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The European Accessibility Act and PDFs: what you need to know

Since 28 June 2025, new accessibility requirements apply across the EU to many products and services. PDFs are an often overlooked part: invoices, contracts, product information and e-books must be usable by everyone.

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Note: this guide provides general orientation and is not legal advice. Whether and to what extent your organisation is affected should be assessed case by case with a qualified adviser.

What is the European Accessibility Act?

The European Accessibility Act (EAA) is Directive (EU) 2019/882 on the accessibility requirements for products and services. Member states had to transpose it into national law, and the requirements have applied since 28 June 2025. Its goal is that people with disabilities can use certain products and services without undue difficulty.

Covered areas include, among others:

  • e-commerce services,
  • consumer banking services,
  • e-books and dedicated software,
  • elements of passenger transport services (such as websites, apps, electronic tickets and travel information),
  • electronic communications services and certain hardware such as self-service terminals.

National laws: BaFG in Austria, BFSG in Germany

Each member state has its own implementing law. In Austria, the EAA was transposed by the Accessibility Act (Barrierefreiheitsgesetz, BaFG), Federal Law Gazette I No. 76/2023. In Germany, it was transposed by the Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG) together with an implementing regulation. Both apply to economic operators that place covered products on the market or provide covered services to consumers.

Exemption for microenterprises

Microenterprises providing services are exempt from the requirements. Under the directive, a microenterprise has fewer than 10 employees and an annual turnover or annual balance sheet total not exceeding EUR 2 million. This exemption does not apply to products in the same way; the details follow from the respective national law.

Public sector: separate rules

Websites, apps and documents of public sector bodies have been covered for several years by the Web Accessibility Directive (EU) 2016/2102. Austria implemented it in the Web Accessibility Act (Web-Zugänglichkeits-Gesetz, WZG); Germany at federal level through regulations including BITV 2.0. Public bodies therefore generally need to make the PDFs they publish online accessible as well.

What does this mean for PDF documents?

The laws do not prescribe a particular file format, but they require information to be perceivable, operable, understandable and robust. In practice, the benchmark is the harmonised standard EN 301 549, which refers to WCAG for web content and documents. For PDF files, PDF/UA (ISO 14289) is the common technical way to meet these requirements. How the two standards relate is explained in PDF/UA vs. WCAG.

PDFs that are part of a covered service are typically relevant, for example:

  • contract documents, terms and conditions and pre-contractual information,
  • invoices, account statements and order confirmations,
  • product information, manuals and data sheets,
  • electronic tickets and travel documents,
  • e-books in PDF format.

A practical approach

  1. Take inventory: Which PDFs do you provide to customers, and which of them belong to a covered service?
  2. Check: Find out whether the documents are tagged and whether title, language and fonts are set correctly, for example with a PDF/UA check.
  3. Fix the sources: Adapt templates in Word, InDesign or your document system so that new PDFs are accessible from the start.
  4. Remediate the archive: For existing PDFs without a source file, retroactive tagging can add a technical base structure that is then completed manually.
  5. Validate: Check results with PAC or veraPDF and manually. Typical messages are explained in Common PAC and veraPDF errors.

EasyPDFUA helps with checking and conservative tagging. However, a report or generated copy is not confirmation of legal compliance and not a certification of full PDF/UA conformance.

Frequently asked questions

When did the European Accessibility Act take effect?

The requirements of the European Accessibility Act, and therefore of national laws such as the Austrian BaFG and the German BFSG, have applied since 28 June 2025.

Do all PDFs have to be accessible?

Not necessarily. The EAA covers certain products and services for consumers. PDFs that are part of such a service should be accessible. Public sector bodies are additionally subject to their own rules.

Does the EAA apply to small businesses?

Microenterprises with fewer than 10 employees and no more than EUR 2 million in annual turnover or balance sheet total are exempt for services. If in doubt, seek a case-by-case legal assessment.

Is PDF/UA enough to meet the legal requirements?

PDF/UA is the common technical standard for accessible PDFs and covers a large part of the requirements. The legal provisions and EN 301 549 remain decisive, and content aspects such as clear language also matter.