PDF Document Accessibility is Critical for Your Website
Leslie Janek is a document accessibility specialist for Microassist. She has remediated or otherwise made accessible specialized content ranging from K-12 science, technology, engineering, art, and math to higher education coursework, and other public and private sector content. In addition to PDF document remediation, Leslie consults with clients on remediation strategy, and creates and delivers training on how to create accessible PDF files and remediate inaccessible PDFs.
In Website Accessibility, Documents Count, Too
According to U.S. Census Bureau, more than 56 million Americans live with a disability. Meanwhile, an increasing number of fundamental services are moving to websites and applications, sometimes at the expense of brick and mortar options. And, while the Americans with Disabilities Act was written before the internet became a household word, the court system and the Department of Justice have repeatedly affirmed, through enforcement if not by regulation, that Title III requirements for non-discriminatory access apply to online environments as well as physical ones. It’s more important than ever to create online content that is accessible to people with disabilities, not only for inclusion, but to mitigate your risks of legal action.
There have been numerous cases in the news about website accessibility. Many of us may first think online accessibility applies only to web pages and forms. But when you dig a little deeper, you find that not only does your website need to be accessible, so does any digital content that you post on your website. This includes, video, audio, images, and all documents that are available through your site.
From a PDF brochure to a Microsoft PowerPoint presentation of your last shareholders meeting, document files must conform to accessibility standards for people with disabilities to have access to that document’s information. Often, accessing that information means using assistive technologies such as screen readers. This means that the image and text content within a PDF needs to be structured in a way that works for those technologies as well standard browsers, devices, and applications. However, if the correct content development processes are not in place, those PDF documents could be largely inaccessible to individuals who have visual, auditory, mobility, or cognitive impairments, preventing them from having equal access to your content or your products or services.
PDF Accessibility Litigation
Most people who do not have a disability take the ability to perform common, everyday activities for granted. But taking a class at a university, filing taxes, reviewing mortgage documents, or reading a contract can be almost impossible for a person with disabilities if the content creator did not take accessibility into account. That lack of document accessibility has become more apparent as host websites come under closer scrutiny though complaints, demand letters, and other legal actions.
Below are a few examples of decisions and settlements involving PDF documents and other online files:
- In 2015, Scribd, Inc., an online subscription library service, agreed to make its website accessible in response to an action by the National Federation of the Blind. The settlement also addressed PDF documents specifically, requiring that then-currently uploaded files would be made accessible upon request, allowing for certain limitations. However, all new documents uploaded to the Scribd website would be made accessible before posting. Inaccessible PDF files were specifically disallowed.,
- In 2016, Bank of America committed to having its many mortgage-related documents comply with Web Content Accessibility Guidelines. This agreement resulted from a structured negotiation resolving the dispute brought Jessie Lorenz, a Bank of America mortgage holder with visual disabilities.
- H&R Block came under scrutiny when the National Federal of the Blind (NFB) found that the company’s website, including downloadable software related to tax filing, was not accessible. The resulting settlement gave H&R Block five years to make their website, apps, and tax filing system compliant with WCAG 2.0 Level AA standards, including “…all of the information, resources, files, databases, images, graphics, text, audio, video, multimedia, services, code…and any other communications sent by or retrieved from hrblock.com to members of the public accessing it.”
- Public education is required under Title II of the ADA to make electronic information resources accessible to people with disabilities. Complaints brought to the U.S. Department of Education’s Office of Civil Rights regarding the Michigan Department of Education, resulted in a voluntary resolution agreement to make up to 8,000 documents accessible, or delete them from the website. The Michigan DOE is one of many educational institutions against which similar complaints have been filed.
PDF Benefits Include Accessibility—When Created Correctly
There are many benefits to presenting content in Portable Document Format, or as PDF documents, on your website.
- Documents are more secure because any changes made to the document leave a digital footprint that can be reviewed later.
- PDF viewing software can be downloaded at no cost, so anyone can access the information.
- PDF documents can be viewed on most devices, including mobile, without the formatting issues you may run across in other formats such as Microsoft Word or PowerPoint.
