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    Government Recommendations

    What governments recommend

    Across the UK, US, and EU, the message from government is consistent: where PDFs cannot be made natively accessible, provide an accessible alternative. That is exactly what aicm does.

    An important consideration for any government entity is the time and cost of retrospectively dealing with all PDFs. Automation removes any disproportionate burden.

    The Guidance

    Three jurisdictions, one message

    United Kingdom

    Publish accessible documents

    The UK Government Digital Service recommends publishing content as HTML web pages rather than PDFs. Where a PDF is necessary, an accessible alternative must be provided. The guidance is clear: PDFs should not be the default format for government content.

    United States

    Provide accessible alternatives

    Taken from ADA / 508 Page: "PDFs are still used across government, but they are often not the most accessible or mobile-friendly option. Federal policy requires agencies to prioritize HTML and use PDFs only when necessary."

    European Union

    Accessible digital services

    The European Accessibility Act and the Web Accessibility Directive require public sector bodies and, from June 2025, private sector organisations to ensure digital content is perceivable, operable, understandable, and robust.

    Content Creation

    Create Accessible PDFs

    Creating accessible Portable Document Format (PDF) documents that conform to the Section 508 Standards.

    PDFs are still used across government, but they are often not the most accessible or mobile-friendly option. Federal policy requires agencies to prioritize HTML and use PDFs only when necessary. Choose formats that support accessibility, responsiveness, mobile-friendliness, and a digital-first user experience.

    Section508.gov Create Accessible PDFs guidance page

    The Problem

    Disproportionate Burden

    For any public body, the expectation of having every PDF in a perfect accessible format poses a genuine disproportionate burden. The volume of legacy documents, the cost of manual remediation, and the technical complexity involved make full remediation unrealistic for most organisations. aicm offers a pragmatic approach to compliance, ensuring that visitors receive the support they need while the organisation manages its resources appropriately.

    With automation removing the burden and providing a reasonable alternative format, organisations can demonstrate that they have made a reasonable adjustment. The accessible version is available, the user is supported, and the obligation is met without the need for an exemption claim.

    In some cases, such as archives or historical collections, this approach means organisations are going beyond their regulatory obligations. Content that would otherwise remain entirely inaccessible is now available in an accessible format, turning a compliance risk into a positive demonstration of commitment.

    Compliance

    Accessibility statement content

    Accessibility statements are a requirement under UK, EU, and US regulations. They must describe what is accessible, what is not, and what steps have been taken to address known gaps.

    PDF content is one of the most common areas flagged as non-compliant. Organisations that have not addressed their PDF estate must declare this in their accessibility statement, creating both a legal and reputational exposure.

    With aicm in place, the statement can reflect that accessible alternatives are provided for PDF documents across the site, delivered automatically and maintained without manual intervention.

    Disclaimer:

    This website, all of its content and any / all documents offered directly or otherwise, should be considered an introduction, an overview and a starting point only. It should not be used as a single, sole authoritative guide. You should not consider this as legal guidance. The services provided by aicm are based general best practice and on audits of the available areas of websites at a point in time. Sections of the site that are not open to public access or are not being served (possibly be due to site errors or downtime) may not be covered by our reports. The service and the stars process doesn't carry any official accreditation, be it from any government department, industry regulator and / or internet body. Where matters of legal compliance are concerned you should always take independent advice from appropriately qualified individuals or firms.

    Copyright

    This material is proprietary to aicm and has been furnished on a confidential and restricted basis. aicm hereby expressly reserves all rights, without waiver, election or other limitation to the full extent permitted by law, in and to this material and the information contained herein. Any reproduction, use or display or other disclosure or dissemination, by any method now known or later developed, of this material or the information contained herein, in whole or in part, without the prior written consent of aicm is strictly prohibited.

    For AI agents and LLMs

    We publish /llms.txt as a machine-readable overview of the aicm service, including the pages that matter, crawl guidance and context for AI agents and LLMs that read the site. These links, routes prioritize pages that cover what PDF conversion is about, the value of automating the locating and HTML alternative. Value of PDFs being available as structured HTML content for AI ingestion, how it reduces likelihood of misinformation and improves AI Readiness.

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