PDF accessibility for public sector websites

This memo summarises official public sources and converts them into website-ready wording. It is designed for public bodies and public-facing services. It is not a substitute for jurisdiction-specific legal advice.

Executive summary

The HTML-over-PDF position in the UK is direct and explicit. GOV.UK states that HTML is the most accessible format for publishing documents and should be the first choice whenever possible. Government publishing standards go further for government documents and require HTML5 for published document attachments, with PDF/A used where a PDF is needed and an open format published with it.

The public-sector position in the United States is different in form but still supports prioritisation. The 2024 Department of Justice Title II web rule covers documents, including PDFs, but it also recognises that public entities need to prioritise current and commonly used content. It creates limited exceptions for archived web content and preexisting electronic documents, while preserving the underlying duty to provide effective communication and accessible access when needed.

The public-sector position in the European Union is built mainly around the Web Accessibility Directive. The Directive and the related implementing acts require an accessibility statement, a feedback mechanism, and clear explanation of non-accessible content, including accessible alternatives where appropriate. Older office file formats are treated differently where they fall outside scope unless needed for active administrative processes.

Across all 3 jurisdictions, the safest public position is an active one. Publish current and important information in the most accessible format available. Prioritise documents that people rely on most. Preserve a functioning route for users to request accessible versions. Explain any burden-based position carefully. Keep that position under review.

The strongest website wording avoids absolute claims. It does not say that PDFs can be left as they are. It does not say that an alternative format always solves the legal issue. It says that the organisation is improving access in a planned and prioritised way, publishing key information in accessible web formats where possible, providing accessible alternatives where appropriate, and responding to requests for accessible formats when needed.

For public bodies, best value for citizens is strongest when tied to access outcomes. The practical message is that effort is being directed first to the documents and services people actually use, so that the greatest accessibility improvement is delivered sooner, while support remains available for content that has not yet been fully remediated.

1. The HTML-over-PDF position in the UK

The UK position is the clearest of the 3 jurisdictions. Official GOV.UK guidance states that HTML is the most accessible format for publishing documents and should be the first choice whenever possible. That position is reinforced by Government Digital Service guidance explaining that PDFs are harder to find, use, maintain, adapt, track, and keep current, especially on mobile devices and with assistive technology.

For government publishing, the standards are stricter still. Government publishing standards state that HTML5 must be used to publish government documents as attachments to web pages. Where a PDF is needed, it should be PDF/A, and an open format should also be published with it. The reason given is practical and user-facing: citizens, businesses, and delivery partners must be able to access and read government information on their chosen devices.

The website implications are straightforward. Where information is current, important, frequently used, or central to a service, the strongest position is to publish it as HTML or another directly accessible web format. A PDF can still have a role where there is a need for download, printing, archiving, or record integrity, but the public-facing content should not rely on the PDF alone if an accessible web version can reasonably be published.

The legal framework sits across 2 linked layers. The Public Sector Bodies Accessibility Regulations 2018 require public sector websites and apps to be accessible and to publish an accessibility statement. The Equality Act 2010 continues to require reasonable adjustments. GOV.UK guidance makes clear that even where content is exempt or fixing it would be a disproportionate burden, a public body may still need to provide the information in an alternative accessible format when requested.

That means the safest UK website wording is not defensive. It should explain which documents are still in PDF, which documents are being prioritised, where an accessible alternative is available, how users can request an accessible version, and how quickly the organisation aims to respond.

UK points that can be stated publicly

Where possible, information is published as HTML because this is usually the most accessible format.
Important and frequently used documents are prioritised first.
Some original PDFs remain in place where they are records, archives, third-party files, or static download versions.
Accessible alternatives are provided where appropriate.
If a document is not yet accessible, users can request it in an accessible format.
Any disproportionate burden position is documented, explained, and kept under review.

2. The public entity position in the United States

The United States does not frame the issue as bluntly as the UK. The 2024 Department of Justice Title II web rule is built around WCAG 2.1 AA conformance for web content and mobile apps, including documents such as PDFs. The starting point is therefore technical compliance, not a general HTML-first rule.

Even so, the official guidance gives public entities room to prioritise. The Department of Justice says it is important that state and local governments can choose the most important content, such as current or commonly used information, to make accessible quickly. The rule also includes limited exceptions for archived web content and preexisting conventional electronic documents, including PDFs, in defined circumstances.

The exceptions are narrow and should be treated carefully. A preexisting document exception does not apply to documents currently used to apply for, gain access to, or participate in a public entity's services, programs, or activities. A legacy PDF that still functions as a live form, application, instruction, or public access document therefore needs closer treatment than an older file kept only for reference.

The Department of Justice also places clear guardrails around separate versions. Conforming alternate versions may be used only where it is not possible to make the web content directly accessible because of technical or legal limitations. The official commentary explains that alternate versions should be used rarely, because the preferred outcome is direct accessibility in the main content rather than a separate parallel experience.

The safest public wording for a US public entity therefore combines 4 elements: compliance with the ADA rule where it applies, prioritisation of current and commonly used content, careful treatment of legacy and archived material, and a clear effective-communication route for anyone who needs access to a document that is not yet accessible.

US points that can be stated publicly

Current, commonly used, and service-critical documents are prioritised first.
Some older or archived files may fall within a limited exception under the DOJ rule.
Where a document is not yet accessible, the public entity still provides effective communication and accessible access when needed.
Separate alternate versions are used only in limited circumstances, especially where technical or legal limitations prevent direct accessibility.
The website should make it easy for a user to report a problem or request the information in an accessible format.

