PDF/UA, WCAG 2.1 and EN 301 549: which standard applies to accessible documents?

Which standard applies legally? The laws refer to harmonised standards

What counts legally is the harmonised standard, not WCAG or PDF/UA as such: where content conforms to a harmonised standard whose reference has been published in the Official Journal of the EU, it is presumed to meet the accessibility requirements, insofar as the standard covers them. None of the legal acts reviewed names WCAG or PDF/UA explicitly.

Directive (EU) 2016/2102 requires Member States to ensure that public sector bodies take the necessary measures to make their websites and mobile applications more accessible by making them perceivable, operable, understandable and robust (Art. 4). Art. 6(1) governs the presumption of conformity via harmonised standards. Where no references have been published, EN 301 549 V1.1.2 (2015-04) serves as the fallback yardstick for website content (Art. 6(3)). Documents are covered: Recital 26 understands office file formats to mean documents that are not primarily intended for use on the web and are included in web pages, such as PDF, Microsoft Office or equivalent open-source formats.

Germany

Federal public bodies must make their websites and mobile applications accessible (§ 12a(1) BGG); BITV 2.0 applies to them, taking account of the implementation deadlines in §§ 12a to 12c BGG (§ 2(1) BITV 2.0). Compliance with the requirements is presumed where the offerings conform to harmonised standards referenced in the Official Journal of the EU (§ 3(2) BITV 2.0). Anything the standards do not cover must be made accessible in line with the state of the art (§ 3(3)). Integrated content such as documents forms part of the website (§ 2a(1) BITV 2.0). For products and services, the presumption under § 4 BFSG applies, in relation to the requirements of the regulation issued under § 3(2) BFSG. More on this in the article on the BFSG for companies.

Austria

The WZG applies to websites and mobile applications of the federal government and certain federally affiliated bodies (§ 2(1) WZG). For them, the presumption under § 3(2) WZG applies. The body responsible for the tasks under § 5 publishes the standard references announced by the European Commission on its website (§ 3(3) WZG). The WZG does not cover the federal states (Länder) and municipalities; the state laws (Landesgesetze) apply to them (see the comparison of the state laws reviewed). For products and services, the presumption under § 5(1) BaFG applies; more in the article on the BaFG for companies.

EN 301 549 V3.2.1: clause 9 covers web pages, clause 10 covers documents

EN 301 549 V3.2.1 (2021-03) assigns documents according to how they are integrated: clause 10 applies to documents that are not web pages, to documents that are not embedded in web pages and to documents that are provided with a web page but are neither embedded in it nor rendered together with it, in other words to downloadable files (clause 10.0).

• Conformance with WCAG 2.1 Level AA is equivalent to meeting all of clauses 9.1 to 9.4 and the conformance requirements in 9.6 (clause 9.0).
• Documents that are embedded in a web page and rendered together with it fall under clause 9 (clause 10.0).
• Note 1 to clause 10.0 gives letters, spreadsheets, emails, books, pictures, presentations and movies that have an associated user agent such as a document reader, editor or media player as examples.
• Clause 10 also applies to documents that are protected by digital signatures, encryption, password protection or watermarks, once they are presented to the user (Note 7 to 10.0).
• Individual web criteria are marked “Void” for documents, for example 10.2.4.1 (Bypass blocks) and 10.2.4.5 (Multiple ways); these placeholders keep the numbering of clauses 9, 10 and 11 aligned (Note 6 to 10.0).

Informative Annex A maps the standard to Directive (EU) 2016/2102. Table A.1 expressly covers downloadable documents, including forms. Once the standard is cited in the Official Journal of the EU under this directive, compliance with the clauses listed in Tables A.1 and A.2 gives a presumption of conformity within the limits of the scope of the standard (Foreword, Annex A). Directive (EU) 2019/882, to which the BFSG and BaFG refer, does not appear in the text of V3.2.1.

These WCAG 2.1 success criteria matter for PDF, Word and PowerPoint

Clause 10 requires the WCAG 2.1 success criteria for documents, partly by reference, partly with adapted wording. WCAG 2.1 is structured into four principles (perceivable, operable, understandable, robust), 13 guidelines and testable success criteria at Levels A, AA and AAA (WCAG 2.1, Introduction).

Further criteria apply as soon as the document contains the relevant content, such as captions for embedded videos (10.1.2.2), link purpose (10.2.4.4) or resize text (10.1.4.4). How to implement this in Word and PowerPoint is shown in the checklist for accessible Office documents.

