Release of WCAG 2.0 Techniques for PDF

Andrew Arch - AGIMO
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On 3 January 2012, the World Wide Web Consortium (W3C) Web Accessibility Initiative (WAI) published updated Techniques for Web Content Accessibility Guidelines (WCAG) 2.0, including new techniques for the Portable Document Format (PDF) and Silverlight, and an update to Understanding WCAG 2.0. With these new techniques now released, agencies need to incorporate as many of them as practicable, as well as the applicable general techniques, to increase the accessibility of their PDFs.

For a refresher on how to create accessible PDFs, refer to the slides from the Adobe education session held in March 2011 and published on the Web Guide. Other resources include:

The W3C How to Meet WCAG 2.0: A customizable quick reference now includes a view of the PDF and general techniques through the customisation panel. We look forward to seeing many more accessible PDFs and will be interested in agencies' experiences with these new techniques.


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

Comments (36)

Hi again Peter

I actually have been using this methodology as we've been working on it. Also, I do use a scoring system for my PhD research as I need to be able to compare websites, counting violations. It will be interesting to compare the manual to the automated tool scores.

Glad you found the methodology interesting - hope you'll give it a try and let us know your thoughts.


Hi Peter and group

Have you looked at the Public Working Draft of the W3C WAI Evaluation Methodology that was just released for public comment? It will provide some valuable ideas for evaluating websites including how to select sample pages. I hope this helps.


Hi folks,

I fired a few questions through to AGIMO's WCAG 2 team in July to clarify a few things. The responses I got were quite helpful so I thought I'd share them with you all:

QUESTION: I’m sure we all have the best intentions, so just want to know, will there be any repercussions for agencies who aren’t 100% WCAG 2.0 compliant by end of Dec 2012 and especially Dec 2014?

ANSWER: We are aware that many agencies face a challenge to meet the Level A/Dec 2012 checkpoint and we hope to provide guidance on our position on this in the near future. One proposal being looked at (and I emphasise that this is just a proposal for now) is to ask agencies to provide a progress report and action plan for AA compliance if they cannot ensure A compliance by 1 January 2013. As you may gather from that, we’re aiming to assist rather than punish.

QUESTION: After December 2014, is AGIMO going to continue to consult with those agencies that haven’t yet completely complied, requiring them to continue reporting on their progress (or something similar)?

ANSWER: We have not settled any approach to accessibility beyond December 2014. I suspect we will only develop a formal plan for this period once we have surveyed the outcomes of the December 2012 checkpoint and have a feel for how agencies are progressing.

QUESTION: Do we need to provide alternative formats internally, if we know what software every staff member has installed (e.g Word, Acrobat reader etc)

ANSWER: If this knowledge means you can guarantee that every staff member will have equal access to documents, then a single format is fine. But if e.g. a staff member uses some form of assistive technology in their work, you need to ensure that your chosen format is compatible with that technology.

We received much the same answers from AGIMO when asking similar questions.

My department cannont (due to lack of staff, budget and time) meet Level A by Dec 2012. It is possible that our main website will - but we are much more than one corporate website...

We have 85 external applications and 20 websites and only one Accessibility Analyst with a contract that expires on Xmas Eve (that's me btw) - not to mention the 100's of internal applications that are already deemed out of scope because of the above reasons.

IMHO, too much time has been wasted hiring external contractors to do small amounts of conformance checking; too much money has been spent on sending staff to awareness days that provide little to no practical advice; and not enough time has been spent on restructuring the work practices of our department to create best practice, accessible websites and applications.

As I've heard repeatedly from managers and developers - they need extra budget to do things properly - but our budget was once again cut this financial year...

We are aiming to go striaght for the AA by Dec 2014 - without trying to meet a Level A stage gate on the way...

I'm not sure we'll make it, but we are drafting our implementation plans now. Our biggest issue is that nothing we have meets WCAG 1.0 - so it's a monumental task in front of Geoscience Aus...

I just re-read that previous email. Please excuse my deplorable typing - must have been really tired. :)

Hi Vivienne,
It was M Lawrence that was after the PDF - I was offering to help him as well! I'm an Accessibility Analyst myself...
Thanks for the kind offer though!


The Commission will review the accessibility of PDF documents again in 2013, by which time it is expected that the provision, support, and utilisation of accessibility features will have improved.

