In brief
Documents such as PDFs and Office files are part of the EAA when they belong to an in-scope service: terms and conditions, invoices, tickets, statements, brochures and forms. Article 2(4) excludes office file formats published before 28 June 2025, but not new or updated ones.
EN 301 549 has its own clause for non-web documents. The practical aim is a tagged, structured document that works with assistive technology.
When are documents covered?
- Documents that you publish on a website or in an app are website and app content, and Article 2(4) lists exclusions for it. See content exclusions.
- Documents that are part of an in-scope service, such as the contract, invoice or ticket you give a customer, are part of the service. See EAA scope.
- The Directive speaks of "office file formats" published before 28 June 2025. Whether a given PDF counts as one is a question for national guidance. When in doubt, treat PDFs as in scope.
In EN 301 549
EN 301 549 has a separate clause for non-web documents. It applies WCAG success criteria to documents where they are relevant. Check the standard for the exact clauses, because document requirements are not identical to web page requirements.
What an accessible document needs
These are the main points, with the WCAG criterion behind each. The mapping is practical guidance, not a clause reference:
- Tagged structure: real headings, lists and tables instead of visual formatting (info and relationships).
- Reading order: the tag order matches the visual order (meaningful sequence).
- Image descriptions: alternative text for informative images and an artifact tag for decorative ones (non-text content).
- Document title: a descriptive title that the viewer shows (page titled).
- Language: the default document language, and language changes where they occur (language of page).
- Contrast: text and images with enough contrast (contrast minimum).
- Real text: no scanned page images without a text layer.
How to make them
- Write the document in a proper authoring tool and use its styles for headings, lists and tables.
- Add alternative text, set the language and the title, and check the reading order.
- Export with tags. In Word and similar tools there is an option to create a tagged PDF.
- Check the result in a PDF tool and with a screen reader, and fix tags where needed.
- Where practical, also publish the same content as an accessible web page.
What to do
- Inventory your documents. Note the date of publication and whether they belong to a service.
- Fix new and updated files first. The date-based exclusion does not cover them.
- Use templates. Build accessibility into the source templates for contracts, invoices and brochures.
- Check with a screen reader. Open a sample of PDFs and listen to them.
- Offer an alternative. An accessible web page or other format on request.
Common mistakes
- Scanned PDFs with no text layer. Assistive technology cannot read them.
- Visual headings that are not tagged. A bold line is not a heading for a screen reader.
- Wrong reading order. Columns and sidebars can be read in the wrong sequence.
- Tables used for layout. Use tables only for data and mark up headers.
- Assuming old files stay excluded after editing. A new version published after 28 June 2025 is not covered by the date-based exclusion.
Sources
This page is for informational purposes only and is not legal advice. For binding requirements, refer to the official text of the European Accessibility Act (Directive (EU) 2019/882) and to the national law of the Member State where you operate.
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