New Texas Law Demands Digital Accessibility—Including PDFs

What is HB 5195?

Texas HB 5195 is a law passed in 2025, effective September 1, 2025, that aims to modernize state agency internet websites and digital service portals. The law adds Subchapter S to Chapter 2054 of the Texas Government Code, titled Modernization of State Agency Internet Websites and Digital Services. 

Key Elements

• State agencies must assess their websites and online service portals to identify improvements in usability, navigation, accessibility, and overall digital service efficiency.

• Simplification of access to forms, applications, and services, reduction or elimination of paperwork where digital alternatives exist.

• Agencies must consider compliance with accessibility standards under Subchapter M.

• Mandated responsive web design — sites must work well on desktops, laptops, tablets, cell phones.

• The Department of Information Resources (DIR) must develop and provide guidance, templates, and best practices, help standardize modernization efforts, provide technical support.

• Reporting: DIR has to submit a report by November 15, 2026 outlining status, priorities, challenges. And there is to be a review of digital modernization efforts, including cost-efficiency and effectiveness, with findings biennially until (some sections) expire.

What is Subchapter M (Accessibility Standards) and How It Ties In

Before HB 5195, Texas already had Subchapter M within Chapter 2054, which deals with Access to Electronic and Information Resources by Individuals with Disabilities. 

Subchapter M and related rules (Texas Administrative Code – TAC Chapters 206 and 213) impose accessibility rules on state agencies, institutions of higher education, etc., covering electronic and information resources (EIRs). These include websites, documents, multimedia, etc. 

How HB 5195 Requires PDFs to Be Accessible

One of the less obvious but important implications of HB 5195 is that by enforcing compliance with Subchapter M standards, it essentially implies that documents published by state agencies — including PDFs — must themselves meet accessibility requirements. Here’s how:

1. “Enhancements to ensure compliance with accessibility standards under Subchapter M.”
   HB 5195 directs agencies, in their assessments and any improvements, to include “enhancements to ensure compliance with accessibility standards under Subchapter M.” That means any electronic and information resources (EIRs) used by agencies (websites, documents, PDFs, forms, etc.) should be accessible.
2. Texas Administrative Code & DIR EIR Policy already define that PDFs must be accessible / alternative formats provided.
   • Under the DIR policy “Electronic and Information Resources (EIR) Accessibility Policy”, PDF is specifically mentioned among the resource types that must be accessible.

3. Existing law already requires accessible documents.
   Subchapter M (Texas Government Code, Chapter 2054, Subchapter M) and the TAC 206/213 rules specify that state agencies’ EIRs must be accessible to people with disabilities. That includes documents both developed and procured. PDFs being a common format, they fall under “electronic and information resources.”
4.  HB 5195’s assessment and modernization mandate means agencies must audit/document what is accessible and what is not.

Because agencies have to assess their websites and portals for accessibility (including under Subchapter M) and then plan improvements, that includes identifying inaccessible PDFs and forms, rectifying or providing alternate formats.

Why This Matters: What’s At Stake If PDFs Aren’t Accessible

• Accessibility isn’t just web pages: many critical documents—application forms, legal notices, guidelines, reports—are distributed as PDFs. If those PDFs are inaccessible (e.g. missing tags for assistive tech, images without alt text, improper structure/headings), people who use screen readers, or other assistive devices, may not be able to access them.

• Failing compliance could expose agencies to legal or reputational risk. Texas state rules, plus federal law (e.g. Section 508, ADA), support the idea that public EIRs must be accessible.

• Non-accessible PDFs are a barrier, undermining the aim of HB 5195: better access and usability of government services online.

Practical Implications & What Agencies Should Do

To comply, state agencies should:

• Inventory all PDFs, forms, and document‐type resources published on their site or in portals.

• For each, check whether it is accessible: tagged appropriately, alt text on images, semantic structure (headings), searchable text (not just scanned images), etc.

• If a PDF is not accessible, either remediate it (make it accessible), provide an alternate format (e.g. HTML or accessible PDF), or phase it out/replace if feasible.

• Use DIR’s templates, guidance, and best practices to ensure consistency.

• Establish processes such that in future, any newly produced or procured document is created in accessible format from the start.

• Track and report these efforts, as legislative and compliance reporting kicks in under HB 5195.

Making compliance easy for PDFs

State agencies don’t have to tackle PDF accessibility on their own. Equidox Software makes it fast and easy to remediate PDFs so they meet Texas and federal accessibility standards. With AI-powered tools and a user-friendly interface, even non-technical staff can quickly convert inaccessible documents into fully compliant, screen-reader–friendly files. By streamlining the remediation process, Equidox helps agencies save time, reduce costs, and ensure that all residents can access critical information and services.

 

Modernization Includes Accessibility

HB 5195 is a strong step toward making Texas government digital services more accessible, usable, and modern. It requires modernization efforts and assessments that include making PDFs accessible. Tools like Equidox Software can make this process much simpler for agencies by streamlining PDF remediation, reducing compliance risk, and ensuring that all Texans can access critical digital content.

Nina Overdorff

Nina comes to Equidox with years of sales and marketing experience from a variety of industries and holds a BS in Language Arts Education. Nina has a passion for words, storytelling, and information, which she believes everyone should have access to regardless of ability. After spending time as a teacher with a blind student, she became much more aware of the limitations and abilities of web accessibility, and how essential it is to those experiencing disabilities. “Being able to access information equally ensures that everyone has an equal opportunity for education, employment, and success in life.”