If you follow the Sufficient Techniques provided by the W3C, you should be OK...

It would then be worth testing the PDF with other tools and possibly letting an Accessibility Analyst review it for you too...

Hope that helps - and if you can't find anyone, please send me an email and I can point you in the right direction...

HI Peter
Let me know if you'd like the PDF tested. I also have people who can develop the PDF if you don't have the ability in-house. The Sufficient Techniques are really good once you get your head around them.

Hi Andrew,

With the available techniques does this mean we can rely on SmartForms, or again is AGIMO recommending an alternative format is available?

I'm new to the area of SmartForms but am anticipating having to field a lot of questions from one of our business areas which uses them.

With regard to providing an 'alternative format' is it sufficient to refer users to paper forms or application over the phone?

As an accessibility advocate I like to think that it should be an equivalent 'on-line' experience', e.g. HTML, but again I can anticipate this argument coming up.

Further to that where does AGIMO stand regarding alternative formats being, send us an email we'll send out a paper based resource, or here's our toll free number call us. I get a feeling that this argument might get used a lot.

Thanks for your input.

We have big reports in full Accessible PDF do we have to create equivalent HTML file or can we just link the accessible PDF?

I would like to raise a question regarding Accessibility and Specialist audiences.

I understand that content intended for specialist audiences must take into account the same accessibility considerations as content for non-specialist audiences, but it has come to my attention that that there will be cases where the use of specialist software formats is required for which there is no accessible alternative (at this point in time) - for example: Seismographs, CAD drawings, Bathymetry, and I could rattle off a few more.

Will the Web Guide take into consideration that some things published on the web may never be made Accessible (with current coding techniques), and Accessible Alternatives may never exist for things that have a very limited audience?

I understand and agree that Standards exemptions for specialist audiences should not be presumed, as members of a specialist audience cannot be presumed to be without disabilities affecting their Internet use, or to have scripting or plugin-enabled browsers.

I think I'm after a 'ruling' that states that departments must provide a summary, file format and file size and a method by which the user can contact the department for assistance in accessing the inaccessible content...

As departments move towards "standards based" development, these issues will lessen over time, but I'm currently auditing my department and finding applications that are 15 years old or older, which have extremely limited audiences, and very limited resources for 'retrofitting' accessibility...

Good morning,

I'm wondering whether anything has been mandated yet in relation to use of the Government coat of arms in accessible PDFs, particularly by screen readers?

For example, are the Arms required to be announced by a screen reader (via alt text) and if so, must they be the first item announced in the reading order?

Alternatively, can we simply not worry about them (and tag them as Background images).

I look forward to hearing from you.

Kind regards, Aaron

I'd have to agree with you Vivienne - it is a case of a few 'bad apples'...

Under NTS, do I have to (retrospectively) optimise documents for accessibility if they were published before June 2010 and we currently provide alternative formats (Word and PDF) on our website?

Thanks Shari,

If your content is published primarily in accessible HTML with the PDF provided as a convenient printable alternative, then it isn’t required to utilise the PDF Techniques. However, it would be good practice to incorporate the applicable PDF and General techniques to enable the widest group of visitors to easily search the entire document and to read the document offline.

Hi Clare,

The issue of accessible office documents is a whole other area of accessible e-publishing, albeit closely related. The best advice on this topic, apart from Microsoft’s accessibility pages, comes from the OCAD University’s Accessible Digital Office Document Project undertaken for UNESCO and the Government of Ontario.

Trust this helps.

Hi Andrew,

I'm aware there will be publicity around AGIMO and WCAG 2.0 once the transition is complete. So if agencies aren’t 100% compliant, they will be at higher risk of complaints as the public will be more aware (especially users who rely on assistive technologies etc). So meeting WCAG 2.0 is the best way to reduce this risk. With this in mind, I have two questions:

I’m sure we all have the best intentions, so just want to know, will there will be any repercussions for agencies who aren’t 100% WCAG 2.0 compliant by end of Dec 2012 and especially Dec 2014?

Is AGIMO going to continue to consult with those agencies that haven’t yet completely complied, requiring them to continue reporting on their progress (or something similar) post Dec 2014?

Thanks, Aaron

Andrew (sorry, but you probably knew this was coming), what is AGIMO's position on the use of PDF when it is

a) the sole format in which content is provided
b) created using all the relevant WCAG 2.0 techniques for PDF (and the more general accessibility techniques)?

