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BFSG compliance since 2025

Accessible PDFs: Documents That Every User Can Read

PDF documents are among the most common digital barriers. Missing tags, incorrect reading order and unlabelled form fields render PDFs unusable for screen reader users. We create and convert your documents to the PDF/UA standard – verifiable, certifiable and BFSG-compliant.

PDF/UA Standard Screen Reader Tested BFSG-Compliant

85%

of all PDFs published without accessibility check (project experience)

ISO

14289-1 PDF/UA standard

4

Core areas: tags, order, alt texts, forms

50+

accessible document projects

The Barrierefreiheitsstärkungsgesetz (BFSG) applies not only to websites but explicitly also to digital documents made available through them. Contracts, forms, product sheets, price lists, annual reports – all PDFs offered for download must meet the requirements of EN 301 549 and, by extension, the PDF/UA standard. Without correct tag structure, consistent reading order and descriptive alternative texts, these documents are simply unusable for around 13 percent of the German population (Statistisches Bundesamt, 2023) with disabilities.

What accessible PDFs differ from ordinary PDFs

An ordinary PDF looks identical on screen to an accessible PDF – the difference lies entirely in the invisible document structure. Screen readers such as NVDA, JAWS or VoiceOver do not read visual layouts; they require a logical structure of tags that give the document semantic meaning. If these tags are missing or incorrectly applied, a screen reader user receives noise of disconnected text, skipped content or no output at all instead of structured information.

Particularly insidious: many PDFs were originally created for print, not digital consumption. Documents produced in Adobe InDesign, Microsoft Word or a CAD system and exported as PDF contain no structure tags at all without a deliberate accessibility setup. Clicking the export button is not enough – it takes a well-considered production process that integrates accessibility from the outset. Our team accompanies you in anchoring accessible design in document production as well.

The four core areas of accessible PDF documents

Structure Tags and Document Hierarchy

Every content element of a PDF must be tagged to define its meaning: <H1> to <H6> for headings, <P> for paragraphs, <L> and <LI> for lists, <Table> with <TH> and <TD> for tables. Decorative elements receive the artifact tag so screen readers skip them. The tag hierarchy must match the visual layout and reflect a consistent document outline.

Reading Order and Tab Order

Screen readers follow the reading order defined in the document tree, not the visual arrangement. For multi-column layouts, sidebars, footnotes and complexly placed chart captions, the tag order must exactly match the semantic reading direction. In addition, the tab order in interactive PDFs with form fields must be correctly configured.

Alternative Texts for Graphics and Images

Every information-bearing image, infographic, chart and logo must carry a descriptive alternative text that adequately conveys the visual content to screen reader users. Decorative images receive no alt text field but the artifact tag. We review and compose alt texts in line with WCAG success criterion 1.1.1 Non-text Content.

Accessible Forms and Interactive Elements

PDF forms with input fields, checkboxes, dropdown menus and signature fields require special care: every field needs a tooltip (label) that screen readers announce. Required fields must be marked as such. The tab order must follow the logical form structure. Error messages must be programmatically associated with the relevant field.

Our process: from analysis to the certified document

The PDF/UA Standard: What ISO 14289-1 Requires

The PDF/UA standard (Universal Accessibility) has been published as ISO standard 14289-1 since 2012 and forms the technical foundation for accessible PDF documents. It specifies how WCAG requirements translate to the PDF format and defines a complete ruleset of 136 individual requirements, testably specified in the so-called Matterhorn Protocol. PDFs that pass the Matterhorn Protocol fulfil the technical prerequisites for an accessibility statement under the BFSG.

BFSG and PDF Documents

The Barrierefreiheitsstärkungsgesetz applies from 28 June 2025 to new products and services, and from 28 June 2030 also to existing ones. PDFs available for download as part of a digital service offering fall within scope. More about BFSG requirements.

Typical document types we make accessible

Forms and Application Documents

Government forms, insurance applications, registration forms and order documents – with fully labelled fields, correct tab order and screen reader-friendly hint and error texts.

Reports and Business Documents

Annual and sustainability reports, product catalogues, price lists and technical documentation with correctly tagged tables, infographics with alt texts and structured heading hierarchies.

Brochures and Marketing Material

Corporate brochures, product leaflets, presentation slides as PDF – often complex layouts and particularly prone to reading order issues. We correct column structures, flyout graphics and complex information graphics.

