Draft WCAG 2.0 techniques for review – PDF and Silverlight

Andrew Arch - AGIMO
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The World Wide Web Consortium (W3C) Web Accessibility Initiative (WAI) has released draft versions of WCAG 2.0 techniques to support PDF and Silverlight and has issued a call for review. AGIMO are particularly interested in the draft PDF techniques for WCAG 2.0.

The draft techniques generally seem good, and complement the recent PDF accessibility education sessions. However, there is still a potential issue with assistive technologies. The findings of the 2010 Study into the Accessibility of the Portable Document Format for people with a disability considered the 10 most commonly used assistive technologies in Australia1. Comparing these assistive technologies with those listed in the draft techniques, it appears that mainly just users with the latest versions will fully benefit at this stage. We are also aware of some concerns about the inability of PDF to completely separate content from presentation at a level that allows some people with low vision to restyle the documents sufficiently to meet their reading needs. As such, agencies need to understand this issue for low vision, as it will play a role in the determining whether the use of PDF is appropriate. A graphic example showing the finance.gov.au web page follows to demonstrate the linearization, colour and font changes required by some people with low vision.

Screen capture: finance.gov.au as it was designed


Screen capture: finance.gov.au modified as required by some low vision users

The release of these PDF techniques will create an expectation that government will be producing PDFs in line with the new techniques, and users may look to take advantage of the developments in this area, subject to assistive technology support. In the Study into the Accessibility of the Portable Document Format for people with a disability, we stated that once Sufficient Techniques for PDF were released, we would review the position on the use of PDF. As such, it is important that the Community of Expertise reviews the draft PDF techniques – keeping in mind the common assistive technologies in use in Australia – and discusses their applicability to government PDF publishing, and the related issues of meeting the needs of people with disabilities, by commenting to this blog post. AGIMO will be participating in this discussion, and seeking wider input, with a view to responding to WAI’s request for feedback on the draft techniques. We will finalise input on behalf of the Australian Government by mid-August. For those with an interest in Silverlight, draft Silverlight techniques for WCAG 2.0 have also been released and require review and comment. As the draft techniques are a subset of broader WCAG 2.0 documents, W3C has published new complete drafts of Techniques for WCAG 2.0 and Understanding WCAG 2.0 as well as difference-marked versions of both documents:

We invite your feedback on these issues and look forward to a productive discussion.


Comments on this blog are now closed. Please let us know if you would like to discuss this post or have any general comments.


1. Note: The 10 most common assistive technologies in use was based on information provided by assistive technology vendors at time of publishing the Study in November 2010.

Comments (11)

I'd like to add a few comments to the post.

I completely agree that people should go check out the PDF techniques and send in comments. The techniques represent a lot of collective effort on the WCAG working group, but we need them to be as useful as possible. Feel free to suggest additional techniques also if you feel that any are missing.

I'd like to offer clarification in response to the statement above: "it appears that mainly just users with the latest versions will fully benefit at this stage." I believe that the question raised is due to a misunderstanding of the text. This is not a list that is stating that only the most current version of the assistive technologies can be used. We know from the work you did assessing PDF that this is not the case, of course, but the text in the PDF overview document also is indicating that older versions work also. For example, the line for Window-Eyes reads "Window-Eyes 7.2 - screen reader from GW Micro. Window-Eyes was the first screen reader to provide support for PDF files, in Window-Eyes 4.2.". There have been improvements in Window-Eyes and every assistive technology over time, as you'd expect, but this document indicates the assistive technologies that provide support for PDF and only happens to mention the most current version first because that version is the most current.

Also mentioned in the blog post above is the statement that "We are also aware of some concerns about the inability of PDF to completely separate content from presentation at a level that allows some people with low vision to restyle the documents sufficiently to meet their reading needs." It is interesting that the user study conducted by Vision Australia didn't identify these concerns - in fact the low-vision users expressed a 100% satisfaction rating for their experience (95% satisfaction for documents that weren't properly prepared for accessibility, including scanned PDF documents). See http://www.finance.gov.au/publications/pdf-accessibility-study/5-phase_three-user-evaluations.html#tb5 for the data on this.