Along with these benefits, Adobe Acrobat Pro DC—the primary tool for editing PDFs and “tagging” them to identify structure and elements—has built-in features to help make your documents accessible to those with disabilities, particularly people who are blind or visually impaired. However, even though Adobe Acrobat Pro DC is powerful, there are still several manual steps required to ensure the document fully complies with recognized accessibility standards. Whenever possible, some of those steps need to occur before the PDF file is created from the originating format.
Despite the fact that the PDF format is one of the most popular digital formats, most PDF creators do not know how to determine whether or not a PDF is accessible, or how to create an accessible PDF file. The following information will introduce you and your teams to tools and practices that directly affect the accessibility of a PDF document.
PDF Document Accessibility Standards
Document accessibility is similar in many ways to website accessibility. Many of the standards that apply to websites also apply to documents, just in a different way. People with cognitive, hearing, vision and mobility disabilities need to be able to access the information and interact with the document. There are three main standards that determine document accessibility: Web Content Accessibility Guidelines 2.0 (WCAG 2.0), ISO standards, and Section 508.
Web Content Accessibility Guidelines 2.0
As the name suggests, these guidelines, known by the acronym “WCAG,” are used for any web content, including documents. In working with many different companies and agencies to create or remediate content to be accessible, this is the most common standard specified (government agencies sometimes have alternate standards, such as jurisdiction-specific requirements, or standards such as those put forth by Section 508 of the Rehabilitation Act, which we’ll cover next).
There are three levels of accessibility according to these guidelines: Level A, AA, and AAA, with Level A being the bare minimum and Level AAA being a perfect document. In several instances, the Department of Justice has affirmed that the WCAG 2.0 Level AA is the standard by which websites and related files should be judged for access. With WCAG 2.0, your document must be perceivable, operable, understandable, and robust. You can review the entire list of guidelines at the W3C website; however, here is a breakdown of some of the guidelines when dealing with documents.
Perceivable — Having a perceivable document means that everyone, no matter their ability, should be able to reasonably interpret or become aware of the content through their available senses. For instance, documents that are perceivable have these elements and more:
- True text. In any PDF, you should be able to select portions of the text. Often, scanning a document results in what is essentially an unreadable picture of a page full of text. If you cannot make a selection of a word, sentence, or paragraph, the lines and shapes on the page are not being recognized as text. This means that the text is not readable by assistive technology software.
- Sufficient color contrast for all relevant information. This enables those with limited vision to be better able to distinguish text or other significant information from its background.
- Alternative text for all images, form fields, and links. This enables those who are blind or visually impaired to hear a description of any element on the page, even if they can’t see it.
- Instructions or directions that do not rely solely on a single sensory detail. This provides information in an alternate format in case the first presentation is imperceptible (e.g., “a red arrow,” “the large box,” “the dog on the right,” etc., rely exclusively on visual elements that may be indistinguishable from surrounding elements due to disabilities such as color blindness, dyslexia, or low vision)
Operable — Having a document that is operable means a couple of things. The first is that all functionality, including the ability to enter text into a form field, click on hyperlinks, or activate or pause multimedia, is available from the keyboard (many people with disabilities do not use a mouse). The second is that certain items are available for navigation.
Some of the things to consider while making your document operable are:
- A clear and intuitive structure within your document. Most documents are intuitively navigable by visual cues. For instance, stylized type signifies headings and subheadings, bullets and paragraphs, data tables and text content in sidebars. Sighted users used these cues to skim and skip and navigate a document. To make these cues available to non-sighted users, including assistive technologies, accessible documents incorporate heading styles, links, lists, identified tables and table rows and columns, and other programmatic, orderly tagging to make navigation easy.
- Complete functionality when using a keyboard. Keyboard navigation should not be full of surprises. For instance, in an accessible PDF form, the user can move from form field to form field in a logical, intuitive way and complete fields easily.
Understandable — Having a document that is understandable means anyone can comprehend the information with a reasonable amount of education or knowledge. Your document should be written in a way that the intended audience should be able to comprehend it, even with a disability.
A few things to consider are:
- Language identification. The language of the document should be indicated programmatically so that assistive technologies can pronounce and interpret content correctly, or reformat text appropriately (e.g., rendering text larger on a different device with the correct alphabet forms).
- Form instructions. People accessing the form should know when they are in a form field, what it is for, and what information is required or optional. Form fields should have instructions easily available to the user no matter what field they are in.
