WCAG Compliance and PDF Accessibility

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Since they became law decades ago, the Americans with Disabilities Act (ADA) and the Rehabilitation Act have required both public and private organizations to make their facilities accessible to everyone. That first included physical accessibility like wheelchair ramps and accessible parking spaces and has since expanded to include websites, PDFs, and other digital resources. Organizations can evaluate the accessibility and compliance of their websites by measuring them against Web Content Accessibility Guidelines (WCAG) standards.

What is WCAG?

WCAG is an international set of rules developed by the World Wide Web Consortium (W3C) in order to provide a technical standard for web content accessibility. They are the most widely accepted accessibility standards in the world. WCAG are the standards adopted by the governments of Australia, Canada, France, Germany, Hong Kong, India, Italy, Ireland, Israel, Japan, Netherlands, New Zealand, Norway, Spain, UK, and many states in the US to measure digital accessibility in your organization. 

Why is WCAG important?

WCAG is referenced in many laws and standards at both the state and national levels. 

Section 508 of the Rehabilitation Act specifically requires federal government agencies and any company that receives federal funding to make their digital resources accessible. That often includes healthcare organizations that receive funding through Medicare/Medicaid. To comply with Section 508, all electronic content, including PDFs, “shall conform to Level A and Level AA Success Criteria and Conformance Requirements in WCAG 2.0.” 

Title II of the Americans with Disabilities Act (ADA) requires digital accessibility for state and local government organizations. It was recently updated to specifically require WCAG 2.1 AA as the measure for compliance. Depending on the size of the state or local population, content must be made accessible within the next 2-3 years.

Title III of the ADA covers accessibility for private enterprises. Its interpretation has expanded to include publicly accessible websites and digital resources. The DOJ has issued clear guidance that organizations must make their content accessible, and they suggest using WCAG as the technical standard. Despite this guidance, many organizations have failed to make their websites accessible and over 4,000 lawsuits have been filed in 2023 alone. A number of rulings by various federal courts for these lawsuits, including the 9th Circuit Court, have cited WCAG as the standards required to be met to comply with digital accessibility laws.

Many states have also adopted WCAG as their digital accessibility standard. One such example is Colorado’s HB21-1110, which requires that all state and local government agency websites comply with WCAG 2.1 AA standards by July 1, 2024. Compliance with WCAG is the best way to ensure your organization achieves digital accessibility, reaches all of your potential audience, and avoids costly lawsuits. 

What does WCAG cover?

WCAG are technical standards of accessibility that define how information should be presented digitally. They outline the way in which digital information should be presented. The standards are based on a 4-pillared philosophy that states that all digital information must be: perceivable, operable, understandable, and robust for all users. Users include both the general public and employees of any organization. WCAG covers websites and software, mobile technology and applications, and digital documents like PDFs. 

How does WCAG relate to PDF accessibility?

As one of the most commonly used digital document formats, PDF accessibility is essential to achieve digital accessibility. PDF documents can be found on many websites and within the files of many organizations. They can be particularly inaccessible for people using assistive technology to access digital information. 

Let’s examine how PDF Accessibility fits into the four pillars of WCAG:


All contents of the digital document must be perceivable. Each element must be digitally labeled (or “tagged”) so that assistive technology can read it to the user. Failure to digitally tag any element means it is essentially invisible to assistive technology and therefore is not perceivable. 


All functionality within the document must be correctly tagged so that assistive technology can make use of it. Any links must be properly tagged and functional so that they can be activated. Footnotes and tables of contents must also be digitally tagged in order for assistive technology users to make use of them. Headings must be tagged correctly; otherwise, people using assistive technology cannot skim through them to find the content they want to read. 


Complex elements such as flow charts, graphs, and images must be correctly described using text alternatives (alt-text). Elements such as lists and tables must be tagged properly or they will appear as an incomprehensible wall of text. Without the correct list and table tags, an assistive technology user will have no idea of the relationship between the items that comprise these elements. 


This means the tags and reading order are maintained regardless of technology or software updates. It means that the PDF will read the same regardless of the tool or browser used to read it. Any tagging applied must carry over regardless of how it is accessed.

Accessibility – don’t forget the PDFs!

WCAG is the most widely recognized standard for not only websites but also digital files located on those websites. As you work on ensuring that your digital content is accessible, assistive technology users, and meets WCAG standards, don’t forget to include your PDF documents. They contain important information that everyone needs to be able to read.


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Tammy Albee

Tammy Albee | Director of Marketing | Equidox Tammy joined Equidox after four years of experience working at the National Federation of the Blind. She firmly maintains that accessibility is about reaching everyone, regardless of ability, and boosting your market share in the process. "Nobody should be barred from accessing information. It's what drives our modern society."

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