PDF accessibility update from Australian Government

It’s here—the Australian Government has declared its position on accessibility of the Portable Document Format (PDF).

Need some background? We wrote about the status of PDF in our October 2013 article: The low-down on PDFs (for those who don’t already know). In this article we look at the developments made since then.

In 2013, we were commissioned by the Department of Finance to conduct a Review of the Accessibility of the Portable Document Format for People with a Disability (we had conducted a similar study for them back in 2010). This Review centred on finding out the technical capability of PDF to meet all the WCAG 2.0 conformance requirements necessary for government agencies to fulfil their obligations under the Web Accessibility National Transition Strategy (NTS).

Research findings

The aim of our research was to establish if technological advances since 2010 have improved the accessibility of PDFs when accessed from desktop screen readers. However, with so many people using mobile devices to access web content these days, the need to determine if PDF was an independent accessible format on mobile devices became equally important.

We looked at the capability of Australia’s most commonly used desktop and mobile screen readers against the global standards for PDF accessibility – the World Wide Web Consortium’s (W3C) PDF Techniques for WCAG 2.0. Taking into account screen reader market share in Australia, we found that the overall support for desktop was strong, but there was a significant lack of mobile screen reader support for PDF. Below is a simplified summary of the results.

Desktop screen readers:

  • JAWS provides sufficient support
  • NVDA provides sufficient support
  • Window-Eyes provides partial support
  • VoiceOver on Mac doesn’t provide sufficient support

Mobile screen readers:

  • VoiceOver on iOS doesn’t provide sufficient support
  • TalkBack on Android doesn’t provide sufficient support

Current position of the Australian Government and AHRC

Subsequent to the findings of the Review, both the Department of Finance and the Australian Human Rights Commission (AHRC) consider the lack of support for PDF in the mobile environment to be a significant issue. As such, they will continue to reinforce the Government’s existing position that Agencies should publish their documents in HTML, with an accessible PDF optionally provided, except in limited circumstances.

Here’s a summary of the key outcomes:

  • The desktop environment now provides sufficient support for PDF.
  • The mobile environment provides insufficient support for PDF to claim WCAG 2.0 conformance.  
  • Ideally, Agencies should publish documents in HTML, with an accessible PDF optionally provided.

Updated guidance on PDF Accessibility can be found in the Australian Government’s Web Guide.

It is acknowledged that in some circumstances WCAG 2.0-compliant PDFs can now be provided as a sole format, i.e.

  • When PDF Techniques and General Techniques are used to Level AA; and
  • When the usage situation is conducive to accessibility support.


  • An Intranet where the organisation provides an up-to-date standard operating environment and appropriate assistive technologies for PCs.
  • A lengthy report or detailed reference document where it can reasonably be expected that someone would consume the information from a desktop environment rather than a mobile device.

In situations where an Agency reasons that the primary document format for certain types of information can be PDF, they are advised to:

  • Work with properly structured source files.
  • Avoid scanned PDFs, or at least optimise them for accessibility.
  • Apply appropriate WCAG 2.0 techniques.
  • Provide a HTML landing page that includes key points and a summary or overview of the PDF document.
  • Provide an alternative means of accessing the information by providing contact details supported by a process that delivers a timely response and a satisfactory outcome.

If the circumstances above do not apply, and PDF can’t be relied upon for the sole provision of government information, then a PDF file must be accompanied by an alternative WCAG 2.0 optimised format (ideally in HTML).

How we can help you


Digital Access at Vision Australia is a global leader in accessibility training and professional services. Servicing public and private sector organisations nationwide, it is a consultancy at the forefront of the accessibility industry in Australia.

We’ve spent over 15 years helping people understand why accessibility is important and how to make their digital assets, such as websites, documents and mobile apps, accessible to everyone.

Our complete 2015 training programme is now open for registrations. Workshops will be run in most capital cities including Melbourne, Sydney, Brisbane, Perth, Adelaide and Canberra. Early birds get a 10% discount. Courses include:

We also offer specialised in-house training and consultancy options, including:

  • Accessible PDF from InDesign
  • Designing for Inclusion
  • Advanced PDF Remediation

Contact us for further information.

You may also be interested to read about our new tool to make accessible document creation easier. Find out more in Accessible Word documents made easy.

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