The European Accessibility Act (EAA) has applied since 28 June 2025. It requires many products and services sold to consumers in the EU, including e-commerce, banking, transport ticketing, e-books and electronic communications, to be accessible to people with disabilities. National enforcement bodies started checking in earnest during 2026, and documents are one of the most common failure points.
If your customers download PDFs from you, this checklist is for you.
Which PDFs are in scope?
The EAA covers services, and the documents that are part of delivering them. Typical examples:
- Bank statements, loan agreements and account terms.
- E-commerce order confirmations, invoices and return forms.
- Ticket and booking confirmations in transport.
- Product information and instructions provided digitally.
- E-books.
Internal documents and purely business-to-business material are generally outside scope. Micro-enterprises providing services (fewer than ten staff and turnover or balance sheet of €2 million or less) are exempt from the service requirements. National laws differ in detail, so check your country's implementation.
What "accessible" means for a PDF
The EAA points to the harmonised standard EN 301 549, which in turn relies on WCAG success criteria. For PDFs, the practical technical target is PDF/UA conformance. See PDF/UA explained and WCAG 2 for PDF accessibility.
The checklist
- Tagged structure. The PDF has tags for headings, paragraphs, lists and tables. See tagged vs untagged PDFs.
- Logical reading order. A screen reader reads content in the right sequence, including multi-column pages.
- Real headings. Heading levels follow the document's structure without skipping.
- Alt text. Informative images have descriptions; decorative ones are marked as artifacts. See how to add alt text.
- Accessible tables. Header cells are marked, and tables are not used for layout. See making accessible PDF tables.
- Document language and title are set in the properties.
- Colour contrast meets WCAG thresholds, and colour is not the only way information is conveyed.
- Form fields have labels and a logical tab order. See accessible PDF forms checklist.
- No text in images unless there is an equivalent.
- Bookmarks for long documents.
Fix it at the source
Remediating a finished PDF is slow. The efficient route is to fix templates: use heading styles in Word or your design tool, add alt text there, and export with tagging switched on. Every statement or invoice generated from that template then starts accessible.
For documents generated by systems, such as statements and confirmations, ask your vendor whether output is PDF/UA conformant. Many generators added this in response to the EAA.
Check with tools, then with people
Automated checkers (such as the free PAC checker or Acrobat's accessibility check) catch structural problems. They cannot tell whether alt text makes sense or reading order is logical. Test important templates with a screen reader, or with users who rely on one.
Takeaway
The EAA turned PDF accessibility from good practice into a legal requirement for many consumer-facing businesses. Fix your templates, aim for PDF/UA, and test with real assistive technology. For the newest version of the standard, see PDF/UA-2: what's new.