Has, or do you anticipate, AGIMO's position to change now?

I'm asking because of this comment on AGIMO's Web Guide at

"Until otherwise stated, agencies must not rely upon any web technology that cannot claim WCAG 2.0 conformance. That is, any technology may be used, but where it cannot prove its accessibility support, agencies must provide multiple accessible formats. Web technologies that claim accessibility support must prove WCAG 2.0 conformance through the use of WCAG 2.0 sufficient techniques."

Hi Andrew

Reading the above it sounds like AGIMO are moving from a requirement to provide an alternative format to PDF, to only 'advising' that an alternative format is provided if the PDF is created inline with WCAG 2.0. Have I understood this correctly?

I appreciate the reference to the Australia Human Rights Commission advice, but government departments we work with are focused on complying with the NTS and if the position has changed then we need to accurately reflect this when talking to government.

Hi Peter
I'm not sure that this is the right forum, but I'm a wee bit concerned about your comments about accessibility consultants. That approach is certainly not what I do. I use an approach similar to yours, using screen readers and other technology to locate possible usability problems as well as determining the compliance with WCAG 2.0. Currently I am doing a state government department site on a page by page, line by line manual evaluation against the guidelines. They have asked for all errors I can locate with all their line numbers along with descriptions of how they can be corrected.

Some consultants may just use automated testing, but we all know that automated tools are mainly useful in locating trends and those items that can be tricky to locate manually. Some automated tools though are really good in locating specific error types.

Maybe it's the case of 'a few bad apples'?

With the release of Sufficient Techniques to make PDFs accessible, does this now put "an accessible alternative" into the realm of the Usability of a document/website rather than Accessibility?

The Accessibility Test Process that I have used in the last three departments I've worked in seems to work quite well (I'm open to any suggestions on how to improve it, and it is free to use for anyone in any department too):

Accessibility Test Process

Step 1: Select representative sample pages

Step 2: Validate code: (both XHTML & CSS validation)
Validation is a process which ensures that web pages match the grammar and syntax of the language it claims to be using. Validation can be considered somewhat like a spell check for code.

Step 3: Colour Contrast Analysis
This is a tool used for checking the foreground and background colour combinations on web pages to determine if they provide good colour visibility. It also contains functionality to create simulations of certain visual conditions such as colour blindness.

Step 4: Evaluate Accessibility with at least two automated tools
For example: Webaim Wave, Deque Worldspace (and Fireeyes in Firefox)
Automated WCAG 2.0 analysis tools assist in determining the conformance of websites to accessibility checks which can be executed automatically. The results are used to focus the manual evaluation of the web pages.

Step 5: Manually evaluate pages against WCAG 2.0 (Level AA)
Automated testing alone cannot determine conformance – a manual evaluation of the pages is necessary as human judgement is required.

Step 6: Read content to establish language level
i.e.: Pages are written using the clearest and simplest language appropriate for the content
The intent of this test is to discover whether text content on a webpage can be read by users and by assistive technologies, and to ensure that information necessary for understanding it is also available.

Step 7: Examine pages in multiple browsers
For example: IE6, IE7, Firefox, Chrome, Opera and Safari
Different browsers render web pages in different ways. It is important to discover if there are any serious rendering issues present on browsers other than the GA SOE browser.

Step 8: Examine pages using alternate browsers
For example: Lynx for text: using Opera’s Lynx emulator; Jaws or NVDA for audio browsers
Assistive technologies can be used to read out text content to users. This test will determine whether the functionality present when navigating the website normally is also present when using a text based browser.

Step 9: Examine pages of different platforms
For example: PC, Linux, Apple and various mobile devices
This test will determine whether there are issues present when trying to access web pages using methods other than a traditional computer/web-browser combination.

Thanks for asking this Dey – I’ll try and clarify.

The W3C blog post announcing the release of the PDF techniques states that the “publication of techniques for a specific technology does not imply that the technology can be used in all cases to create accessible content that meets WCAG 2.0” and furthermore that developers and publishers “need to be aware of the limitations of specific technologies and ensure that they create content in a way that is accessible to all their potential users”.

While you correctly state that technologies must have sufficient techniques before they can be relied upon, it is also necessary that the technology has ‘accessibility support’ which requires that “user agents including assistive technologies could access all the information they need to present the content to the user”.