- Table structure. Your readers should be able to tell how content in one cell relates to content in another cell, row, or column even if they can’t see the table. This is possible when content authors create each table with a clear table structure with identified row and column headers, or by providing alternate descriptions of the table or access to original data source files.
Robust — Having a robust document means that the information can be interpreted by not only a person, but also by various assistive technologies. We have already mentioned screen readers, which are devices that audibly read the content and navigational elements on a screen. But there are also magnifiers, Braille devices, and other software and hardware that people use when interacting with the web and with web documents. A properly constructed, accessible PDF document works with these technologies because they are built to accept and interpret content in a standardized way, even when they undergo version changes.
To make sure your document is robust consider:
- Using built-in features in the native authoring software according to their original purpose as often as possible
- Ensuring that your PDF document is properly tagged, enabling assistive technologies to interpret, distinguish between, and if needed, reconstitute the types of content it encounters (images vs. text, headings vs. paragraphs, table rows vs. headings)
The ISO, or International Organization for Standardization, creates documents that provide requirements, specifications, guidelines, or characteristics that can be used consistently to ensure that materials, products, processes, and services are fit for their purpose. There are three sets of ISO standards associated with PDF accessibility: ISO 32000-1, ISO 14289-1, and ISO/IEC 40500. These are by far the most stringent sets of standards as they take into account accessibility standards from around the world.
- ISO 32000-1 — This standard deals with the universal file formatting of the PDF document and is very technical in nature. Intended for PDF software developers, it helps ensure that a file can cross different platforms and still keep its formatting.
- ISO 14289-1 — This set of requirements, informally known as PDF/UA, defines the essential requirements for universally accessible PDF documents, PDF programs, and assistive technologies using PDF/UA.
- ISO/IEC 40500 — This standard is identical to WCAG 2.0 standards for universally accessible web content.
Section 508 was an addition to the United States Rehabilitation Act of 1973. It requires federal agencies and anyone receiving federal monies to make their electronic content accessible to people with disabilities. Section 508 has recently been refreshed to largely follow WCAG 2.0 Level A and Level AA, largely by reference; compliance with the refreshed Section 208 standards begins January 18, 2018., When dealing with any agency in the federal government, or an agency or company that receives federal funding, this is the standard that should be used.
Building an Accessible PDF Document
When building or creating your document, you should have accessibility in mind the whole time. It is much easier and less time consuming to create an accessible document from the beginning than it is to deal with fundamental fixes after the fact. Even then, when you convert that original document to the PDF format, you’ll need to follow up with special accessibility tools to make sure your PDF document is compliant. Using best practices in your native authoring software will minimize that second level of work by helping create the proper tags in the final PDF.
Tags appear in what is known as a “tag tree” within PDF editing software (typically Adobe Acrobat Pro DC). The tag tree shows the structure of every single element within the PDF in a hierarchically arranged list. The tags within the tag tree help assistive devices interpret the structure and elements within your document and preserve the layout of the PDF document. They are critical to promoting content perception, easier navigation, document usability, and greater understanding. They can also be finicky, so addressing tagging issues during the content creation process can save you tag remediation headaches later.
When thinking about the content for your document, there are a few questions you should ask yourself. Is the content relevant and does it add value? Is the information organized logically under easy-to-understand headings? These questions will help you remove unnecessary information, supporting understandability. When you have information that is just filler, it can be very confusing while using a screen reader to navigate through the filler to get to the meaningful content.
Always use the authoring software’s internal structures to set up your document using programmatically styled heading levels (e.g., “Heading 1,” rather than tweaking your text font to be “Times New Roman paragraph text, bold, size 16.”), lists, tables, etc. This will make sure that the foundational structure is set up when you are tagging your PDF in Adobe Acrobat Pro DC. Structure allows the user to navigate the content efficiently.
Color contrast is important for people with lower vision or colorblindness. Color contrast should be checked from the beginning of your document creation. Color contrast isn’t subjective, either; color contrast is based on numerical values that relate to each color and compared to each other. If the comparison conforms to the appropriate ratio (which differs for small or large text), there is adequate color contrast. If it does not, even if you think it looks fine, it fails color contrast standards and is out of compliance.