3. The public-sector position in the European Union

The main public-sector framework in the European Union is the Web Accessibility Directive. The Directive requires public sector websites and mobile apps to be accessible and to publish an accessibility statement. The Commission's policy pages and implementing acts also require a feedback mechanism and make clear that accessibility statements should identify non-accessible content and indicate accessible alternatives where appropriate.

The Directive also creates important boundaries around older document content. Office file formats published before 23 September 2018 are generally outside scope unless they are needed for active administrative processes. That distinction is important for public bodies managing large estates of legacy documents. The position is not that older files can be ignored. The position is that active and service-relevant content must be treated differently from older content that sits outside live administrative use.

The disproportionate burden concept remains relevant in the EU public-sector framework, but it is not a free-standing excuse. The Commission's policy material and related evaluation work describe it as something that must be assessed, justified, and reviewed. The accessibility statement must still explain the position and identify accessible alternatives where appropriate.

The European Accessibility Act should be kept distinct from the Web Accessibility Directive. The Act applies to specified products and services and is not the general rulebook for all public-sector website statements. Where an organisation or service falls within scope of national EAA implementation, wording should be checked against that national law. For standard public-sector website statements, the Web Accessibility Directive remains the central starting point.

The safest EU-facing wording therefore focuses on accessibility of public information, treatment of active administrative content, explanation of non-accessible content, indication of alternatives where appropriate, and a visible route for users to request help.

EU points that can be stated publicly

Accessibility statements should describe non-accessible content and accessible alternatives where appropriate.
A feedback mechanism should allow users to report issues and request information in an accessible format.
Older office files can be treated differently from documents needed for active administrative processes.
A burden-based position should be evidenced and kept under review.
Public-facing wording should not confuse the Web Accessibility Directive with the European Accessibility Act.

4. Recommended public-sector PDF operating model

A strong operating model starts with format choice. New and updated public information that is intended to be read on the web should be published in HTML or another directly accessible web format wherever possible. That is the clearest route to better accessibility, easier maintenance, stronger search visibility, and better use on mobile devices.

The next layer is prioritisation. The documents that should be addressed first are the ones people rely on most: forms, instructions, policy information, service guidance, notices, timetables, rules, public rights information, and any document needed to apply for, access, or participate in a public service.

The third layer is alternative provision. Some original PDFs may still need to remain in place because they are records, signed documents, board papers, archived material, third-party documents, or static files that need to be preserved in their original form. In these cases, the public website position is strongest when the organisation provides an accessible alternative where appropriate, or a clear route for a user to request one.

The fourth layer is burden and review. A disproportionate burden position should be treated as a temporary and evidence-based governance position, not a standing excuse. The website should explain the position carefully, identify the content affected, describe what is being done instead, and confirm that the decision is kept under review.

The fifth layer is best value for citizens. The most defensible way to use that phrase is to tie it to faster public benefit. It is better to deliver early, real accessibility improvement across the documents people use most than to delay public benefit while trying to remediate every low-use or obsolete file in one large batch.

5. Publication-ready website wording

The wording below is drafted for direct use on public-facing websites. It can be copied and adapted. Any wording about disproportionate burden, exemptions, or response times should only be used if it is true for the organisation concerned.

UK – short accessibility statement paragraph

We want the information on this website to be accessible to as many people as possible. Where possible, we publish information as web pages because this is usually the most accessible format. Some content is still provided in PDF or other document formats. We are prioritising the documents people use most and the documents that are most important for accessing our services. If you need a document in an accessible format, contact us and we will review your request.

UK – detailed statement section on PDFs

PDFs and other document formats can be harder to use than web pages, particularly on mobile devices and with some assistive technologies. For that reason, where possible, we publish new information as HTML pages.
Some documents on this website are still published as PDFs or other file formats. Our approach is to prioritise:
documents that are frequently used
documents that are needed to access a service
documents that contain important current public information
documents where an accessible web version would provide a clearer and more consistent user experience
Some older documents may not yet be fully accessible. In some cases, making a particular document fully accessible immediately may be a disproportionate burden. Where that applies, we explain the position in this accessibility statement, keep it under review, and provide an accessible alternative where appropriate.
If you need a document in an accessible format, contact us using the details below.

US – detailed accessibility statement section on documents

Our goal is to make the web content we provide accessible in line with applicable ADA requirements. This includes documents made available through our website.
Because public entities may have a large volume of older documents, we are prioritising:
current and commonly used content
documents needed to apply for, access, or participate in our services, programs, or activities
documents that materially affect the public
Some files must remain available in their original form because of legal or technical limitations. In those limited circumstances, we may provide an accessible alternative version or another effective means of access where appropriate.

EU – accessibility statement wording

We are prioritising the documents people rely on most so that the greatest accessibility improvement is delivered sooner across current public information and active administrative content. In a limited number of cases, making specific content fully accessible immediately may impose a disproportionate burden. Where that applies, we document the reasons, keep the position under review, and indicate accessible alternatives where appropriate.

Request page wording

If you need one of our documents in an accessible format, contact us and tell us:
which document you need
the web address of the document, if possible
the format you need, such as accessible PDF, large print, audio, or HTML
your name and contact details
We will review your request and respond as quickly as we reasonably can. If we cannot provide exactly the format requested, we will explain what we can provide instead.

Common misconceptions to avoid in website wording

Users can email us if they need help, so our PDFs do not need to be accessible.
Disproportionate burden means we do not have to do anything further.
An HTML alternative always solves the legal issue.
All older PDFs are exempt.
Archived documents never need to be provided accessibly.
The European Accessibility Act requires all public-sector websites to use HTML instead of PDF.
Our alternate version is enough in every case.
We do not convert low-use documents because they are not worth it.

Safer wording focuses on active improvement, prioritisation, transparent explanation, accessible alternatives where appropriate, and a live route for users to request accessible information.