PDFs are one of the quickest, easiest and most effective ways to share complex information – but with WCAG 2.2 compliance and the European Accessibility Act (EAA) on the horizon, is this popular format truly accessible and compliant for all users?

The PDF, or Portable Document Format, has been an industry standard for sharing information since the 1990s. Supported across almost all platforms and easy to use, it has become the standard format for so many functions from teaching and e-learning, to creative and commercial communication. In fact, wherever you need file sharing flexibility with the reassurance of almost universal access, you’ll probably find a PDF!

However, this universal acceptance assumes equal ability. For many visually impaired people or those with access issues, the PDF format can be restrictive. This is becoming more and more important as organisations deal with evolving digital accessibility rules.

With the European Accessibility Act (EAA) set to come into full effect on June 28, 2025, and WCAG 2.2 (Web Content Accessibility Guidelines) emerging as the global benchmark, ensuring your web-hosted PDFs are truly accessible is no longer just good practice – it's a compliance necessity.

In this article, we’ll examine how to tailor your PDFs to meet these standards, looking at some of the common challenges and the solutions, guided by principles like the PDF/UA (Portable Document Format/Universal Accessibility) Standard.

PDFs have come a long way and are still evolving

PDFs were developed by Adobe Systems in 1993 and quickly became the go-to format for publishing and reading digital documents. By 2008 PDFs had become the ISO standard. This evolution continues with ever-greater emphasis on universal access.

The PDF/UA (Universal Accessibility) standard are the guidelines for making PDF documents accessible. Crucially, PDF/UA is the technical blueprint that directly supports compliance with the overarching Web Content Accessibility Guidelines (WCAG) 2.2, which is now the de facto standard for digital accessibility in light of legislation like the European Accessibility Act (EAA) which comes into full effect from 28th June 2025.

Accessible PDF challenges – and what to do about them

Common PDF accessibility challenges – and how they relate to WCAG 2.2

Whether you're designing comms to be accessible from the get-go – or applying accessibility to something pre-existing, there are some challenges that often come up:

• Some text is not actually ‘text’: Sometimes PDFs contain scanned images of text, or text within images, which makes them inaccessible to text-to-speech reading systems. WCAG 2.2 requires text alternatives for non-text content.
• The structure isn't working: PDFs that lack intuitive structure - clear, appropriate headings and paragraphs - make it hard to find what you are looking for and make it difficult for screen readers to navigate. WCAG 2.2 requires there be a programmatic approach to content.
• There's missing or inaccurate alternative text: If you include images and graphics in a document, and you don’t add descriptive alternative texts, they cannot be interpreted by screen readers. Again, WCAG 2.2 requires text alternatives for non-text content.
• The layout is complex: Complex layouts with multiple columns, tables, or overlapping elements might look great, but can return confused results for assistive technologies. WCAG 2.2 requires a meaningful sequence to support a logical reading order.
• The colour contrast is low: If the colour contrast between text and background is too low, it can make it difficult for people with impaired vision to see text clearly, and be missed by screen readers. WCAG 2.2 requires minimum contrast ratios to Level AA.

Proactive steps for WCAG 2.2 compliant PDFs

There are some things you can do right from the start to make sure any document is as accessible as possible for everyone.

• Use clear and simple language: Always avoid jargon and complex sentence structures, use clear headings and subheadings. This aligns with WCAG 2.2's principle of understandable content.
• Apply consistent formatting: Maintain consistent formatting throughout the document where you can, including font size, font type, and colour. Consistency aids predictability, a key aspect of WCAG 2.2's understandable principle.
• Adopt a logical reading order: Ensure that the reading order of the content is logical and easy to follow. This directly addresses WCAG 2.2 meaningful sequence criteria.
• Add alternative text for images: Provide descriptive alternative text for all images to help screen readers understand the visual content. This is essential for WCAG 2.2 compliant non-text content.
• Suitable colour contrast: Always use sufficient colour contrast between text and background to improve readability. This is a direct requirement of WCAG 2.2 minimum contrast ratios.
• Optical Character Recognition (OCR): You should ensure that the PDF is OCR-processed to make the text searchable and readable by screen readers, a fundamental step towards WCAG 2.2's perceivable principle.
• Table Structure: If you use tables to organise information, they should be clear and use a properly defined structure, including headers and row/column relationships, as mandated by PDF/UA and critical for WCAG 2.2 info and relationships requirements.
• Hyperlinks: Apply clear and descriptive hyperlink text and avoid ambiguous phrases like "Click here". This directly supports WCAG 2.2 in-context link purposing.

How can you tell if your accessible PDF is compliant?

Making sure your PDFs meet WCAG 2.2 standards, particularly for EAA compliance, needs thorough verification.

There are built-in accessibility checkers in many PDF editing tools that can quickly identify potential issues and guide you on the changes needed. You could also use third-party accessibility testing tools to perform a comprehensive accessibility audit, often with specific WCAG 2.2 checks – however, automated tools are only part of the solution.

Manually reviewing your PDF to check if it’s easy to navigate and understand for a human user is vital.

You can even test it with different screen reader technologies (such as NVDA or JAWS) to identify any issues that automated tools may miss, ensuring it truly meets the WCAG 2.2 operable principle.

If possible - and if the project is a more substantial one - consider involving people with specific disabilities in the testing process to get invaluable feedback. Always stay up-to-date with the latest WCAG 2.2 guidelines and PDF/UA standards to ensure your PDFs meet the highest standards of accessibility and compliance.

How Spiral can help

Through many years working with accessibility for both big and and small companies and organisations, the team here at Spiral have found that the best way to approach digital accessibility is to examine the user journey from the outset, ensuring compliance with standards like WCAG 2.2 and preparing for legislation like the European Accessibility Act.

We use a digital-first approach, where the digital version is designed to meet all accessibility requirements, then any print variants are built to work in tandem with those digital assets. This ensures your web-hosted PDFs are compliant by design. Working with an agency like Spiral can make all the difference. We can ensure your PDFs not only cater to the diverse needs of your audience but also meet all the stringent WCAG 2.2 Level AA criteria and your EAA compliance requirements.

Working with Spiral means every piece of comms you create works for everyone.

This article was first published in January 2025. It was updated in May 2025.