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The Australian Government's study into the Accessibility of the Portable Document Format for people with a disability

Executive Summary

People with disabilities face challenges in dealing with the online world. In order to participate in the online world they employ many adaptive strategies and use a range of tools commonly known as assistive technologies. These include text to speech software and screen magnifiers to name a few. The way information is presented online by government and others can make it difficult for assistive technology to do what it needs to. Many technologies have accessibility issues but the Portable Document Format (PDF) is the one most often the subject of web accessibility complaints.

The Australian Human Rights Commission (AHRC) considers Portable Document Format (PDF) files to be generally inaccessible to people with a disability. Since 2000, the AHRC has maintained this strong position and their Disability Discrimination Act: Advisory Notes External Site recommend alternatives be provided when PDF files are used1. To date, the Australian Government has supported this position.

Internationally, perspectives on the accessibility of PDF files are unclear and there is no agreed definition about what constitutes an ‘accessible PDF’. Notwithstanding this, technical advances in the Portable Document Format and improvements in the assistive technologies used by people with a disability are having a major impact on the policy debate.

The Australian Government’s recent endorsement of the World Wide Web Consortium’s (W3C) Web Content Accessibility Guidelines (WCAG) version 2.0 provides a renewed commitment by the Government to web accessibility. To enable the Government to conform to WCAG 2.0 and meet its obligations, particularly in relation to the Disability Discrimination Act 1992 (Cwlth) (DDA) and the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD), a clearer understanding of the implications of using PDF files is required.

It is clear that there is a need for a greater understanding of the way PDF files are accessed by commonly used assistive technologies and the implications in using the Portable Document Format, via various adaptive strategies, by people with a disability.

To address the need for greater clarity on the issue, Vision Australia was commissioned by the Australian Government to undertake this study (the Study). It included a series of user consultations to understand the situational context in using PDF files, followed by technical evaluations assessing the functionality of the most commonly used assistive technologies when interacting with PDF files. The outcome of the consultation and results of the technical evaluations were then tested by people with a disability employing various adaptive strategies to gain an understanding of their experience when interacting with a selection of PDF documents.

It is important to note that accessibility is largely based on situational context. The Study showed there are a number of drawbacks in relying on technical evaluations as the sole determinant of accessibility. While technical evaluation might indicate a product is accessible, the user’s experience in whether they can achieve their specified goals with effectiveness, efficiency and satisfaction is the most important measure of accessibility.

Overall, the Study found that there is insufficient evidence to establish that the development of the Portable Document Format and improvements in assistive technologies have advanced enough for PDF files to be considered accessible for people with a disability, particularly for those who are blind or have low vision.

Importantly, the Study also highlighted that the issues contributing to the inaccessibility of PDF files, when used with assistive technologies, are not in general directly attributable to the Portable Document Format itself. The issues that result in an inaccessible PDF file are, in order of impact:

It should be noted that access to information in any file format, not only PDF, is significantly diminished for assistive technology users if there is no consideration given to these three issues. This Study focused solely on the Portable Document Format as this format is most often the subject of web accessibility complaints.

Furthermore, other than WCAG 2.0 Success Criteria, the Study could not identify an agreed definition on what constitutes an accessible PDF file to enable its accessibility across a wide range of assistive technologies. While the Study identified a body of work being undertaken to establish a set of guidelines for the creation of accessible PDF files by the PDF Universal Access Committee (PDF/UA), the guideline is in draft and not due for release until at least 2011.

As the Government recently endorsed WCAG 2.0, the Study used a number of WCAG 2.0 Success Criteria in the technical evaluations to determine if the use of PDF files with assistive technologies could claim conformance against the Guidelines. Until further data is available on the characteristics of an accessible PDF file and there are Sufficient Techniques available to support the conformance of the PDF technology to WCAG 2.0, the Australian Government position recommending that alternative file formats be provided whenever PDF files are used should remain unchanged.

Key Findings

User consultations (Vision Australia)

Public online consultation (AGIMO)

Technical evaluation

Common assistive technologies

Vendor support

Technical evaluation

User evaluations


The findings of the Study raise the need for:

The Australian Government’s Web Accessibility National Transition Strategy (NTS), released in June 2010, addresses many of the conclusions raised in this Study. The NTS sets out a 4 year work plan for the transition to and adoption of WCAG 2.0. In implementing the NTS governments agencies will need to ensure that the technologies and file formats in use on their websites conform to WCAG 2.0.

The NTS work plan specifically addresses electronic publishing processes, training and education about accessibility issues.

Supporting the Government’s implementation of the NTS, AGIMO are providing resources, advice and guidance for government organisations on its Web Publishing Guide. Complementing the Guide, AGIMO hosts a collaborative community of expertise for people to share their expertise about accessibility and discuss issues. The accessibility of PDF files with assistive technologies will become a dedicated topic of discussion and guidance following the release of this Study.


  1. Australian Human Rights Commission, 2009, World Wide Web Access: Disability Discrimination Act Advisory Notes, viewed 5 April 2010, External Site


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Last Modified: 25 November, 2010