The EU Accessibility Act and PDF: What the Law Requires and What to Do Now

What Is the EU Accessibility Act (EAA)?

The European Accessibility Act (EAA) is the EU directive on accessibility requirements for products and services — formally Directive (EU) 2019/882. It was adopted in 2019, had to be transposed into national law by 28 June 2022, and applies to products and services from 28 June 2025. From that date, a wide range of consumer-facing digital products and services must meet common EU accessibility requirements.

The EAA complements the older Web Accessibility Directive (Directive 2016/2102), which since 2018 has required public sector websites and apps to be accessible. Where the Web Accessibility Directive covers only the public sector, the EAA extends the requirements to the private sector and to a broader range of products and services — including digital content such as PDF documents.

In Denmark, the directive has been transposed into the Act on Accessibility Requirements for Products and Services. Supervision is split across several authorities: the Danish Safety Technology Authority (Sikkerhedsstyrelsen) oversees most products and services, while the Danish Energy Agency, the Danish Transport Authority, and the Danish Maritime Authority cover electronic communications and transport respectively.

In short: the EAA requires that digital services and documents within its scope meet the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. For PDF documents, this means correct structuring and tagging in practice — what the PDF/UA standard (ISO 14289) defines technically. The deadline for new products and services was 28 June 2025; existing services have a transition period until 28 June 2030.

Does the Law Apply to Your Organisation?

The EAA covers consumer-facing products and services across a number of sectors. The most important are e-commerce, consumer banking services, electronic communications, transport-related digital services, e-books and access to audiovisual media services, as well as certain products such as computers, smartphones, payment terminals, and ATMs.

Three conditions typically determine whether your organisation is covered:

• You offer products or services to consumers in the EU. The law applies regardless of where the business is established — including businesses outside the EU that sell to EU consumers. The principle mirrors the geographic reach of the GDPR.
• Your service falls within the EAA’s scope (see the sectors above).
• Your organisation is not a microenterprise. Microenterprises that provide services are exempt.

The microenterprise exemption: a microenterprise is defined as a business with fewer than 10 employees and an annual turnover or balance sheet total of no more than €2 million. Both conditions must be met. You are therefore covered if you have 10 or more employees — or a turnover above €2 million. Importantly, the exemption applies only to services, not products, and it disappears with no grace period as soon as the business grows beyond the thresholds (Taylor Wessing).

The public sector — an important clarification: public authorities have had accessibility obligations since the Web Accessibility Directive (2016/2102) came into force. For the public sector, the PDF requirements are therefore not new under the EAA — but the overall picture of accessibility requirements across the EU has been strengthened. The public sector continues to be governed by the web accessibility legislation and the Danish Agency for Digital Government’s supervision, while the EAA primarily adds obligations for private operators. Read more about the requirements for public websites and PDFs in the guide Digital Accessibility in the Public Sector.

What Does the Law Require of PDF Documents?

The short answer is WCAG 2.1 Level AA, delivered through the technical standard EN 301 549.

EN 301 549 is the harmonised European standard for accessible ICT products and services. The latest published version, v3.2.1 (March 2021), references WCAG 2.1 directly and divides the requirements into Chapter 9 (web), Chapter 10 (non-web documents such as PDFs), and Chapter 11 (software). One important detail: the European Commission confirms that an editorial oversight in the previous version was corrected, so that WCAG 2.1 now explicitly applies to documents downloaded from the web — that is, your PDFs. A newer version, v4.1.1, is in development and is expected to incorporate WCAG 2.2.

PDF/UA — the PDF-specific standard: while WCAG describes what accessible content must do, PDF/UA (Universal Accessibility), ISO 14289, translates the requirements into concrete technical rules for the PDF format. PDF/UA-1 (ISO 14289-1, first published in 2012, revised in 2014, based on PDF 1.7) is the most widely used version. PDF/UA-2 (ISO 14289-2:2024, based on PDF 2.0) is the newest and extends the rules with improved tagging. Both standards can be downloaded at no cost via the PDF Association.

In practice, an accessible PDF document requires the following:

1. Correct tagging and structure — all elements (headings, paragraphs, lists, tables, links, images) must have semantically correct tags in a logical reading order.
2. Alternative text for images — non-decorative images must have descriptive alt text; decorative images are marked as artefacts.
3. Defined document language — the language must be specified in the document’s metadata.
4. Logical reading order — content must be presented in the correct order for screen readers, even in complex column layouts.
5. Sufficient colour contrast — at least 4.5:1 for normal text and 3:1 for large text (WCAG 1.4.3).
6. Bookmarks (navigation) — multi-page documents should have bookmarks that support navigation.
7. Accessible form fields — interactive fields must have descriptive labels and error handling.
8. Correct table structure — tables must have header cells so screen readers can navigate them.
9. Real text — not images of text — scanned pages without a text layer are not accessible.
10. Document title — a descriptive title must appear in the metadata.

How the Standards Fit Together

The confusion around WCAG, EN 301 549, and PDF/UA is a frequent source of uncertainty. This overview clears it up:

WCAG 2.2 was published on 5 October 2023 and adds nine new success criteria compared with WCAG 2.1, while removing one obsolete criterion (4.1.1 Parsing). In practice: aim for WCAG 2.1 AA as a minimum, use PDF/UA as the technical implementation guide, and keep an eye on WCAG 2.2 as EN 301 549 is updated. You can read more in the guides WCAG 2.1 Explained and The PDF/UA Standard.