What does WCAG 2.2 change compared with WCAG 2.1?

WCAG 2.2 is backwards compatible, adds nine success criteria and removes one: 4.1.1 Parsing (WCAG 2.2, “Comparison with WCAG 2.1”). According to the W3C, sites that conform to WCAG 2.2 also conform to WCAG 2.1 (“New Features in WCAG 2.2”).

• 2.4.11 Focus Not Obscured (Minimum), AA; 2.4.12 Focus Not Obscured (Enhanced), AAA; 2.4.13 Focus Appearance, AAA
• 2.5.7 Dragging Movements, AA; 2.5.8 Target Size (Minimum), AA
• 3.2.6 Consistent Help, A; 3.3.7 Redundant Entry, A
• 3.3.8 Accessible Authentication (Minimum), AA; 3.3.9 Accessible Authentication (Enhanced), AAA

EN 301 549 V3.2.1 refers to WCAG 2.1 in clauses 9 and 10. The responsible W3C working group recommends adopting WCAG 2.2 as the new conformance target, even where formal obligations name earlier versions. Anyone required by policy to conform with WCAG 2.0 or 2.1 may still need to test and report on 4.1.1 (WCAG 2.2, “New Features in WCAG 2.2” and “Comparison with WCAG 2.1”).

PDF/UA (ISO 14289): what the standard covers and what it does not

PDF/UA is an ISO standard for the PDF file format: it specifies how PDF is to be used so that accessible electronic documents result. It is a technical standard, not a law. PDF/UA does not appear in the text of EN 301 549 V3.2.1.

This results in a division of labour: PDF/UA describes the technical structure of an accessible PDF (abstracts of ISO 14289-1 and -2). Content questions, such as whether alternative text is equivalent or whether a title describes the purpose, are not governed by PDF/UA-2 according to its abstract; the WCAG criteria in clause 10 of EN 301 549 address them. For Word and PowerPoint files, clause 10 alone remains the yardstick, since PDF/UA only concerns PDF under ISO 32000.

Automated testing is an indicator, not proof

A testing tool such as PAC only covers the part that can be checked automatically. According to the FAQ of the PDF Accessibility Checker (PAC), the tool supports PDF/UA and WCAG, but not all requirements can be checked by software. An additional check by a human is always required, for example whether the semantic tagging is appropriate.

• According to the PAC FAQ, the test result is not legally binding but an indicator.
• Green ticks in the PDF/UA and WCAG tabs only mean that all automatically testable requirements are met.
• PAC currently processes documents in PDF 2.0 format on a best-effort basis; full support exists only for PDF 1.7, and full support for PDF 2.0 and PDF/UA-2 is planned, with no release date known yet.

The content criteria of clause 10 in particular need manual assessment: is the alternative text equivalent (10.1.1.1)? Do the reading order and headings fit the content (10.1.3.1, 10.1.3.2, 10.2.4.6)? Does the title describe the purpose (10.2.4.2)? How monitoring bodies check documents is explained in the article on monitoring and test results.

In practice: in what order is an accessible document produced?

Produce an accessible document in five steps: create the source file, export it as a tagged PDF, check it automatically, check it manually and record the result. Assign the relevant EN 301 549 clauses to each step. The order is a working recommendation, not text from the standard.

1. Create the source file: in Word or PowerPoint, use styles for headings and lists, add alternative text, and set the document title and language (10.1.1.1, 10.1.3.1, 10.2.4.2, 10.3.1.1).
2. Export: output a tagged PDF so that structure and order are preserved (10.1.3.1, 10.1.3.2); if PDF/UA is the target, decide on the part (ISO 14289-1 or -2).
3. Check automatically: work through the automatically testable PDF/UA and WCAG requirements with a tool such as PAC.
4. Check manually: have a person assess alternative text, reading order, headings, contrast (10.1.4.3) and changes of language (10.3.1.2).
5. Record: for each document, note the date, tool, clauses checked, outstanding defects and the person who carried out the check.

The record also supports the accessibility statement. For federal public bodies in Germany, § 7(5) BITV 2.0 requires an actual assessment for this and a statement of whether a third party or the body itself carried out the assessment. The mandatory content is set out in the article on the accessibility statement, and the obligations in each jurisdiction in the guide to accessible PDFs. If you would rather not process your existing documents yourself, you can have accessible documents prepared by Compliance-Kit.