under § 16 BGG with a link to the conciliation body are mandatory (§ 12b(2) nos. 2 and 3 BGG).

Austria

Federal bodies publish the statement in an accessible format and keep it up to date; it must be reachable from the home page (§ 4(1) and (2) WZG). The state laws cited prescribe the model statement (§ 4(1) StWZG, § 15b(3) Oö. ADG, § 12(5) NÖ ADG, § 10a(4) Wiener ADG, § 59(3) Bgld. GADG). In Vienna, a person or office must also be designated for complaints and listed with contact details in the statement (§ 10a(5) Wiener ADG).

A template and the structure can be found in the article Accessibility statement.

Are there penalties for missing accessible documents?

The provisions reviewed here impose no penalty for the web obligations of public sector bodies; for companies, there are provisions on administrative fines and penalties. According to the FFG, neither Directive (EU) 2016/2102 nor the WZG provides for sanctions or penalties. The state laws cited attach no penalty to their web provisions; where they contain penalty provisions, these concern other obligations, for example § 6 Wiener ADG relating to §§ 2 and 4(3). The BGG contains no provision on administrative fines.

Enforcement against public sector bodies

In Austria, the body responsible under § 5(2) WZG, which is the FFG unless a regulation provides otherwise, examines complaints against federal bodies and issues recommendations for action where complaints are justified (§ 5(1) no. 2 WZG). At state level, separate bodies are responsible, for example the equal treatment commissioner of the state and the municipalities in Styria (§ 6(1) StWZG) or the anti-discrimination office in Upper Austria (§ 15b(5) Oö. ADG). In Germany, affected persons can apply to the conciliation body under § 16 BGG for a conciliation procedure (§ 16(2) BGG); it is free of charge for the parties (§ 16(6) BGG).

Companies in Germany

An administrative offence is committed by anyone who, intentionally or negligently, offers or provides a service contrary to § 14(1) BFSG (§ 37(1) no. 8 BFSG). Under § 14(1), the service must meet the accessibility requirements and the information under Annex 3 (Anlage 3) must be accessible. In this case the fine is up to €100,000; in the other cases, for example missing information under no. 2, it is up to €10,000 (§ 37(2) BFSG).

Companies in Austria

The Sozialministeriumservice punishes offering or providing a service contrary to § 14(1) BaFG with a fine of up to €80,000, or up to €50,000 for microenterprises and SMEs (§ 36(1) no. 3 BaFG). Other offences, such as missing information on services under Annex 3 (Anlage 3), carry fines of up to €40,000 (SMEs €25,000) or up to €16,000 (SMEs €10,000) (§ 36(2) and (3) BaFG).

How accessible are documents in practice?

The monitoring results show that PDFs are among the weakest points of public websites. Member States carry out periodic monitoring (Art. 8(1) Directive 2016/2102) and report to the Commission every three years (Art. 8(4)). The checks are carried out by monitoring bodies.

Germany: monitoring in Berlin 2024

• 117 services were checked: 108 websites in simplified monitoring, 4 in in-depth monitoring, and 5 apps.
• PDF documents: 7 of 114 passed the automated test with the PDF Accessibility Checker (PAC), which is 6.1%. In 2023 the rate was 0% (88 documents), in 2022 it was 2.7% (73 documents).
• Criterion 1.3.1 Info and relationships was met by 5 of 117 services (4.3%).
• 15 of 117 services (12.8%) had a formally correct accessibility statement.

Austria: FFG interim monitoring report 2025

• 64% of the websites and apps checked had an accessibility statement, compared with 57% in 2024.
• Almost 70% (69%) of the statements gave no current date; 73% contained all mandatory content.
• None of the 23 websites checked in depth was fully compliant; on average, 18 of the 49 WCAG 2.1 AA criteria checked were not met per website.
• 52.5% of the statements cited a disproportionate burden, frequently for YouTube videos without audio description and several times with the remark that PDF documents could not be published accessibly as standard.
• A common barrier according to the FFG: PDFs that are not tagged or are tagged incorrectly; PDFs created from scans convey no structural information at all.
• 20% of the websites and apps checked belonged to the local administrative level (municipalities).

How the bodies carry out their checks and which samples they draw is explained in the article Accessibility monitoring.

How can you put your document inventory in order in six steps?

You will make the fastest progress if you record your inventory, prioritise according to the legal position and start with the source file. Each of the following steps is linked to a legal reference.

1. Record the inventory. List all PDFs and office files on your website and apps, and, as a federal body in Germany, also on the intranet (§ 12a(1) BGG). Note the publication date and purpose, because the exemptions depend on them.
2. Prioritise. Start with forms and documents for ongoing administrative procedures: the exemption for older office files does not apply to them (Art. 1(4)(a) Directive 2016/2102, § 2(3)(a) WZG). Then move on to frequently used documents, and finally to archives within the meaning of Art. 1(4)(h).
3. Secure the source files. Obtain the Word or PowerPoint originals. Structure, headings and alternative text can be created there; according to the FFG, a PDF created from a scan conveys no structural information. The checklist for Word and PowerPoint shows the individual steps.
4. Remediate. Implement the criteria of clause 10 of EN 301 549: alternative text, structure, reading order, contrast, title and language. For PDFs, PDF/UA (ISO 14289) serves as the technical framework.
5. Test and document. Combine an automated test with a human review. According to the publisher of PAC, not all requirements can be checked automatically. The FFG distinguishes automated simplified checks from in-depth checks of every EN 301 549 criterion. In Germany, the statement requires an actual assessment (§ 7(5) BITV 2.0); an assessment report can be linked.
6. Update the statement. List any remaining non-accessible documents with the reason and, where appropriate, an alternative (Art. 7(1)(a) Directive 2016/2102), and state the feedback contact and the date. As a federal body in Germany, update the statement annually and whenever there is a significant change (§ 7(6) BITV 2.0); as a federal body in Austria, keep it up to date (§ 4(1) WZG).

If you would rather not do the remediation yourself: Compliance-Kit makes PDF, Word and PowerPoint documents accessible. Find out more about accessible document remediation.