BITV 2.0: accessible PDFs in the public sector

For public-sector bodies, digital accessibility is not a future obligation; it has been law for years. Websites can be managed relatively well through central templates, but PDFs remain the most difficult part of implementation. Official notices, meeting papers, forms and reports are produced across many departments, in large numbers and often without an accessible structure.

This guide explains the legal framework and the specific requirements for PDFs, and shows how public-sector bodies can address large document volumes in practice.

Which laws apply to public-sector bodies?

The legal basis begins with EU Directive (EU) 2016/2102 on the accessibility of the websites and mobile applications of public-sector bodies. At federal level, Germany implemented it through the Disability Equality Act (BGG, Sections 12a et seq.) and the Accessible Information Technology Ordinance (BITV 2.0). State and local authorities are governed by the corresponding State equality laws and state regulations, which are broadly equivalent in substance.

Importantly, BITV 2.0 does not apply only to web pages in the narrow sense. It also covers files provided through websites or apps, so an official notice or budget published as a PDF is within scope.

When did the obligation take effect?

All deadlines in Article 12 of Directive (EU) 2016/2102 have passed:

• 23 September 2019: Websites of public-sector bodies published after 23 September 2018 had to be accessible.
• 23 September 2020: All other websites of public-sector bodies, including documents provided on them, had to be accessible.
• 23 June 2021: Mobile applications of public-sector bodies had to be accessible.

Publishing an inaccessible PDF on a public-sector website today is therefore not part of a transitional period; it fails to meet an existing obligation.

What does BITV 2.0 specifically require for PDFs?

BITV 2.0 does not provide its own technical checklist. Instead, Section 3 establishes a presumption of conformity: organisations that meet the harmonised European standard EN 301 549 are presumed to conform. Chapter 10, “Non-web documents”, applies the relevant WCAG success criteria to files such as PDFs. Following the current state of the art means using WCAG 2.2 at conformance level AA. The established implementation standard for PDFs is PDF/UA, currently PDF/UA-2.

In practice, an individual PDF needs:

• A tagged structure: Headings, paragraphs, lists and tables use PDF tags so that screen readers can interpret the document.
• A logical reading order: Content is presented in the correct sequence, including in multi-column layouts.
• Alt text: Images, graphics and diagrams have meaningful text alternatives.
• Correct table markup: Header cells and their associations with data cells are defined semantically.
• Metadata: The document title and primary language are set.

For a detailed overview of the criteria, see WCAG for PDF documents and Understanding PDF/UA.

What exceptions apply to old documents?

Article 1(4) of Directive (EU) 2016/2102 exempts office file formats published before 23 September 2018, unless they are needed for active administrative procedures. An archived set of minutes from 2015 may therefore be exempt; a 2015 application form that people are still expected to complete is not. Each public-sector body should document this distinction rather than applying a blanket “archive” label.

Accessibility statement and feedback mechanism

In addition to making the content accessible, public-sector bodies have two formal obligations under Section 12b BGG and Section 7 BITV 2.0:

1. Accessibility statement: Every public-sector website needs a regularly updated statement describing its conformance status and identifying inaccessible content, such as PDF collections, together with the reasons and planned remedial action.
2. Feedback mechanism: Users must be able to report barriers and request an accessible version of inaccessible content. The statement must also refer to the enforcement or conciliation procedure; at federal level, this is the conciliation body under Section 16 BGG.

In practical terms, every inaccessible PDF that remains online must be identified as a shortcoming in the statement and may be requested in an accessible form through the feedback mechanism at any time. The smaller the outstanding collection, the lower the ongoing workload.

Who monitors compliance?

Compliance is actively monitored. At federal level, the Federal Monitoring Body for Accessibility of Information Technology periodically examines the websites, apps and documents of public-sector bodies; the federal states have established equivalent monitoring bodies. The methodology follows Implementing Decision (EU) 2018/1524, and the findings feed into regular reports to the European Commission. Documents such as PDFs are expressly within the scope of monitoring.

Why legacy document collections are the core challenge

For most public-sector bodies, the main challenge is not one complex document but the volume. Common document types include:

• official announcements and notices,
• meeting papers and minutes, often hundreds of pages long,
• forms and applications,
• public-information brochures and leaflets,
• statistics, reports and budgets.

Legacy documents add to the challenge. Council information systems, official-gazette archives and download areas contain years of documents that must remain available but pre-date accessibility requirements. Training every member of staff is difficult because of turnover and because technical PDF tagging is rarely feasible alongside their primary work. Remediating tens of thousands of documents manually is not practical.

Manual or automated remediation?

Both approaches have a role; document volume is the deciding factor:

Automation leaves existing workflows unchanged. Staff and specialist applications continue to generate documents as before; remediation begins with the finished PDF and modifies only its structural layer, leaving the layout and content unchanged. See Automatically check and correct PDF accessibility. The specific requirements for public administration are covered on Accessible PDFs for authorities.

Accessful’s remediation guarantee applies during accessibility audits: if a document remediated by Accessful is not accepted as accessible, we will remediate it again free of charge—quickly and at no additional cost.

A step-by-step approach for public-sector bodies

1. Catalogue the collection: Inventory every publicly available PDF across the website, council information system, download areas and forms server.
2. Identify exemptions: Identify documents published before 23 September 2018 and determine whether they are needed for active administrative procedures. Document each decision.
3. Assess accessibility: Audit the remaining collection for accessibility, free of charge and without registration at scan.accessful.de.
4. Prioritize: Start with forms and documents used in active procedures, followed by frequently accessed content and then the legacy collection.
5. Correct: Process large volumes automatically and reserve targeted manual work for visually complex exceptions.
6. Update the statement: Update the accessibility statement and feedback mechanism, and list any remaining shortcomings with a remediation schedule.
7. Establish an ongoing process: Automatically audit and remediate new documents before publication through the web app or API. See How it works.

BITV 2.0 is not a project with an end date. Public-sector bodies continually produce new PDFs, so accessibility must be an ongoing, largely automated process. This keeps the document collection accessible and meets the obligations under the BGG and BITV 2.0 without placing a permanent burden on individual departments.