The EAA is a landmark piece of legislation designed to ensure that digital products and services are accessible to people with disabilities. It aims to eliminate barriers and promote digital inclusion across the EU, impacting sectors like:
E-commerce and banking
Websites and mobile apps
E-books and audio-visual content
Ticketing and transport systems
Consumer hardware like smartphones and ATMs
Offer goods/services to EU customers even if the company is not EU-based
Yes, PDFs are included.
Any digital document that plays a part in customer-facing services (such as product information, reports, brochures, application forms, contracts, instructions, or legal disclosures) must be accessible under the EAA.
That means your downloadable PDFs, if they’re used to communicate essential information, need to be compatible with assistive technologies like screen readers, and conform to WCAG 2.1 AA (soon WCAG 2.2).
An accessible PDF should:
Use proper document structure (headings, lists, tables)
Have descriptive alt text for images and graphs
Include tags to indicate reading order
Be navigable with keyboard and assistive tech
Have sufficient colour contrast and readable fonts
Contain searchable text (not just scanned images)
Tools like Adobe Acrobat Pro, PAC 2024 (PDF Accessibility Checker), or accessibility plugins for your content management system (CMS) can help test and remediate PDFs.
Ensuring a PDF is accessible under the EAA isn’t just a case of “fixing it at the end.” It requires thinking about accessibility at every stage of content creation, from the original document in Word, InDesign, or another authoring tool, through to the exported PDF.
This means planning document structure before you write, using clear and consistent heading levels, choosing fonts and colours with adequate contrast, and ensuring all non-text elements have meaningful alternative descriptions.
It also means checking that the export process preserves tags, reading order, and searchable text, rather than producing a flat image file. By baking accessibility into the design and production process, you’ll avoid costly retrofits, speed up compliance, and deliver a better experience for all users.
Over 1.3 billion people globally live with a disability. For them, digital accessibility is about equal access, independence, and dignity. But there’s a strong business case, too:
89% of professionals say accessibility offers a competitive advantage
81% say it improves customer acquisition
75% say it increases revenue
(Source: Level Access)
Ignoring accessibility means more than just missing out on market opportunities. Non-compliance with the EAA could result in fines up to €100,000, product bans, and serious reputational damage.
Start by conducting an accessibility audit of your digital estate. Identify all customer-facing PDFs and test them against WCAG 2.1 standards. Many PDFs fall short due to being untagged or poorly structured.
Don’t wait until content is live. Design and develop with accessibility from the start:
Use accessible templates in Word, InDesign, or your CMS
Train your teams in PDF tagging and WCAG principles
Invest in monitoring tools to flag issues early
You’re required to be transparent. Outline how your website and PDFs meet accessibility standards, include contact information, and provide a feedback channel for users encountering issues.
Accessibility is an ongoing journey. As your content evolves, so must your approach. Monitor performance, collect feedback, and adapt.
Accessibility Beyond the Web
Tools like Signly, which overlay sign language translations on web content, are great examples of low-code, high-impact accessibility enhancements. But equally important is content accessibility, the everyday PDFs, documents, and reports that people rely on to understand your services.
A fully accessible digital experience includes everything your users interact with, not just your homepage.
The 2025 EU Accessibility Regulations apply to more than just websites. If your organisation publishes digital documents, especially PDFs, they must be accessible under the European Accessibility Act.
Accessibility isn’t just a legal checkbox. It’s a way to connect, to lead, and to build trust with a broader audience. By ensuring your PDFs and web content meet accessibility standards, you’re opening the door to inclusive communication, stronger engagement, and better compliance.
Many organisations are now embedding real-time accessibility tools into their websites to improve usability for people with disabilities. For example:
A sign language interpreter tool is accessible from the bottom right corner of the screen.
A comprehensive accessibility toolbar that allows users to adjust font size, contrast, and more.
Behind the scenes, it's equally important to monitor compliance. Adding automated accessibility scanning tools into the back end of your website helps identify and resolve issues proactively, ensuring ongoing compliance with accessibility standards.
Need support assessing your documents or getting ready for the EAA?
We’re here to help guide you on the road to compliance.
📩 Contact: Bob Crosbie-Dawson
📧Email: bcrosbie-dawson@blacksun-global.com
Black Sun Global is a stakeholder advisory and engagement agency that's been driving transformation and positive change for ambitious brands for more than 20 years. With deep expertise in disclosure and reporting, ESG, sustainability, and digital engagement, we reshape how organisations connect with customers, investors, employees, and the wider world.
We are trusted partners to some of the most influential global organisations, sparking innovation and sustainable performance through our strategic insights, partnerships, and proprietary technologies.
As founders of the Positive Change Group, we are on a mission to create a new kind of stakeholder relations partner. Our world-class specialists work closely with executive leadership teams to protect reputations, inspire trust, and promote responsible business practices - building resilience and long-term value in a rapidly changing world.
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