While recent versions of assistive technologies may be able to access all the information provided as a result of applying the newly published techniques, the most commonly used assistive technologies in Australia, as identified in the Australian Government’s study into the Accessibility of the Portable Document Format for people with a disability published in November 2010, may have limitations. Because of this situation in Australia we are currently considering the issue.

In the meantime, while agencies can technically rely on PDF, they are advised to provide users with choice and publish an alternative in line with the Australia Human Rights Commission advice to “make the content available in at least one additional format and in a manner that incorporates principles of accessible document design”.

We welcome the new techniques and expect agencies to incorporate the PDF and general techniques, where applicable, in their documents.

As a W3C member, AGIMO monitors all W3C working groups and participates where appropriate. We are abreast of the progress on the Evaluation Taskforce, however it's proposed evaluation methodology is not yet at a draft stage and so is not considered appropriate for distribution or promotion. If you read the linked testing advice, you will see we recommend generally 10% for medium-large websites and detail content which should always be included (such as indexes, search, navigational element, media etc) or what you might consider "critical processes".

Until such time as a methodology is finalised by the W3C, agencies should follow AGIMO's advice on the matter.

Peter: sounds like a robust approach, glad you have found a good working system. We'll be publishing a "Quick Check" guide in the next few days on the Web Guide, we'd welcome your feedback on that once its released.

Hi Andrew and Jacqui
As you can imagine, this change will have a huge impact on my ongoing research. I'm rather unsure how to address the issue now, as I can't possibly look at each of the PDF's linked to from a website to determine their accessibility. Any suggestions?

I am wondering if there is any guidance on how to make excel documents accessible that have formulas and are therefore locked?

Also with relation to Word Fillable forms - does a screen reader read a field that is a calculated?? If not, what technique would you use to convey this information?

Many thanks,

We've translated some of our brochures into Arabic, French, Vietnamese, Simple and Traditional Chinese and we link to PDF versions of them on our website. We provide equivalent English html and PDF versions. Do we have to make the non-English PDFs accessible too?

I was wondering if anyone could point me in the right direction please?

I am preparing a PDF booklet for publication that needs to meet WCAG 2.0 accessibility requirements for online publishing.

I have never worked with anything like this before and was wondering if anyone could recommend web designers/developers/DTP operators or the like that would be able to design and prepare such a PDF document?

Any suggestions or direction much appreciated.

Thank you,

M Lawrence

Hi Andrew
As you know, the Evaluation Methodology Task Force of the W3C WAI is working on a website accessibility evaluation methodology for everyone to use. We are suggesting that people don't just use the 10% rule, but include a selection of pages that are most critical for users (key reason for the website), pages form part of critical processes, and a further random sample, trying to cover as many of the WCAG 2.0 concepts as possible. This would not always equate to the 10% guideline suggested.

Can I propose forming a movement to convince agencies to abandon PDF? The effort required to make these files accessible, in particular lengthy and complex document files, is a massive burden. And we're all facing resource cutbacks.


Just a quick question - if you have content (e.g. a report) that is fully available in HTML and you also want to publish a design version in PDF - does the PDF still need to meet the Sufficient Techniques for PDFs?

We have been told this is not necessary but I have not since any written advice to that effect.


HI Aaron and Andrew
I have similar questions about what happens after the NTS.

My PhD research is looking at the changes in website accessibility for government and non-government websites during the NTS. I hope to publishing some journal articles and conference papers as well as my thesis, and I'm sure people will ask about the results of the NTS and how it may have had a flow-on effect to other organisations.

I'm very interesting on how compliance will be enforced and if there will be any repurcussions for agencies who don't comply.

I'm also wondering if there will be something happening for education next.


if the content is only provided as PDF rather than HTML does this breach WCAG compliance?

Also is RTF more accessible than PDF?

Hi Katie – good question. The answer is ‘yes’, in order for the person who cannot see the document to understand what it is about before they potentially seek help to complete it.

Hi Andrew,

Just wondered if you could advise me on what is probably a silly question. Do documents that are uploaded on the web but can only be completed by printing them out, have to meet WCAG 2.0 requirements?

I am talking about legal waiver documents and such that we have up for ease of providing them to clients but they aren't able to be filled in electronically because of the requirement for signatures/witnesses etc.


Last updated: 01 August 2016