PDF and ADA Compliance

 In Articles

The Importance of PDF Accessibility

Not everyone is able to go to the web and easily read a document. For a person with a visual, mobile, or cognitive impairment, reading and navigating document text can be problematic. In fact, about 15% of the world’s population lives with some form of disability. The Americans with Disabilities Act (ADA)  of 1990 is a civil rights law that prohibits discrimination based on disability. As the years progress, that number will only grow. For example, as the “baby boomer” generation moves towards retirement and continues to age, more and more people will increasingly rely on assistive technologies, such as screen magnifiers or screen readers, to read their documents.

Too often, organizations have spent considerable time and effort ensuring their HTML content is accessible for everyone, including people with disabilities, but have ignored the fact that their website contains a significant number of documents and forms (the majority of which are in PDF).  Along with HTML, PDF is the most widely used document format to provide information, and PDFs play a key and growing role in many areas where documents are needed. In almost any setting and in every economic sector, from banking to education to healthcare and insurance, and just general-purpose use as well, PDF is most often the “final-form” electronic document format of choice.

Because PDF is so widely used, and likely the best choice for documents and forms on many websites, it’s important to keep in mind that they need to be made fully accessible, too.  This will help to ensure that your entire website is in compliance with accessibility standards such as WCAG 2.0 AA, PDF U/A, Section 508, and HHS.

Common PDF Accessibility Issues

No (or incomplete) Metadata


From an accessibility standpoint, the document needs to have a Title so that people know what the document is about.  While that might seem like common sense, there are additional things to consider when it comes to the Title.  First, it should be descriptive for the document, as opposed to numbers, symbols, and not really telling readers what the document is about.  Second, in the document’s properties, settings need to be established so that the document Title is displayed (and read by assistive technology) as opposed to the File Name.  Let’s face it, we’ve probably all seen some pretty cryptic File Names that are not ADA compliant.


An important consideration regarding this aspect of the metadata is that the document’s Author should not be a particular individual’s name.  It should be your company, agency, department, etc.


While optional (by some accessibility standards) the Subject can be the same as the Title or it can provide a little additional information as to what the document is about.


Keywords help to make the document easier to locate when searching for it online.  A good rule of thumb for ADA compliance could be to use some of the headings (and/or bookmarks) in your list of keywords.

Not Tagged: 

If a PDF doesn’t have tags, it’s not accessible and not in compliance with accessibility standards.  It’s as simple as that.

No Bookmarks: 

In documents longer than nine pages, Bookmarks aid in navigation.  Bookmarks should match the headings used in the document.

Image only PDF’s (OCR): 

If the PDF is a scanned document, each page is treated like one big picture.  Running OCR – Optical Character Recognition – converts scanned text to searchable text.  If it’s searchable, it’s also “taggable,” and properly tagging the content with heading tags, paragraph tags, and others as needed (lists and/ or data tables, for example), makes the document accessible.

Table Headers not defined: 

For data tables to be read correctly by screen readers and other assistive technology, the header cells need not only to be defined as headers (in TH) tags, but their scope also needs to be assigned – column or row – so that screen readers can correctly associate data cells with the correct header cells.

Improper Tag Structure: 

While it’s pretty cut-and-dry that an untagged PDF isn’t accessible and in ADA compliance, a tagged PDF is not automatically accessible.  Some examples of this scenario include if the incorrect tags are used, if the tags are put together incorrectly, or if the reading order isn’t correct.  In those examples, even though the PDF is tagged, it’ll still be inaccessible and out of compliance.   

Images missing an alternative text: 

This is a common problem in web pages and in PDFs.  The issue is, that without alternative text assigned to Figure tags, the screen reader will announce that there’s a graphic on the page, but then doesn’t have any other information to provide regarding what it’s an image of and why it’s important.

How to Evaluate Your PDF Compliance Risk

Find and list all documents in your domain

Take a thorough inventory of your electronic information, including both information that is being disseminated publicly, i.e. on your website, as well as electronic information being provided internally to employees. It’s important to recognize that ADA lawsuits can be brought by consumers and employees, alike, so taking stock of the entire inventory of electronic information available is vital to safeguarding against litigation.

Assess the accessibility level

Once you’ve taken stock of the electronic information that is available, you need to determine how much of it may already be accessible. Once you have a clear understanding of the scope of your problem by separating the information that is already accessible from the information that is not, you are one step closer to having an organized strategy in place for achieving full accessibility of your electronic information.

Prioritize your documents by importance

Finally, prioritize which electronic information to begin making accessible first. You can determine this based on how often the information is used, how important the information is to internal audiences, and how important the information is to external consumers.  Once you’ve answered these questions, you’ll be able to determine which pieces of your inaccessible information pose the largest risk so that you can address those first.

Steps to ADA Compliance

You can put your organization on the path to ADA Compliance by doing the following:

  1. Start a web accessibility program in your organization. Ensure accessibility standards define clear and achievable success criteria. Develop a formal accessibility policy and publish the policy on your website.
  2. Consider changing existing policy to share the burden of creating accessible content from the CIO/webmasters to the “content creators,” while maintaining central control over overall ADA compliance.
  3. Allocate appropriate resources towards the problem of document accessibility, including budget allocations for accessibility coordinators, software tools, training, and remediation.
  4. Consider whether to do the work in-house or to outsource.  If outsourcing, be sure to work with reputable vendors who really understand the complexities of PDF accessibility and who will stand behind their work.
  5. Many organizations have focused their accessibility efforts on HTML/CSS content. Remember to also focus on your PDFs–they are often a major cause of accessibility non-compliance.
  6. Identify, research, and utilize verification and remediation tools for ADA compliance when available.

Compliance Means a Richer Experience for Everyone

Regardless of your business, your website represents you and your brand. Before you find out from a lawsuit that you’re not in compliance, the time to act is now!

Make sure that all your online resources – including websites, PDF documents, and mobile apps – follow industry standards like compliance with the latest Web Content Accessibility Guidelines (WCAG). Look for ways to make your site more inclusive for all, including those with disabilities.  Your goal should be to ensure that all your potential users can access and do business on your site.

Not only will you be reducing the risk of litigation, but you’ll be making your business available to more consumers and enriching their experiences, too.

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