PDF Accessibility for Government Organizations

Digital Accessibility Decree: Legal Requirements for Dutch Government

The Digital Accessibility Decree (Besluit Digitale Toegankelijkheid) is the Dutch implementation of the EU Web Accessibility Directive (2016/2102). It mandates that all digital content published by Dutch government organizations—websites, mobile applications, and documents including PDFs—must conform to EN 301 549, the European accessibility standard that references WCAG 2.1 AA.

The Decree applies to all levels of Dutch government: national ministries, provincial governments, municipalities, water boards, and public bodies. It also covers organizations that perform public tasks or receive significant government funding. Enforcement is handled by the ACM (Autoriteit Consument & Markt), which conducts compliance reviews and can impose penalties for persistent non-compliance.

Document Accessibility Requirements PDF documents published on government websites must meet the same accessibility standards as web pages. This includes policy documents, forms, annual reports, procurement documents, and public notices. Documents published after September 23, 2020 must be accessible—there is no 'legacy exemption' for newly published content regardless of when it was originally created.

Accessibility Statements Government organizations must publish accessibility statements on their websites. These statements must declare the conformance status of the website and its documents, describe known accessibility barriers, and provide contact information for accessibility issues. The statements must be updated annually.

Accessibility Challenges in Government Documents

Government organizations face particular challenges in achieving document accessibility due to the volume, variety, and legacy nature of their document portfolios.

Forms and Interactive Documents Government forms—applications, declarations, registrations—are among the most critical documents for citizens. Yet many government PDFs have form fields without labels, illogical tab orders, missing field descriptions, and no error handling. Citizens using screen readers may be unable to complete essential transactions like tax filings, permit applications, or benefit claims.

Policy Documents and Reports Lengthy policy documents often have complex structures with multiple heading levels, cross-references, footnotes, and appendices. These require careful tagging to be navigable. Tables of contents need to link to their corresponding sections. Figures and charts need comprehensive alternative text that conveys the policy implications, not just the visual content.

Legal and Legislative Texts Legislative documents have specific structural requirements—articles, paragraphs, sub-paragraphs—that must be tagged semantically. Cross-references to other legislation must be identifiable. These documents are often lengthy and require bookmarks and proper heading structure for efficient navigation.

Multilingual Documents Government documents are often published in Dutch with English or other language versions. Each version must be independently accessible with correct language tagging. Documents containing multiple languages must mark language changes inline so screen readers pronounce text correctly.

Accessibility in Government Procurement: TenderNed Requirements

Dutch government procurement increasingly requires accessibility compliance. Organizations bidding for government contracts must demonstrate that their deliverables—including documents—meet accessibility standards.

TenderNed and Procurement Requirements TenderNed, the Dutch government's electronic procurement system, publishes tenders that frequently include accessibility requirements. Bids may be evaluated on whether proposed solutions meet EN 301 549 and WCAG 2.2 AA. For contracts involving document deliverables, PDF/UA compliance may be explicitly required.

Demonstrating Compliance Government contractors need to demonstrate their accessibility capabilities. This may include: compliance certificates for existing documents, accessibility testing methodology documentation, processes for ensuring ongoing accessibility, and staff training records. EqualXS provides compliance certification that satisfies these procurement requirements.

Contract Deliverables Documents delivered under government contracts must meet the same accessibility standards as internally-produced documents. Contractors should build accessibility review into their delivery processes and ensure they have the capability to remediate documents that don't pass accessibility testing.

Downstream Requirements Organizations receiving government funding may also be subject to accessibility requirements. Subsidized organizations, ZBOs (autonomous administrative authorities), and public-private partnerships should verify their accessibility obligations.

Implementing Document Accessibility for Government Organizations

Government organizations need systematic approaches to achieve and maintain document accessibility across departments and document types.

Phase 1: Portfolio Assessment Begin with a comprehensive audit of your document portfolio. Identify all document types published across your organization—policy documents, forms, reports, public notices. Assess current accessibility status using automated tools like PAC for initial screening. EqualXS provides detailed portfolio assessments mapping to Decree requirements.

Phase 2: Priority Remediation Not all documents have equal priority. Focus first on: documents with active citizen usage (forms, frequently accessed information), documents for which you've received accessibility complaints, newly published documents (which have no legacy exemption), and documents with legal significance. Address these immediately while developing longer-term processes.

Phase 3: Template Standardization Create accessible templates for common document types across your organization. Standardized templates for policy documents, forms, reports, and public notices ensure new documents start from an accessible foundation. Include accessibility checkers in document approval workflows.

Phase 4: Staff Training Train staff who create documents on accessibility requirements and techniques. This includes: accessible Word and PowerPoint creation, proper PDF export procedures, alternative text writing, and use of accessibility checking tools. Different training may be needed for different roles—policy writers, web teams, communication departments.

Phase 5: Ongoing Compliance Establish processes for maintaining compliance: regular accessibility audits, procedures for responding to citizen accessibility requests (required under the Decree), annual accessibility statement updates, and integration of accessibility into document governance. EqualXS offers ongoing monitoring services to maintain your compliance status.