E-tickets, timetables and travel information as accessible PDFs
A long-distance coach operator that emails tickets as PDFs has been covered by the European Accessibility Act since 28 June 2025. A city tram operator sending exactly the same PDFs is not, at least not under the EAA. In passenger transport the directive only reaches certain digital elements. Where those elements produce PDFs, the PDFs have to be accessible.
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Not legal advice: which obligations apply to your transport business depends on the mode of transport, who owns or controls the operator and national law, and should be assessed case by case.
Which parts of a transport service are covered
Article 2(2)(c) of Directive (EU) 2019/882 names air, bus, rail and waterborne passenger transport services provided to consumers after 28 June 2025. The carriage itself is not the point. The directive gives an exhaustive list of the elements that have to be accessible:
- websites,
- mobile device-based services, including mobile applications,
- electronic tickets and electronic ticketing services,
- delivery of transport service information, including real-time travel information (for information screens, only interactive screens located in the EU),
- interactive self-service terminals located in the EU, except those installed as integrated parts of vehicles, aircraft, ships and rolling stock.
Germany copied the list word for word into section 1(3) no. 2 of the BFSG; Austria transposed it in its Accessibility Act (BaFG). How the directive is structured overall is described in The European Accessibility Act and PDFs.
Local transport: terminals only
For urban, suburban and regional transport services, only point (v) of that list remains: interactive self-service terminals. The directive defines these services by mode, namely rail, bus and coach, metro, tram and trolley bus. The website, app, e-tickets and travel information of a purely local or regional operator are therefore outside the EAA.
That does not leave the operator free of obligations. If it is a public sector body or controlled by one, the rules for public sector bodies may apply. Only a case-by-case assessment can answer that.
Extra information duties for long-distance services
For long-distance services, Annex I Section IV also requires information on the accessibility of vehicles, infrastructure and assistance. On top of that come ticketing information, real-time travel information such as timetables and disruptions, and service information, for example about lifts that are out of order. EU passenger rights law continues to apply alongside.
Where PDFs come from in a transport business
Much of this information reaches passengers as a PDF: downloaded from the website, attached to the booking confirmation or opened in the app. The table maps the usual documents to the elements in the directive.
| Document | Related EAA element | Typical barrier |
|---|---|---|
| E-ticket, booking confirmation | electronic tickets and ticketing services | Essential details only in the barcode or an image; reading order jumps between columns |
| Timetable, timetable extract | travel information | Large tables without header cells, symbols and footnote markers without text |
| Conditions of carriage, fare rules | website, ticketing service | Long documents without heading tags or bookmarks |
| Passenger rights and refund forms | website, app | Form fields without labels, wrong tab order |
| Network maps, route maps | travel information | Complex graphic with no text alternative |
| Accessibility information on stations and vehicles | service information | Of all documents, these are often scanned or untagged |
The e-ticket
Route, date, train or flight number, coach and seat, fare, plus a machine-readable code. A PDF ticket rarely holds more than that. A screen reader can do nothing with the barcode. Every detail that matters for the journey therefore has to be in the document as real text, tagged in a sensible order. The code itself gets a short alternative text ("Barcode for ticket inspection") or is marked as an artifact.
Fixing tickets one by one makes no sense. They are almost always generated by the booking system, so accessibility has to live in the template and the generator. Two details belong there too, because screen readers announce them first: a meaningful document title ("Ticket Vienna to Salzburg, 14 Nov 2026" rather than the booking reference) and the document language in /Lang.
Timetables are data tables
Few kinds of PDF content take as much effort to tag as a timetable. A screen reader should be able to give the right stop and the right service for every departure time. That only works if the header cells are tagged as TH: stop names as row headers with Scope Row, service numbers or operating days as column headers with Scope Column.
Empty and merged cells, or subheadings running across several columns, make the table tiring to move through. Several simple tables are better than one nested one. Markers such as "request stop only" or the bicycle symbol need a text equivalent, for instance a legend the table refers to, ActualText or alternative text. If school-holiday or weekend services are only shaded in colour, many users lose that information entirely.
For very large timetables, ask whether the PDF needs to be the primary source at all. An accessible HTML journey planner or a searchable online timetable often does more, with the PDF as a supplement. How WCAG criteria carry over to PDFs is covered in WCAG 2.2 for PDF documents.
Network maps
A network map will not fit into a short alternative text. The alternative text on the Figure tag should therefore state the purpose and point to a text version, for example a list of all lines with their stops and interchanges, in the same PDF or as a separate document. Within the graphic, sufficient contrast and line numbers along the routes mean nobody has to tell lines apart by colour alone.
Article 2(4)(c) does exempt online maps and mapping services on websites and apps. For maps intended for navigation, though, that only holds if the essential information is available in an accessible digital form. The exemption presupposes the accessible alternative.
Old timetables, old ticket machines
For websites and apps, Article 2(4) exempts among other things office file formats published before 28 June 2025 (PDFs are generally counted among them), as well as archived content that is neither updated nor edited after that date. A timetable republished every year is not an archive. Nor are conditions of carriage that have been amended.
For self-service terminals lawfully in use before 28 June 2025, member states may allow continued use until the end of their economically useful life, but for no more than 20 years (Article 32(2)). The details are set by national law, in Germany by the BFSG.
Where to start
First, classify: long-distance, local or both? That decides which elements are covered in the first place. Next, list every PDF produced in booking, passenger information and refunds, together with the system that generates it.
One typical document per type is enough to begin with. Run it through the PDF/UA check and also through PAC or veraPDF. Changes to templates and generators have the most effect, because tickets and confirmations are produced by the thousand. Tags, title, language and table structure belong in the output itself. Whether that holds over time can be monitored on outgoing documents through the PDF accessibility API.
EasyPDFUA checks structure, title, language, fonts and links, and can give untagged PDFs a base structure through retroactive tagging. It does not reconstruct timetable tables, alternative text for network maps or form labels. That work belongs in the source or in manual remediation. A check report does not confirm legal compliance either. Other sectors are listed in the overview of affected industries.
Frequently asked questions
Does the EAA apply to trams, metros and city buses?
Only to interactive self-service terminals. The website, app, e-tickets and travel information of a purely urban, suburban or regional operator are not covered by the EAA. If the operator is a public sector body, its own accessibility rules may still apply.
Does a PDF e-ticket have to be accessible?
In air, bus, rail and waterborne transport, yes: electronic tickets and ticketing services are named explicitly. Urban, suburban and regional services are the exception. All travel details should be in the PDF as tagged text, not only in the barcode.
How do I make a PDF timetable accessible?
Tag it as a real table, mark stops and services as TH header cells with a scope, explain symbols in text and never rely on colour alone. For very large timetables an accessible online journey planner is usually the better primary source, with the PDF alongside.
Can EasyPDFUA tag timetables automatically?
No. EasyPDFUA creates a base structure, sets title and language, links URLs and repairs unambiguous Unicode mappings. The header cells of a timetable have to be tagged in the source or by hand.