All images—photos, charts, diagrams, logos, illustrations, etc.—need to have adequate alternative text. Alternative text explains images for non-sighted users. A screen reader will use the textual information that is tied to the image tag to explain the image. If the image does not add value to the content but is simply decorative, you can declare it as such using the procedure for the particular authoring software you are using. In Acrobat Pro, you can tag decorative images as “background” in the final PDF so the screen reader will just skip over it.
All documents need to have certain properties designated for assistive technology to work correctly. Each document needs to have the language of the document set so the assistive technology can read it correctly. This can usually be designated in the native authoring program, but should also be checked in the final PDF.
Also, assuming that the structure of your document is logical in your native program and that you’ve created your structure properly, there may be settings in your authoring software that help carry your structure to the PDF format. Otherwise, in your PDF, you will need to set the tab order for the document to follow the structure of the document that you laid out. Having this tab order set properly will affect how a cursor travels through your document and the order in which your content is read.
Finally, when the PDF is set up you will need to mark the document as a tagged document if that did not happen upon conversion. If content isn’t tagged, a screen reader will not be able to read the content in your document.
The reading order of a document is probably one of the most important things to remediation. This order is a road map for the screen reader to follow the correct path of your content. For Word documents, the reading order is usually left to right, top to bottom. However, sometimes there are text boxes or columns that may require a different reading order. More complex layouts in Adobe InDesign can also vary, as can content within PowerPoint presentation slides. The language in which content is written can also require a different reading order. For all these reasons, it’s important to make sure that you create your original file logically. However, Adobe allows you to set the order in the final PDF, though it may take making adjustments.
Document Creation Software and PDF Accessibility
Top document creation software, such as those within the Microsoft Office suite of products and Adobe InDesign, have built-in accessibility tools that can help you create an accessible document from the start.
Here are some helpful tips to create an accessible document from the beginning. Even though these documents will still need to be reviewed after they are made into a PDF, a great number of accessible functions will carry over into your PDF document upon conversion, saving you time (Note: Some of these conversions require adjusting settings in your authoring software). Also, should you need to publish both the original document and the PDF, your native document will already be accessible.
Here are some areas to consider when creating Word documents and PowerPoint presentations:
- Microsoft Word
- Use Word’s built-in styles for headings, paragraphs, lists, etc. to set up a vital structure in your document.
- Use built-in tools to create tables, charts, table of contents, etc. so the structure will transfer to your PDF.
- Add alternative text to all figures so the screen reader can relay the meaning and intent of the images on the page.
- Use clear, descriptive language for hyperlink text.
- Microsoft PowerPoint
- Use PowerPoint’s built-in templates to ensure the structure and reading order of the elements on your slide are set up correctly.
- If you have complicated images, group the elements, and create one figure, then apply alternative text.
- If you want to print the notes of your presentation, make sure to structure your notes with styles as well.
Finally, Microsoft Word and PowerPoint have built-in accessibility checkers to test your document for proper structure and use of headings and alt text. It will also point out areas that require human judgment, and provide tips for improving the accessibility of your original document. While not foolproof, these checkers can help direct you to increase accessibility in your native documents before converting them to PDF files. [Consider implementing the processes outlines in PowerPoint 2013 Tip: Use the Selection Pane to Improve Accessibility, for instance.]
Adobe not only makes great software to create accessible PDF documents, but it makes great authoring software as well. Adobe InDesign, as well as other tools such as Framemaker, are great tools to create documents.
Below are a few helpful tips when creating documents in InDesign:
- While creating the document, use the Articles panel to structure the document and designate the order of each element of content. When you convert the document to a PDF, you can also map styles to PDF tags. This will all the PDF to retain the heading, subheading, and other style structure you designated in your original InDesign file.
- Make sure and include alternative text for all of your images. The alternative text will convert over when you create your PDF.
PDF Accessibility Remediation
But what about the PDF files you already have? Even if your website is largely accessible, if the content available through your website or that is otherwise delivered electronically (email, third-party delivery) is inaccessible, you could be at risk of legal action. To reduce this risk, making your PDF documents accessible should be a priority. While the most cost- and time-efficient way to ensure your PDF documents are accessible is to first implement accessibility practices while using your original authoring software, there are ways to make existing PDFs accessible to users with disabilities and comply with accessibility standards. Of course, there may be cases when the original document may also need to be remediated.
