Since June 28, 2025, the following regulations apply in Austria: Accessibility Act (BaFG) and in Germany the Barrier-free accessibility enhancement law (BFSG). Both oblige many companies to make digital products and services accessible without barriers. This also applies to PDF documents that are made available digitally.
But what exactly does „barrier-free“ mean in the context of PDF files? And how can legal requirements such as the BaFG be fulfilled with technical standards such as PDF/UA?
What does „PDF not accessible“ mean?
The note means: The document lacks the technical structure that assistive tools like screen readers need. Visually, the PDF can look flawless.
Typical causes are:
- Missing tags: Headings, paragraphs, and tables are not marked as such.
- Incorrect reading order: The content is read out in a different order than it is intended to be.
- Missing alternative text: The images and graphics do not have any description.
- No voice input: The screen reader does not know which language it should read in.
- Text as an image: In scanned documents, the text is not actually present as text.
Whether a PDF is accessible can be determined using testing tools such as the PDF Accessibility Checker (PAC). The standard PDF/UA is the benchmark for this.
What is PDF/UA?
PDF/UA (Universal Accessibility) is an international standard (ISO 14289) that regulates how PDF documents must be created so that they are accessible to all people - including those with visual, hearing or cognitive impairments. The standard ensures that:
- Contents is readable for screen readers ,
- A meaningful navigation structure (e.g. headings, lists) is in place,
- Alternative texts for images are provided,
- The document can be operated with a keyboard,
- and Metadata such as language and title are correctly set.
Which companies must provide accessible PDFs?
With the BaFG (Austria) and BFSG (Germany), the European Directive (EU) 2019/882 is being implemented. This requires many companies to make digital information accessible without barriers – also in the form of barrier-free PDFs.
Particularly affected are:
- e-commerce services (e.g. web stores),
- digital booking systems (e.g. tourism portals),
- Publishers with digital publications,
- Banks,
- Transportation companies,
- Telecommunications provider,
- as well as public authorities and other service providers with online offerings.
Anyone who fails to meet the requirements risks fines and a loss of reputation. The amount of the penalties is determined by each country individually:
- Germany (BFSG): up to €100,000, in less serious cases up to €10,000
- Austria (BaFG): escalated according to company size, up to €80,000 for large companies
- Switzerland The European Accessibility Act does not apply directly, but it does affect companies that offer their services in the EU.
- Other EU countries: own regulations based on the same directive
How an accessible PDF works
A PDF is considered an accessible PDF if it meets the following requirements:
- Tagged PDF- All content must be provided with structural tags (headings, paragraphs, lists, tables).
- Alternative texts for images- Every graphic needs a meaningful descriptive text.
- Reading order- The sequence of content must be logical and linear.
- Navigation elements- Tables of contents, bookmarks and links must function correctly.
- Contrast and font size- Texts should be customizable and designed with sufficient contrast.
How companies should prepare now
The effort involved in converting to accessible PDFs can be considerable, depending on the scope of the content. It is therefore advisable to take the following steps now:
- Check PDF workflows: Which tools and templates are used? Do they support PDF/UA?
- Train employees: Designers, editors and developers should be trained in accessible document creation.
- Check existing PDFs: Tools such as the PDF Accessibility Checker (PAC) can be used to check PDFs for conformity.
- Implement standards: Rely consistently on PDF/UA in new projects.
- Obtain advice: Agencies or specialists for digital document management can provide support with implementation.
How neeyo helps with the implementation of PDF/UA
As a specialized partner in the field of customer communication management (CCM) neeyo supports companies on their way to barrier-free communication - from analysis and technical implementation to ongoing quality assurance.
Our services in the area of PDF/UA:
- Shipping-specific selection Whether accessibility is necessary (digital) or not (print)
- Automated tagging of sections (headings, continuous text, etc.)
- Logical reading order through the document structure
- Language tags are set automatically
- Possibility to add all other metadata manually (Alternative texts for images, tables, etc.)
Conclusion: Start now - with neeyo as your partner
PDF/UA is not just a legal requirement, but a sign of digital responsibility and inclusive communication. The neeyo.suite supports the requirements of PDF/UA – automatically where possible and with clear verification steps where people decide. How to permanently embed accessibility into the document structure is shown in our blog post Barrier-free documents