The European Accessibility Act and your PDFs

A customer who uses a screen reader opens your terms, your price list or a booking confirmation and gets nothing useful: no headings, a jumbled reading order, images with no description. Under the European Accessibility Act, that can be a compliance problem as well as a lost customer. Here is what the law requires, who it covers, and how to make PDFs that work for more people.

This is general information, not legal advice. If you are unsure whether the law applies to your business, ask a lawyer or your national authority.

What the European Accessibility Act is

The European Accessibility Act, or EAA, is an EU directive (Directive (EU) 2019/882). EU countries had to turn it into national law by 28 June 2022 and apply those rules from 28 June 2025 (EUR-Lex). It sets common accessibility requirements for a list of products and services, so people with disabilities can use them and businesses face one set of rules across the EU (European Commission).

Who it covers

The EAA applies to certain products placed on the market and services provided to consumers after 28 June 2025, including:

• Computers, smartphones, e-readers and their operating systems
• Payment terminals, ATMs, ticket machines and check-in machines
• Electronic communications and access to audiovisual media services
• Websites, apps and e-tickets for air, bus, rail and waterborne passenger transport
• Consumer banking services
• E-books
• E-commerce services

There is an important exemption for very small service businesses. Microenterprises that provide services do not have to meet the service accessibility requirements. The directive defines a microenterprise as one with fewer than 10 staff and an annual turnover or balance sheet total of no more than €2 million. The exemption is for services; businesses that make or sell covered products still have obligations, even when they are small.

Where PDFs come in

The directive does not single out PDFs, but documents are part of how many covered services work. Account terms, order confirmations, e-tickets and product information often arrive as PDFs. For services, the directive asks providers to make the information they give perceivable, operable and understandable, to make it work reliably with assistive technology, and to supplement non-text content with an alternative (EUR-Lex, Annex I).

Two details help you decide where to start:

• Office file formats published on websites and apps before 28 June 2025 are outside the directive's scope. Documents you publish from that date are the ones to get right.
• Service contracts agreed before 28 June 2025 can continue unchanged until they expire, but for no longer than five years from that date.

How accessibility is measured

The EAA is written in general terms. It does not give a checklist for PDFs.

For PDFs, the key idea is tags. A tagged PDF carries a hidden structure that tells a screen reader what is a heading, a list, a table or an image, and in what order to read it. The free PAC checker tests files against PDF/UA and the Web Content Accessibility Guidelines (WCAG), which it calls the two most widely recognised document accessibility standards (PAC).

Practical steps for accessible PDFs

The most reliable route is to build accessibility into the source document and then export a tagged PDF.

Step 1. Start in the source file. Use real heading styles in Word, Google Docs or similar, not just bigger bold text. Use proper bulleted lists and simple tables with a header row.

Step 2. Describe images. Add alternative text to every image that carries meaning, and mark purely decorative images as decorative.

Step 3. Write plainly. Use short sentences, descriptive link text and the right document language.

Step 4. Check contrast. Make sure text stands out from its background, and don't rely on colour alone to show meaning.

Step 5. Export a tagged PDF. In Microsoft 365, run the Accessibility Checker first, then save as PDF with the "Document structure tags for accessibility" option turned on (Microsoft Support).

Step 6. Test the result. Run the PDF through a checker such as PAC, which also includes a visual check, then try it with a screen reader yourself.

Where Pagestro fits, and where it doesn't

Pagestro's PDF tools do not add or repair accessibility tags. Tools that build a new file, such as merge and split, don't carry existing tags over. For an accessible final PDF, export it from your source app and check it.

Pagestro can help earlier in the process:

• A scanned PDF is just pictures of pages, which a screen reader cannot read. OCR PDF can add a searchable text layer or rebuild the scan as an editable Word file. Fix the headings and alt text in Word, then export a tagged PDF. Our guide to making a scanned PDF searchable walks through the OCR part.
• PDF/A is about long-term archiving, not accessibility. PDF to PDF/A makes an archival PDF/A-2b copy that keeps how the pages look, but it doesn't make a file readable by screen readers. See what PDF/A is for the difference.

Both tools run in your browser, so your documents are not uploaded.

Frequently asked questions

Does the EAA apply to my small business?

It depends on what you sell. The EAA covers specific products and consumer services, such as e-commerce and banking. Microenterprises that provide services, meaning fewer than 10 staff and no more than €2 million in turnover or balance sheet total, are exempt from the service requirements.

Do I have to fix every old PDF on my website?

Office files published on websites and apps before 28 June 2025 are outside the directive. Focus on documents you publish from that date. National laws can add detail, so check yours.

Is a PDF/A file accessible?

Not by itself. PDF/A is about keeping a file readable for the long term. An accessible PDF needs tags, alternative text and a logical reading order.

Can Pagestro make my PDFs accessible?

Not on its own. Pagestro doesn't add accessibility tags. It can turn a scan into editable text with OCR, so you can finish the job in a word processor and export a tagged PDF.