PDF Accessibility Tools
There are several tools that can be used to ensure your PDF document is accessible. These tools make checking your document simple and much more efficient. Using all three of these tools will get you close to compliance with all passing marks, but you still need to check your document manually.
- Paciello Colour Contrast Analyser — Color contrast should be one of the first things that you check so you can resolve design problems within your native documents and before you start applying any remediation steps to existing PDF files. The Paciello Group has created great open source software to check color contrast. The tool checks against WCAG 2.0 contrast standards and gives examples of different color blind conditions.
- Adobe Acrobat Pro — Adobe Acrobat Pro is not an authoring program, but is critical to checking and editing PDF documents. The accessibility checker within the Adobe Acrobat Pro DC software will run a full check on your document and create a report. The report breaks down any issues and points you to the Adobe User Guide website to show you how to fix the errors. This tool, while helpful, misses many marks. Do not rely on it exclusively to check for compliance. Also, keep in mind that PDF files rely on tagged content to be readable. Changes you make to the document will often un-tag the content that you are editing, rendering it essentially unavailable to a screen reader. Make sure you have all fonts needed on your local computer. If you do not have the font used within the original document on your computer, Adobe will fill in the new content with a standard font, which can disrupt the way your document looks. To ensure the greatest levels of accessibility, those who remediate PDF documents regularly will dive into the tag tree to correct structural, reflow, and accessibility errors. Sometimes this is the most reliable way to fix complex issues, but it is also the most specialized.
- PDF Accessibility Checker 2.0 — The PDF Accessibility Checker (PAC) 2.0 is a free tool created by the Access for All Foundation. It will automatically check your PDF document for accessibility issues. The checker is set against the WCAG 2.0 standards and can also help you check the reading order of the document. It will point you to the error in the page and organize errors by categories to help you fix the issue.
A note on Adobe Acrobat Reader — The Acrobat Reader is a free download that allows you to open a PDF document. It has extremely limited editing functionality and will not help you remediate a document. However, you can get insight into how accessible a PDF document is. For instance, you can easily determine whether your PDF text is can be perceived by assistive technologies. You can also use your Tab key to navigate through form fields to check logical flow. However, to ensure that your document is compliant with accessibility standards and is properly structured, you must have Acrobat Pro.
Common PDF Remediation Pitfalls and Mistakes
There could be a whole book on common pitfalls and mistakes when it comes to PDF remediation. The issues that come up in PDF remediation can be very easily fixed (and Microassist offers formal training in this area), but locating the error and knowing how to fix it can sometimes be challenging. Here are a few common issues that have been known to cause challenges with PDF documents.
- Embedded Fonts — Embedding fonts is one of the first steps that should be performed when remediating a document. If you skip this step and you try to perform your remediation, when you get to the end of your remediation process and then embed the fonts, your document could become corrupted. When the document is corrupted you will have to start over from a previously saved version.
- Adobe Auto Tag Feature — Even though Adobe offers an auto tag feature that will automatically tag a document, this feature is not always your friend. Sometimes the feature works like a charm, so it never hurts to try. Make sure that you have saved another version and run the auto tagging tool. Running this tool can sometimes corrupt your document or it will work its magic and you will have a wonderfully tagged document.
- Disappearing Content — When tagging content, sometimes when you select the wrong things, some of your content will disappear. The content doesn’t really disappear, there are layers in the PDF and they need to just be rearranged to show in the correct order. You will have to search for your hidden content in the content panel and rearrange the content to bring it back to the front.
- Links — Even if you set up links correctly in your original authoring software, sometimes you have to re-create the links in Adobe Acrobat Pro DC. All links have to have a Link OBJR tag associated with it in order to pass compliance and to work correctly as a clickable link. You may have to search for the tag and reorder the tags for the link to function correctly.
- Tables — Tables can be very useful when setting up data that can be better comprehended in tabular format. Tables can also be very complicated to set up in a PDF document to make them accessible. Setting up their structure can be very time consuming and easy to get wrong. If you have the order of the data mixed up, your document can also become corrupted as Adobe cannot read the information.
