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PDFs Remain a Challenge for Section 508 Compliance

Apr 3, 2023

In February, the Department of Justice (DOJ) released its first report on Section 508 web compliance since 2012. The analysis, which relied on self-reported data, showed several key issues in government accessibility initiatives — and for most federal agencies, document accessibility remains a prominent point of concern.

The U.S. government frequently uses Adobe’s PDF (Portable Document Format) for tax forms and document archives. Adobe PDFs pose distinct accessibility challenges, particularly for people with vision disabilities:

  • Visual text from image-only PDFs cannot be accessed with screen readers (software that converts text to audio or braille) and other assistive technologies.
  • Older PDFs may not “reflow:” Users must scroll horizontally and vertically to read all of the information. This can make them less accessible for people who use screen magnifiers and people with mobility limitations.
  • PDFs that aren’t properly tagged do not contain semantic information, so screen reader users may hear the content out of order. Keyboard-only users may have trouble navigating the documents.
  • Visual content within PDFs needs accurate alternative text (also called alt text). Without alt text, images and graphs may be unreadable for people with vision disabilities.

These issues are avoidable. The Web Content Accessibility Guidelines (WCAG) are the international consensus standards for digital accessibility, and the government’s own Revised Section 508 standards incorporate WCAG by reference. 

Authors can create accessible PDFs by following WCAG — but according to the Justice Department, many top agencies simply aren’t following the rules.

Related: Section 508 Compliance Testing for Websites

Most government PDF files have serious accessibility issues

To analyze PDF accessibility, the General Services Administration (GSA) analyzed the “Top 10 Downloads" reported by various government agencies. When those documents were PDFs, the GDA tested them for conformance with the Revised Section 508 standards.

Of the documents analyzed: 

  • Among the top downloads, 77% were PDFs.
  • Only 20% of those PDFs were conformant.
  • 57% of PDFs were non-conformant.
  • Among the non-conformant PDFs, 73% of the documents were untagged.

The Justice Department notes that the low conformance rates suggest “poor policy and process controls.” 

However, it’s important to note that conformance varies by agency. The Department of Veterans Affairs (VA), for example, had relatively high conformance rates for web documents (although, as we’ve discussed in other articles, VA websites are more likely to have other accessibility issues).

With that said, most federal agencies have room for improvement. How can those agencies address the issue — and provide essential documents for all users, including those with disabilities? 

Related: 6 Common PDF Accessibility Mistakes

Building Better Policies for PDF Accessibility

Digital accessibility discussions often focus on web pages accessibility, and for a good reason: Every website should provide users with an inclusive experience, and most web accessibility barriers can be addressed easily during the development process.

But PDF accessibility is extremely important, especially when web-delivered documents contain essential information. Federal agencies must follow the Revised Section 508 standards — particularly when authoring PDFs.

When developing Section 508 compliance policies, keep these concepts in mind:

  • Digital accessibility must be an ongoing priority, not an afterthought. Tagging PDFs is much easier when importing or creating documents. After-the-fact remediation is more expensive (and potentially less effective). 
  • Use color and images thoughtfully. Make sure your documents don’t rely on visual presentation alone; users should be able to understand the content without relying on a single type of sensory perception.
  • Don’t rely on auto-tagging. Check documents to make sure that the markup accurately reflects the structure of the content.
  • All web documents must be accessible — not just PDFs. Publication processes should include checks for accessibility markup.
  • Agencies must develop a consistent, sustainable strategy for testing all web documents. 

The DOJ report notes that “Section 508 Program staffing levels may not be commensurate with agency size, mission and scope of accessibility-related work,” and staff volatility remains a significant challenge for compliance.

If your agency is struggling to meet its responsibilities under Section 508, we’re ready to help. At the Bureau of Internet Accessibility, we provide clients with accessibility training, testing, document remediation, and other resources to establish a roadmap for long-term success. 

To get started, read about our PDF & Document Accessibility Remediation solutions or send us a message to connect with a subject matter expert.

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