Training Materials and Manuals

Technical manuals, operating instructions, training slides and e-learning materials that must be fully usable by people with visual or motor impairments.

Legal Documents and Contracts

Terms and conditions, privacy policies, contracts and official notices – documents where usability by all groups is not just a requirement but a legal and ethical matter of course.

Technical Documentation

Data sheets, specifications, API documentation and technical guides with complex tables, code fragments and nested list structures correctly transferred into the tag hierarchy.

Accessible PDFs from your authoring software

The most efficient approach to accessible PDFs begins not in Acrobat but in the source file. Microsoft Word, InDesign, LibreOffice and PowerPoint all offer export options for accessible PDFs – but only if the source document is correctly structured. In practice this structure is frequently absent: headings are created with manual font size adjustments instead of styles, tables are assembled from tab stops, images have no alt texts. Our team advises you on setting up your templates and authoring processes so future documents are produced with low barriers from the start – without additional effort per document.

Comparison: production paths for accessible PDFs

Source File Optimisation vs. Remediation

For documents whose source file is available, we recommend optimising the export process: correct styles, export settings and alt texts in the source file. For documents without a source file or with complex layouts, we carry out direct remediation in Adobe Acrobat Pro. Both paths lead to a validated, PDF/UA-compliant result.

  • Source file available: optimise structure in Word/InDesign/PowerPoint, then configure accessible export
  • Source file not available: manual tag structuring in Adobe Acrobat Pro (remediation)
  • Large document inventories: batch assessment with PAC and prioritised remediation by criticality
  • New production: template creation with embedded accessibility settings for your team

Scope: what accessible PDFs deliver – and where limits lie

PDF/UA-compliant documents are technically accessible to screen reader users and people who navigate documents by keyboard. They cover the technical requirements of the BFSG and EN 301 549. What PDF/UA does not address is the comprehensibility of the content itself: complex specialist language, unclear wording and the absence of easy-language versions are not accessibility problems in the technical sense but can nonetheless create significant barriers for people with cognitive impairments. If you are also seeking support in this area, our complementary service Easy Language addresses exactly this aspect.

Accessible PDFs do not replace an accessible website. Where possible, we recommend providing content primarily as accessible HTML pages and using PDFs only for print versions or legally required document forms. This recommendation is consistent with the BFSG approach, which demands digital accessibility across the entire user journey. Our accessible web development service accompanies you across your entire digital presence.

Bulk conversion: making existing document inventories accessible

Many organisations hold hundreds or thousands of PDFs accumulated over the years that now need to be made accessible. Full manual remediation of every document is neither economically sensible nor feasible within the required timeframe. Our approach to large document inventories is guided by risk-based prioritisation: which documents are accessed most frequently? Which are indispensable for legally relevant processes (contract signing, application submission, complaint procedures)? Which target groups are most frequently affected by accessibility barriers? These questions determine the order of processing.

  • Batch analysis of all PDFs with PAC and automated check scripts to produce a priority list
  • Categorisation by criticality: legally relevant, frequently accessed, target-group-relevant
  • Remediation in waves by priority, starting with critical and high-frequency documents
  • Building internal templates and export workflows so new documents are produced accessibly from the outset
  • Progress reporting with proof of current conformance status for your accessibility statement
  • Training your staff for sustainably accessible document production

Quality assurance: how we test accessible PDFs

Our quality assurance comprises three successive testing levels. We start with PAC 2024 (PDF Accessibility Checker) – the most comprehensive available tool for automated testing of PDFs against the Matterhorn Protocol. PAC checks the 136 requirements of the PDF/UA standard and outputs exact error locations for every failed checkpoint. This automated check reliably captures structural errors – analogous to axe-core for web pages but calibrated to the PDF standard.

The automated check is followed by manual inspection of the tag structure, reading order and alternative texts by our specialists in Acrobat's accessibility panel. This surfaces quality issues that automated tools accept as "present" but are content-wise inadequate – for example, alt texts that merely repeat the filename. Finally we conduct a practical test with NVDA, navigating the entire document and verifying the correct output of all content elements. Only when all three testing levels have been passed is a document considered accepted. The entire inspection process is transparently documented and traceable for you.

Frequently asked questions about accessible PDFs