- Alternative Text — Alternative text can be tricky if you have not studied up on a highly specialized subject. Knowing the correct jargon and terminology is a big part of alternative text. Science, Technology, Engineering and Mathematics (STEM) images can be very complex. Also, practicing different types of images on a regular basis can keep you up to speed with how to correctly explain some things. Knowing when to turn to an expert for help is a big part of remediation.
In the world of PDF documents, planning ahead and building accessibility in from the start is the best thing you can do. When that is not possible, following systematic steps within your original document and then again in your PDF file can set you on the path to make any PDF document accessible. Not only is making your document accessible the right and legal thing to do, but it will allow anyone, no matter their ability, to access the information that you are trying to present to them.
. Nearly 1 in 5 People Have a Disability in the U.S., Census Bureau Reports, www.census.gov/newsroom/releases/archives/miscellaneous/cb12-134.html
. In one of the most notable instances of 2017, the DOJ weighed in on Gil v. Winn Dixie, with a Statement of Interest (www.ada.gov/briefs/winn_dixie_soi.pdf) that provides background on the DOJ’s position that Title III applies to websites and states, “…[T]he United States respectfully submits this Statement of Interest to clarify public accommodations’ longstanding obligation to ensure that individuals with disabilities are not excluded, denied services, or treated differently than other individuals because of the absence of auxiliary aids and services, such as accessible electronic technology. This obligation means that websites of places of public accommodation, such as grocery stores, must be accessible to people who are blind, unless the public accommodation can demonstrate that doing so would result in a fundamental alteration or undue burden.”
. Digital Accessibility Checklist: 10 Critical Elements to Evaluate for Website Accessibility, www.microassist.com/digital-accessibility/digital-accessibility-checklist/
. National Federation of the Blind, et al. v. Scribd, Inc., Settlement Agreement and Release (PDF), http://dralegal.org/wp-content/uploads/2015/11/scribdsettlementagreementandrelease.pdf retrieved from DRALegal.org, “National Federation of the Blind, et al. v. Scribd, Inc.” http://dralegal.org/case/national-federation-of-the-blind-et-al-v-scribd-inc/
. Bank of America Enhances Accessibility of Mortgage Documents, Bank of America newsroom, http://newsroom.bankofamerica.com/press-releases/consumer-banking/bank-america-enhances-accessibility-mortgage-documents and Bank of America Accessible Mortgage Information Agreement. www.lflegal.com/2016/05/bankofamerica-mortgage-agreement/, May 4, 2016
. Justice Department Enters Consent Decree with National Tax Preparer H&R Block Requiring Accessibility of Websites and Mobile Apps Under Americans with Disabilities Act, Department of Justice, www.justice.gov/opa/pr/justice-department-enters-consent-decree-national-tax-preparer-hr-block-requiring. See also the consent decree at www.ada.gov/hrb-cd.htm
. Education department to make website more accessible, Detroit Free Press. www.freep.com/story/news/local/michigan/2015/07/13/mde-web-site-overhaul-federal-complaint-accessibility-disabilities/30055313/, July 13, 2015.
. Top 10 Reasons to Use PDF Instead of Word, Excel or PowerPoint, Adobe Document Cloud Blogs, https://blogs.adobe.com/documentcloud/top-10-reasons-to-use-pdf-instead-of-word-excel-or-powerpoint/
. Section 508 Law and Related Laws and Policies, Section508.gov, www.section508.gov/content/learn/laws-and-policies
. Section 508 Refresh: How WCAG Impacts Federal Website Accessibility Requirements www.microassist.com/digital-accessibility/section-508-and-wcag/
. G17: Ensuring that a contrast ratio of at least 7:1 exists between text (and images of text) and background behind the text, www.w3.org/TR/WCAG20-TECHS/G17.html
This post was originally published as Don’t Forget The Documents: Minimizing ADA Accessibility Liability In Online PDFs, in the September 2017 issue of Mealey’s™ Litigation Report: Cyber Tech & E-Commerce. Mealey’s is a subscription-based information provider and a division of LexisNexis. Copyright © 2017 by Leslie Janek. Any commentary or opinions do not reflect the opinions of Microassist or LexisNexis, Mealey’s. Responses welcome.
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