Is PDF accessible in Australia?

More than two years ago I wrote about WCAG 2.0 and Accessibility Supported, and my fear that, “the concept of ‘accessibility supported’ is not fully understood”. I believe that this “could put at risk the whole move to improve the accessibility of the web.” I am concerned that mixed-messages relating to the status of PDF as a “web content technology” is still causing problems within Australia at least.

I have presented many workshops about web accessibility and WCAG 2 compliance and the issue of “accessibility supported” is at the heart of some of the most common questions I get asked. Specifically, many developers want to know if they are still required to provide an accessible alternative for the PDF and/or JavaScript they include in a site. When answering questions like this I stress, of course, the need to ensure all content is as accessible as possible and the five Conformance Requirements for WCAG 2.0. But at a practical level this doesn’t fully answer the question because Conformance Requirement 4 states, “Only accessibility-supported ways of using technologies are relied upon to satisfy the success criteria”.

Now this would all be fine and dandy if developers were able to clearly identify which web content technologies, when used appropriately, are sufficiently supported by assistive (adaptive) technologies to be considered “accessibility supported” within the meaning of WCAG 2.0. However, when WCAG 2.0 was released in December 2008, the WCAG Working Group and the W3C effectively side-stepped this question, and more than three years later they continue to do so.

“The Working Group, therefore, limited itself to defining what constituted support and defers the judgment of how much, how many, or which AT must support a technology to the community and to entities closer to each situation that set requirements for an organization, purchase, community, etc.”

Understanding Accessibility Support

In Australia, this effectively means handing the decision over to the government regulators, most importantly the Australian Human Rights Commission and the Australian Government Information Management Office (AGIMO).

Changing attitudes

When it comes to all forms of disability rights in Australia, the Australian Human Rights Commission plays a key role in implementing the Disability Discrimination Act 1992, which it does (in part) through the issuing of Standards, Guidelines and Advisory notes. The Advisory Note relating to web content accessibility now references WCAG 2.0 and advises all sites move to Level AA compliance over the next few years. The Advisory Note doesn’t explicitly preclude the use of JavaScript (or Flash for that matter) but it does require them to be implemented in a way that is accessible. The attitude to the use of PDF however is significantly different:

“The Commission’s advice, current October 2010, is therefore that PDF cannot be regarded as a sufficiently accessible format to provide a user experience for a person with a disability that is equivalent to that available to a person without a disability, and which is also equivalent to that obtained from using the document marked up in traditional HTML.”

World Wide Web Access: Disability Discrimination Act Advisory Note (Version 4)

The websites of all government agencies in Australia are required to transition to WCAG 2.0, Level AA compliance, by the end of 2014. The Australian Government Information Management Office (AGIMO) is managing this transition through the National Transition Strategy (NTS), and the Government Web Guide provides an overview of what is required in terms of accessibility and which web content technologies can be used:

“Web technologies that claim accessibility support must prove WCAG 2.0 conformance through the use of WCAG 2.0 sufficient techniques

Agencies are reminded that it is still a requirement to publish an alternative to all PDF documents (preferably in HTML). … Agencies must abide by the Australian Human Rights Commission’s Disability Discrimination Act Advisory Notes in order to mitigate risk of disability discrimination complaint.”

Australian Government Web Guide: Accessibility (April 2011)

None of these documents appear to explicitly address the question of which web content technologies can be considered “accessibility supported”. However, with the exception of PDF, the Advisory Note and the Web Guide both seem to suggest that, any web technology, including JavaScript, can be considered “accessibility supported” if, for each relevant Success Criteria, there are recognised W3C Sufficient Techniques relating to that technology.

While I didn’t fully agree with excluding PDF, that all seemed reasonably clear until January this year when AGIMO posted an article on their blog about the Release of WCAG 2.0 Techniques for PDF. The main article is short, comprising an outline of the situation and various resources. However, in the comments, various people ask if this means that PDF (when used appropriately) can now be considered “accessibility supported”, to the extent that it is no longer necessary to provide multiple accessible formats. In answering this question, Jacqui van Teulingen, the Director of AGIMO wrote in part:

“As stated, the PDF Sufficient Techniques are now available, so technically an agency can rely on PDF by using the WCAG 2.0 PDF Sufficient Techniques and all applicable General Techniques, and will be considered to be complying with the NTS.”

Release of WCAG 2.0 Techniques for PDF (January 2012)

On the face of it, this comment seems to be at odds with the directive in the Australian Government Web Guide and the advice provided in the Human Rights Commission Advisory Note relating to web content accessibility. And, I suspect, once again there are developers, particularly those working on sites for government agencies, left wondering, or maybe even wandering…

We need clarity

This issue is not just about the use of PDF, but rather the process in Australia for determining those “web content technologies” that are considered acceptable and those that are not. I find it really hard to understand how Flash can be declared acceptable but PDF unacceptable, when both can cause significant accessibility problems when used inappropriately. Surely, it should not be a question of what technology is used, but how it is used.

When it comes “accessibility supported”, rather than precluding some web content technologies and not others, I believe the authorities should rely on the existence of Sufficient Techniques for each relevant Success Criteria as the main determinant of whether the use of a particular technology is accessible. That means, for example, if a web document has an image, there is a technique that allows an accessible alternative for that image, and if there are headings, then there is a technique that will allow them to be presented by different user agents, including commonly used assistive technologies.

I think the Australian authorities should consider the approach to the issue of “accessibility supported” (WCAG Conformance Requirement 4) as outlined in the Government of Canada Standard on Web Accessibility:

“Conformance requirement 4 (Only Accessibility-Supported Ways of Using Technologies) defines the ways of using technologies that can be relied upon to satisfy the success criteria. It can only be met by use of the following technologies:

  • XHTML 1.0 or later excluding deprecated elements and attributes,
  • HTML 4.01 excluding deprecated elements and attributes,
  • HTML5 or later excluding obsolete features, or
  • Technologies with sufficient techniques (specific to each technology) to meet all applicable success criteria.”

Government of Canada Standard on Web Accessibility (1 August 2011)

I believe it is time the Australian Government Information Management Office and the Human Rights Commission fully embrace both the spirit and the recommendations of WCAG 2.0. The accessibility of websites should be determined by how well they satisfy the five WCAG 2.0 Conformance Requirements regardless of the web content technology used.


  1. Thanks for taking the time to post your thoughts on this, Roger. It sets out the problem clearly. And it’s not just developers who are shaking their heads on this issue. Every day thousands of content authors and hundreds of content managers are wondering where they stand on the use of PDF.

    The Canadian position is certainly much clearer than ours. But I wonder what the impact will be on people with disabilities who rely on older technologies should we adopt this stance? This of course leads us back to your initial concern – the lack of information about assistive technology support for various web technologies.

  2. A decision on or an approved technique for creating accessible PDFs is certainly required. However, I disagree with Alex’s concern about older technologies – without forcing users (any users) onto the bleeding edge, there are very rapidly diminishing returns in catering for old tech.

  3. Hi Roger,

    I suspect that the situation is even more complex that you’ve indicated. Australian federal and state governments routinely use PDF files to deploy translated government information on the web. And considering that PDFs are essentially glyph orientated rather than character orientated …


  4. Yes, WCAG 2.0 was a cop-out, which I think was partly due to some proponents of very javascript-using accessibility-impaired webapps being influential among the working group and they’d rather blur the guidelines than produce obviously-accessible versions of their apps. Why not stay with WCAG 1.0 until the route forwards becomes obvious?

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