I do agree that there are additional things that would provide better support for a larger number of users with visual impairments, but there are many features in Adobe Reader and the PDF format which do help already such as support for high-contrast color modification, text resizing, and text reflowing.

The techniques offered will help authors reach WCAG AA support with PDF documents. We have not yet created techniques for WCAG AAA support for PDF, but encourage comments on the current set.

Andrew, thanks for clarifying a potential misunderstanding from the Draft PDF Techniques document about assistive technology (AT) support. We think with the current draft wording, some may interpret the guidance to mean that only the AT latest versions provide PDF accessibility supported, and this might benefit clarification. We acknowledge that AT support has been increasing over time and that some ATs have very good support. However, with much better PDF support in the latest releases of some ATs, it does seem that many AT users will need to upgrade at not inconsiderable expense to gain the most benefit from what PDF now enables.

With respect to the issue of low vision, there are many many different low vision conditions, and a large number of different solutions required. We acknowledge the Study may not have sampled low vision users extensively enough, but due to the range of conditions and requirements, even a larger sample may have missed some requirements.

Finally, we acknowledge the effort of Adobe over the years to continually improve the accessibility features of PDF and the Adobe Reader from both a semantic information point of view and by incorporating other features such as text-reflow. We look forward to further enhancements of these products, and of ATs too, in future releases.

It's difficult to provide any constructive feedback to an entity such as AGIMO, which on a positive note has tried harder than most to change govt agency attitudes to accessibility, but unfortunately has drastically failed. Nearly all fed gov agencies continue to publish online using only PDF regardless of the policies espoused herein. Nothing is done. Nothing has changed. That said I save even greater criticism for the human rights commission because it does not have the guts to name and shame these agencies.

Please DO SOMETHING rather than just continue to talk about it.

Hi Peter

Thanks for the comment. I can appreciate your frustration with the time taken to change attitudes and behaviour for improved web accessibility, but I have to disagree with the sentiment that AGIMO has failed in our attempt to do just this. Since endorsement of WCAG 2.0 (in November 2009), agencies have made great strides in improving the accessibility of their online services, and continue to do so. Moreover, there is a willingness and interest in the field, from all sectors, that is unprecedented (and at times, overwhelming). The success of the accessibility stream on the AGIMO blog is proof of that.

Furthermore, we are only in the first year of the National Transition Strategy, our four year plan to move federal government websites to WCAG 2.0 Level AA.

However, change takes time. And it takes a strong governance framework, clear understanding and commitment. I am not certain naming and shaming necessarily works as well as support and education, but the AHRC did in fact do this with the Web Watch program in 2008. Since then we have made extensive progress in our review of PDF accessibility, though the PDF Accessibility Study and the PDF Accessibility Education sessions (both linked in original post).

The final part of this PDF work comes with the review of draft WCAG 2.0 Sufficient Techniques, the outcome of which will determine how PDFs are used on government websites into the future. We feel talking about it is essential, it's part of the engagement process. It helps us determine whether our policies and approaches are fair and correct and in line the needs of our stakeholders.

And hopefully in time, the impact of talking about it has a beneficial impact on the work that we do.

Thanks for your feedback.

Thanks Raven

I am sympathetic to your comments, but disagree.

The DDA has been around since 1992.

Publishing in PDF only was supposed to have been banned since 2001 - TEN years ago.

The only way visually impaired people will finally get equality is when Adobe ensure PDF's are accessible and not because Aust Govt agencies meet its legal and moral obligations.

I notice another major govt agency published some very important draft legislation today and again it is only available in PDF and Word.


Hi All,

Currently our department is posting PDFs on its website with an accompanying RTF version.
My question is: With the requirements of National Transition Strategy for 2012 in mind - if the PDF is not accessible, but an alternate accessible version such as RTF is available, does the PDF still need to be made accessible?


