PDF/UA (ISO 14289)

PDF/UA (ISO 14289) is the technical ISO standard for accessible PDF, not expressly required by law.

What is PDF/UA (ISO 14289)?

PDF/UA is the international standard ISO 14289. It specifies how the PDF format is used to produce accessible electronic documents. The standard has two parts:

• Part 1, ISO 14289-1:2014 (PDF/UA-1): specifies the use of ISO 32000-1:2008. Edition 2 was published in December 2014 and replaces the withdrawn ISO 14289-1:2012. ISO last reviewed and confirmed it in 2025, so it remains current.
• Part 2, ISO 14289-2:2024 (PDF/UA-2): specifies the use of ISO 32000-2. The first edition was published in March 2024.

Both parts come from committee ISO/TC 171/SC 2. They describe the technical structure of the file. According to the ISO abstracts, they do not cover, among other things, processes for converting paper or electronic documents to PDF/UA, rendering details, or hardware and operating systems. Part 2 also excludes content requirements beyond facilitating programmatic access and textual representation, as well as requirements for specific classes of documents such as invoices or reports.

For context: PDF/UA is a technical standard. Directive (EU) 2016/2102 does not mention PDF/UA.

Legal basis and references

What counts in law are the accessibility requirements of Article 4 of Directive (EU) 2016/2102, not PDF/UA. Under Article 4, Member States ensure that public sector bodies make their websites and mobile applications perceivable, operable, understandable and robust. Under Article 6(1), content that meets harmonised standards whose references have been published in the Official Journal of the EU is presumed to conform. Where no such references have been published, Article 6(3) refers, for websites, to EN 301 549 in version V1.1.2 (2015-04). Article 6(4) empowers the Commission to update this reference to a more recent version.

PDF files on websites are covered. Under recital 26, office file formats are documents not primarily intended for use on the web and included in websites, such as documents in PDF format, Microsoft Office formats or equivalent (open source) formats. Article 1(4)(a) excludes such files if they were published before 23 September 2018, unless they are needed for active administrative processes.

Version EN 301 549 V3.2.1 (2021-03) covers documents in clause 10. It concerns non-web documents, meaning documents that are not a web page, not embedded in web pages and not used in the rendering or functioning of the page (definition in clause 3.1). Under clause 10.0, clause 10 also applies to documents provided with a web page but neither embedded nor rendered together with it, meaning downloadable documents. The individual requirements oblige the document to satisfy WCAG 2.1 success criteria, in some cases in an adapted wording set out in tables. Examples:

• Clause 10.1.1.1: Non-text content (success criterion 1.1.1)
• Clause 10.1.3.1: Info and relationships (success criterion 1.3.1)
• Clause 10.1.3.2: Meaningful sequence (success criterion 1.3.2)

EN 301 549 V3.2.1 does not mention PDF/UA. Whether a PDF meets clause 10 is measured against these success criteria. How Germany and Austria implement the requirements is explained in the article PDF/UA, WCAG and EN 301 549 for documents.

Practical example

A typical case is an annual report written in Word and published as a PDF on the website. For clause 10 of EN 301 549, the success criteria count, not the PDF/UA label. Check the Word document itself:

• Images and charts have alternative text (clause 10.1.1.1).
• Headings, lists and tables are set up as structure, not just formatted visually (clause 10.1.3.1).
• The reading order makes sense (clause 10.1.3.2).

The same applies to PowerPoint presentations you share as PDF. Note 1 to clause 10.0 names presentations, letters and spreadsheets as examples of documents. Under note 7 to clause 10.0, the requirements also apply to signed, encrypted or password-protected documents when they are presented to the user. PDF/UA is a separate standard for the PDF format that EN 301 549 V3.2.1 does not reference; conformity with clause 10 is shown through its success criteria (see tagged PDF).

If you would rather not convert reports, forms or presentations yourself, you can have accessible documents prepared.

See also

• EN 301 549 (harmonised standard for ICT accessibility)
• Tagged PDF (tag structure)
• WCAG 2.1 (Web Content Accessibility Guidelines)
• Office file formats