Deadlines and Transitional Arrangements

The EAA operates with several deadlines depending on whether the matter concerns products, services, or special categories:

The deadlines appear in the EUR-Lex summary of the directive and are confirmed in the Danish implementation. Note that “existing” services means solutions that were in use before 28 June 2025 and have not been substantially modified since. New PDFs published after this date are subject to the immediate requirements — the transition to 2030 does not cover new content.

What Happens If You Don’t Comply?

The EAA is enforced nationally. Article 30 of the directive requires each member state to set penalties that are “effective, proportionate and dissuasive” — authorities cannot simply issue warnings indefinitely. The result is a patchwork of national penalty regimes.

Penalties vary considerably between countries. By way of example, France operates with fines from €5,000 to €250,000 plus up to €25,000 per year for a missing accessibility statement, while Ireland is the only member state with the possibility of criminal sanctions, including imprisonment of up to 18 months for serious and sustained violations. In practice, enforcement usually begins with an order to remedy before actual fines come into play.

Enforcement is no longer theoretical. France filed its first EAA lawsuits in November 2025 against retailers including Auchan, Carrefour, E.Leclerc, and Picard; Norway has issued ongoing daily penalties against a health portal; and both Sweden and Denmark began contacting businesses about compliance in the autumn of 2025.

For most organisations, however, the immediate fine is not the largest risk. It is the combination of reputational damage and a growing volume of complaints from users with disabilities, who now have a clear legal basis to point to.

PDFs in Practice: Scanned Files, OCR, and Conversion to HTML

PDF documents are where many organisations encounter the greatest challenges — particularly two types.

Scanned PDFs are effectively images of paper documents with no text layer. To a screen reader they appear as blank pages. Such documents are not accessible and cannot be made so without first extracting the text with Optical Character Recognition (OCR) and then adding correct structure. Read more about how text recognition works in the guide OCR and Scanned PDFs.

Born-digital PDFs contain machine-readable text but often lack the tagging and structure that PDF/UA requires. Here there are typically two paths: either remediate the PDF so that it meets PDF/UA, or convert the document to accessible HTML. The HTML format offers, in many cases, better responsiveness, user-controlled scaling, and screen reader compatibility than even a well-prepared PDF/UA document — this is explored in PDF to HTML: How to Make Your Documents Web-Accessible.

PDFAccess is built for exactly this: the tool converts both born-digital and scanned PDFs to WCAG 2.1 AA-compatible HTML directly in the browser via WebAssembly, without data leaving the device. For organisations with large PDF archives, conversion can reduce the overall volume of documents that would otherwise require manual remediation.

How to Check Your PDFs

There are two types of check, and both are necessary.

Automated checking (rapid screening) can identify most technical errors — missing tags, missing alt text, incorrect document language. Relevant free tools include:

• PAC (PDF Accessibility Checker) — Windows software from the PDF Association that validates against PDF/UA and WCAG.
• PDFAccess — browser-based, open source, no installation or upload.
• Adobe Acrobat Pro — has a built-in accessibility checker, but requires a paid subscription (Adobe’s guidance).

Manual checking is necessary for a full assessment. Automated tools typically catch only 30–40% of accessibility issues. A person must judge whether the reading order makes sense to a screen reader user, whether the alt texts actually describe the content, and whether complex tables and forms work as expected.

A realistic approach for an organisation with many documents is to prioritise: start by identifying the most visited and business-critical PDFs, make those accessible first, and work systematically through the archive from there. Many public sector CMS installations — for instance Optimizely (formerly EPiServer) or Sitecore — hold embedded PDFs in the content tree that have never been reviewed; a systematic effort begins by mapping which documents are actually published and reachable via the website.

Frequently Asked Questions

Does the EAA apply to PDFs used only internally within a company? No. The EAA applies to services provided to consumers. Purely internal documents for your own staff are not covered by the EAA — but may be subject to other workplace accessibility legislation.

What is the difference between the Web Accessibility Directive and the EAA? The Web Accessibility Directive (2016/2102) applies exclusively to the public sector. The EAA (2019/882) extends the requirements to the private sector and specifies requirements for a broader range of products and services, including digital content such as PDFs.

Does the EAA apply to businesses outside the EU that sell to EU customers? Yes. If your business offers products or services to consumers in the EU and meets the size criteria, you are covered — regardless of where the business is established.

Are scanned PDFs accessible? No. Scanned PDFs without a text layer are not accessible, because screen readers cannot read images of text. They must be processed with OCR and correct tagging — or converted to accessible HTML.

Does the EAA require WCAG 2.2? Not today. EN 301 549 v3.2.1 references WCAG 2.1 AA, which is therefore the applicable requirement. WCAG 2.2 is recommended because it is backwards compatible and prepares the organisation for future updates of EN 301 549.

Next Steps

The EAA makes it a legal requirement that digital content — including PDFs — is accessible. For new documents the requirement has applied since 28 June 2025, and although existing services have until 2030, enforcement is already underway.

A practical order to work through:

• Clarify whether your organisation is covered (sector, size, consumer-facing service).
• Map which PDFs are actually published and reachable via your digital services.
• Prioritise the most visited and business-critical documents first.
• Run an automated screening, and follow up with manual checks of the prioritised documents.
• Decide, for each document, whether it should be remediated to PDF/UA or converted to accessible HTML.
• Update your accessibility statement with the status of the PDF documents.

The most important first step is knowing which of your PDFs have problems. From there, the task becomes concrete and manageable.