Hi Raven,

Thanks for your reply. It does raise more thoughts and questions in my mind.

At the end of the day, the Department Head is concerned only with compliance - as in "Can I tick the box?". She is only concerned with the legal issues, not what is best practice, what is more accessible or what is possible, but achieving compliance at minimum cost.

Yes, there are inaccessible RTFs, HTML, and PDFs - so as you say, there isn't really a "good format". Depending on how a document is created and by who, either of the RTF or PDF versions of any one document could be more accessible than the other.

And yes, a person will access the format that best suits them, but that I'm not sure that behooves us to provide everything in all possible formats - all being "accessible as reasonably possible", or does it?

My thinking is if either a PDF or RTF (neither being the original document) is created with care and made as accessible as possible then one format is enough and the compliance box can be ticked. As in - "we've provided the ramp as per the building code, but we're not required to push you up it".

Granted there is "best practice", but I what am really looking for is something definitive - a mandate or ruling (in black and white) from AGIMO that instructs government departments - on this PDF/RTF issue - in their obligations for the National Transition Strategy.

Is there any such thing?


The primary cause of inaccessible PDF and RTF/Word is due to:
* documents that are poorly constructed in the first instance by writers who don't know how to use word processing software 'properly' , and
* documents created in desktop publishing programs by allegedly professional graphic designers who either don't know how or don't want to structure and tag the documents correctly .

Australian Government web teams want to publish accessible material, but more often than not we are the last point in the publishing process. We usually do not have the resources to HTML large documents, and trying to 'fix' poorly constructed PDF is nothing short of an RSI hazard (lots of mouse clicking required).

Craig Thomler recently wrote an excellent article on his blog:
Online-first: Building in web at the front-end, rather than the back-end of government processes
I think Craig's post comprehensively explains the reasons for the continued publication of 'inaccessible' documents on Australian Government Websites.

I accept Peter's view that 10 years would seem like more than enough time to get this sorted out.

However, what those of us who consider ourselves to be accessibility advocates within the APS are attempting to do is pretty similar to trying to turn a bulk carrier around by pushing it with a canoe.

The National Transition Strategy was drafted to allow agencies to make business choices about the way they publish web content providing it meets the standard. It does not prescribe technologies nor file formats; they are business decisions for the agency.

If you’d like to apply a strictly ‘tick the box’ approach you need to provide only one accessible format. In respect to the format, the National Transition Strategy does state that only technologies for which there are WCAG 2.0 Sufficient Techniques can be relied upon to claim conformance. As of today’s date, because the draft Sufficient Techniques for PDF have not been finalised and released, you would not be able to use a PDF as your only accessible format and claim conformance. However, we know this will change over time in which case an agency will be able to rely on an accessible PDF.

However, you must note a ‘tick the box’ single format approach goes against the recommendations and advice provided by the Australian Human Rights Commission, which places people at the centre of accessibility and promotes choice in their consideration of whether information is, or is not, accessible.

The AHRC advises specifically on PDF in their Web Access: DDA Advisory Notes:
“The Commission’s advice, current October 2010, is therefore that PDF cannot be regarded as a sufficiently accessible format to provide a user experience for a person with a disability that is equivalent to that available to a person without a disability, and which is also equivalent to that obtained from using the document marked up in traditional HTML.
Accordingly, organisations that publish documents only in PDF risk complaint under the DDA unless they make the content available in at least one additional format and in a manner that incorporates principles of accessible document design. Additional formats should be published simultaneously with the PDF version, and at least one such format should be downloadable as a single document if the PDF version is available as a single download.
Because the use of accessibility features in PDF documents does improve their accessibility for some users, the Commission’s advice is that all documents published on the web in PDF should be authored to incorporate as many accessibility features as possible.”

Agencies are advised to follow the AHRC’s advice in addition to the National Transition Strategy.

Is there any confirmation to the query from Mark Dale - dated: August 31, 2011 at 4:15 pm

Hi Jacqui

Thanks a lot for the response that really helps and answers a lot of my queries.

Last updated: 01 August 2016