For public bodies, digital accessibility is not an upcoming obligation, but rather applicable law - and has been for years. While websites can be controlled comparatively easily using central templates, the PDF remains the most difficult part of implementation: notices, meeting documents, forms and reports are created decentrally, in large numbers and often without an accessible structure.
This guide classifies the legal framework, explains the specific requirements for PDF documents and shows how authorities can practically solve the quantity problem.
Which laws apply to public-sector bodies?
The starting point is this EU Directive (EU) 2016/2102 about accessible access to websites and mobile applications of public bodies. Germany has them at the federal level Equal Opportunities for Persons with Disabilities Act (BGG, §§ 12a ff.) and the Accessible Information Technology Ordinance (BITV 2.0) implemented. The respective regulations apply to state and local authorities State equality laws and state regulations, which are largely structured in parallel in terms of content.
| control | level | Meaning for PDFs |
|---|---|---|
| Directive (EU) 2016/2102 | EU | Basic obligation for accessibility including “file formats of office applications” such as PDF |
| BGG §§ 12a–12b | Federal | Obligation to have accessible IT and an accessibility declaration |
| BITV 2.0 | Federal | Specifies requirements, explanations and exceptions for federal agencies |
| State laws and regulations | Countries/municipalities | Corresponding obligations for state authorities, municipalities and universities |
Important for classification: BITV 2.0 expressly applies not only to websites in the narrower sense, but also to files that are made available via websites or apps - a notice or budget published as a PDF therefore falls within the scope.
Since when does the obligation apply?
The deadlines from Article 12 of Directive (EU) 2016/2102 have all expired:
- September 23, 2019: Public sector websites published after September 23, 2018 must be accessible.
- September 23, 2020: All other websites of public authorities – including the documents offered there.
- June 23, 2021: Mobile applications of public bodies.
Anyone who publishes a non-accessible PDF on a government website today is not moving through a transition phase, but rather is failing to fulfill an existing obligation.
What does BITV 2.0 specifically require for PDFs?
BITV 2.0 does not prescribe its own technology checklist, but works with one Presumption of conformity (§ 3 BITV 2.0): Whoever the harmonized European standard EN 301 549 complies with is considered compliant. For documents, Chapter 10 (“Non-Web Documents”) is relevant, which contains the success criteria of the WCAG transferred to files such as PDFs. Orientation to the current status means: WCAG 2.2, Compliance Level AA. As a technical implementation standard for PDFs PDF/UA established, current PDF/UA-2.
For a single PDF this means in practice:
- Tagged structure: Headings, paragraphs, lists and tables are marked as PDF tags so that screen readers can grasp the document.
- Logical reading order: Content is output in the correct sequence – even with multi-column layouts.
- Alt text: Images, graphics and diagrams carry meaningful text alternatives.
- Correct table marking: Headers and cell references are semantically defined.
- Metadata: Document title and main language are set.
You can find a detailed overview of the criteria in the guides WCAG for PDF documents and Understanding PDF/UA.
What exceptions apply to old documents?
Directive (EU) 2016/2102 excludes in Article 1 paragraph 4 “file formats of office applications”. before September 23, 2018 were published – unless they are needed for active administrative procedures. An archived protocol from 2015 can therefore be excluded; an application form from 2015 that citizens should continue to fill out is not. Every authority should make this distinction in a documented manner instead of simply referring to “archive”.
Accessibility statement and feedback mechanism
In addition to the accessibility of the content itself, there are two formal obligations (§ 12b BGG, § 7 BITV 2.0):
- Accessibility Statement: Every website of public authorities needs a regularly updated declaration that indicates the level of compliance and identifies non-accessible content - such as PDF holdings - along with the reasons and planned corrective measures.
- Feedback mechanism: Users must be able to report barriers and request non-accessible content in an accessible form. The declaration also refers to the enforcement or arbitration procedure (at federal level, the arbitration board according to Section 16 BGG).
Practically relevant: Every non-accessible PDF that remains online must be listed as a defect in the declaration - and can be specifically requested at any time via the feedback channel. The smaller the uncorrected inventory, the lower the ongoing effort.
Who monitors compliance?
The implementation is actively monitored: at the federal level Federal monitoring agency for accessibility of information technology periodically websites, apps and documents from public bodies; the federal states have set up appropriate monitoring centers. The testing methodology follows Implementing Decision (EU) 2018/1524, and the results are included in regular reports to the EU Commission. Documents provided such as PDFs are expressly included in the scope of the check.
Why old stocks are the core problem
The problem for most authorities is not the single complex document, but the quantity. Typical document types affected:
- official announcements and notices,
- Meeting documents and minutes, often with hundreds of pages,
- forms and applications,
- Public relations brochures and flyers,
- Statistics, reports and budgets.
In addition, there is the legacy: Council information systems, official gazette archives and download areas contain documents from many years that must still be accessible, but were created before any accessibility requirement. Training for all employees fails due to fluctuation and the fact that technical PDF tagging is hardly affordable in addition to the specialist work. Individual manual processing is not possible in terms of time when dealing with four or five-digit document numbers.
Manual or automated remediation?
Both ways have their place - the volume is crucial:
| Criterion | Manual editing | Automated correction |
|---|---|---|
| Suitable for | Individual, creatively complex documents | Large inventory and constantly new documents |
| Lead time | Hours to days per document | Results typically in seconds per document |
| Scaling | Personnel dependent | Batch processing thousands of documents |
| Way of working | Tagging by hand in special software | AI automatically adds tags, reading order and alt text |
| Proof | To be documented manually | audit-ready report for each document |
The advantage of automation: The existing workflows remain unchanged. Processing and specialist procedures generate documents as before; The correction only starts with the finished PDF and only adds to the structural level - the layout and content remain unchanged. The page shows how this works in detail Automatically check and correct PDF accessibility; The site deals with the specific requirements of administrations Accessible PDFs for authorities.
In the event of an exam, Accessful's remediation guarantee applies: If a document remediated by Accessful is not recognized as accessible during an accessibility audit, we will remediate it free of charge - quickly, easily and at no additional cost.
A step-by-step approach for public-sector bodies
- Record inventory: Inventory all publicly provided PDFs – website, council information system, download areas, forms server.
- Delimit exceptions: Identify documents from before September 23, 2018 and determine whether they are required for active administrative proceedings. Document the demarcation.
- Check status: Check the remaining inventory for accessibility - at Accessful for free and without registration scan.accessful.de.
- Prioritize: First, forms and documents from active procedures, then frequently accessed content, then the old inventory.
- Correct: Process large quantities automatically and specifically rework special design cases manually.
- Update statement: Update the accessibility declaration and feedback mechanism, identify remaining deficiencies with a schedule.
- Establish a permanent process: Have newly created documents checked and corrected automatically before publication - via web app or API, see How it works.
BITV 2.0 is not a project with an end date: As long as an administration communicates, new PDFs are created. Anyone who organizes accessibility as an ongoing, largely automated process keeps the inventory permanently accessible - and fulfills the obligations under BGG and BITV 2.0 without constant strain on the departments.