Office file formats

PDF, Word and similar documents in websites; where a law has a specific exemption for office files, it covers only files published before a statutory cut-off date.

21 October 2026 · Category: Accessibility · Compliance-Kit

TL;DR

Office file formats are documents that are not primarily intended for use on the web but are included in websites, such as PDF, Microsoft Office or equivalent (open-source) formats (Recital 26 of Directive (EU) 2016/2102). Under their cut-off exemption, the Directive and the WZG (AT) exempt such files only if they were published before 23 September 2018 and their content is not needed for active administrative processes (Article 1(4)(a) of the Directive) or ongoing administrative procedures (§ 2 Abs. 3 lit. a WZG). BITV 2.0 (DE) has no such exemption. BFSG and BaFG use 28 June 2025 as the cut-off date.

What are office file formats?

Office file formats are documents that are not primarily intended for use on the web and are included in websites. Recital 26 of Directive (EU) 2016/2102 gives examples: documents in Adobe Portable Document Format (PDF), in Microsoft Office formats or in equivalent (open-source) formats. The Steiermärkisches Web-Zugangs-Gesetz defines "Dateien mit Büroanwendungsformaten" in § 2 Z 3 StWZG with the same core wording but names no example formats.

The term matters mainly for exemptions. Under Article 1(4)(a) of Directive (EU) 2016/2102, the Directive does not apply to such files published before 23 September 2018. This does not hold where their content is needed for the active administrative processes of the public body. The cut-off exemption does not cover files published later.

Exempted content can still be requested. The accessibility statement must describe and link to a feedback mechanism through which users can request information exempted under Article 1(4) (Article 7(1)(b) of Directive (EU) 2016/2102).

Exemptions and cut-off dates: Germany and Austria compared

Germany and Austria use different cut-off dates, and German federal bodies have no cut-off exemption for office files at all.

Legal act	Exemption for office files	Reference
Directive (EU) 2016/2102	published before 23 Sept 2018, unless needed for active administrative processes	Art. 1(4)(a)
WZG (AT, federal)	published before 23 Sept 2018, unless needed for ongoing administrative procedures	§ 2 Abs. 3 lit. a
StWZG (AT, Styria)	published before 23 Sept 2018, unless needed for ongoing procedures	§ 1 Abs. 2 Z 1
BITV 2.0 (DE, federal)	none; only archives not needed for active administrative procedures and not updated after 23 Sept 2019	§ 2 Abs. 2 Nr. 2
BFSG (DE, companies)	published before 28 June 2025	§ 1 Abs. 4 Nr. 2
BaFG (AT, companies)	published before 28 June 2025	§ 2 Abs. 3 Z 2

Germany

BITV 2.0 has no cut-off exemption for office files. Documents are part of websites (§ 2a Abs. 1 BITV 2.0). Only archives are exempt that neither contain content needed for active administrative procedures nor were updated or revised after 23 September 2019 (§ 2 Abs. 2 Nr. 2 BITV 2.0). The BFSG does not apply to office file formats published before 28 June 2025 (§ 1 Abs. 4 Nr. 2 BFSG), nor to archives whose content is neither updated nor revised after that date (§ 1 Abs. 4 Nr. 5 BFSG). This entry does not cover German state laws.

Austria

The WZG exempts office files published before 23 September 2018 whose content is not needed for ongoing administrative procedures (§ 2 Abs. 3 lit. a WZG). It applies only to the federal level and federally linked bodies (§ 2 Abs. 1 WZG). State laws apply to the states and municipalities. Among the reviewed state laws, the StWZG, for example, covers the State of Styria, its municipalities and municipal associations (§ 1 Abs. 1 StWZG) and exempts office files published before 23 September 2018 whose content is not needed for ongoing procedures (§ 1 Abs. 2 Z 1 StWZG). The article on state laws for municipalities in Austria gives an overview. Under the WZG and the StWZG, requests for exempted content that is not accessible must be answered within two months (§ 4 Abs. 3 WZG; § 4 Abs. 2 StWZG). The BaFG exempts office files published before 28 June 2025 and archives not updated after that date (§ 2 Abs. 3 Z 2 and 5 BaFG).

Practical example: separating older files from new ones

Whether a file is exempt depends on its publication date, its purpose and the applicable law. A Styrian municipality reviews three files on its website. Council minutes published as a PDF in 2017, not needed for any ongoing procedure, fall under § 1 Abs. 2 Z 1 StWZG. An application form in Word published in 2016 and still used in ongoing procedures does not. A PowerPoint presentation published in 2026 and exported as PDF is not covered by the cut-off exemption; the requirements of § 3 StWZG apply to it.

A German online retailer whose service falls under the BFSG makes the same distinction: product data sheets as PDF published before 28 June 2025 are exempt under § 1 Abs. 4 Nr. 2 BFSG, newly published data sheets are not.

Record the publication date and purpose of each file. This separates older stock from files you need to remediate. The guide to accessible PDFs and documents sets out the framework. If you do not want to handle the stock yourself, you can have your documents made accessible. This entry is not legal advice.

Frequently asked questions

Do PDF files count as office file formats?

Yes. Recital 26 of Directive (EU) 2016/2102 expressly names documents in Adobe Portable Document Format (PDF), alongside Microsoft Office and equivalent (open-source) formats.

Are old PDFs on German federal websites exempt?

No. BITV 2.0 has no cut-off exemption for office files. Only archives are exempt that neither contain content needed for active administrative procedures nor were updated or revised after 23 September 2019 (§ 2 Abs. 2 Nr. 2 BITV 2.0).

Does a different cut-off date apply to companies under the BFSG and BaFG?

Yes. The BFSG and BaFG only exempt office file formats published before 28 June 2025 (§ 1 Abs. 4 Nr. 2 BFSG; § 2 Abs. 3 Z 2 BaFG). Files published later are not covered by this exemption.

Can users still request exempted documents?

For public bodies, yes. The feedback mechanism must allow users to request information exempted under Article 1(4) (Article 7(1)(b) of Directive (EU) 2016/2102). Under the WZG and the StWZG such requests must be answered within two months (§ 4 Abs. 3 WZG; § 4 Abs. 2 StWZG).

Sources

Directive (EU) 2016/2102 on the accessibility of the websites and mobile applications of public sector bodies, Erwägungsgrund 26, Erwägungsgrund 46, Art. 1 Abs. 4 lit. a, Art. 7 Abs. 1 lit. b, eur-lex.europa.eu
Web-Zugänglichkeits-Gesetz (WZG), consolidated version, § 2 Abs. 1, § 2 Abs. 3 lit. a, § 4 Abs. 3, ris.bka.gv.at
Steiermärkisches Web-Zugangs-Gesetz (StWZG), consolidated version, § 1 Abs. 1, § 1 Abs. 2 Z 1, § 2 Z 3, § 3, § 4 Abs. 2, ris.bka.gv.at
Barrierefreiheitsstärkungsgesetz (BFSG), § 1 Abs. 4 Nr. 2 und Nr. 5, gesetze-im-internet.de
Barrierefreiheitsgesetz (BaFG), consolidated version, § 2 Abs. 3 Z 2 und Z 5, ris.bka.gv.at
Barrierefreie-Informationstechnik-Verordnung (BITV 2.0), § 2 Abs. 2 Nr. 2, § 2a Abs. 1, gesetze-im-internet.de

Legal status of the sources checked: 19 October 2026 (RIS, gesetze-im-internet.de, EUR-Lex)

Practitioner note: This article is practice-oriented compliance documentation, not legal advice. We are compliance specialists, not a law firm. For legally binding advice, consult an admitted lawyer.