WCAG 2.2 AA Compliance for PDFs

What's New in WCAG 2.2 for PDF Accessibility

WCAG 2.2, published in October 2023, represents the most significant update to accessibility guidelines since WCAG 2.1. The update adds nine new success criteria specifically designed to improve accessibility for users with cognitive disabilities, low vision, and those using mobile or touch devices.

For organizations already compliant with WCAG 2.1 AA, the transition focuses on six new criteria at Level A and AA. At Level A, two new criteria apply: Consistent Help (3.2.6) requiring help mechanisms to appear in the same location across pages, and Redundant Entry (3.3.7) preventing users from re-entering the same information twice.

At Level AA, four new criteria apply: Focus Not Obscured (2.4.11) ensuring keyboard-focused elements remain visible, Dragging Movements (2.5.7) requiring single-pointer alternatives for drag operations, Target Size (2.5.8) mandating minimum 24×24 pixel touch targets, and Accessible Authentication (3.3.8) eliminating cognitive function tests for login processes.

While some criteria apply more directly to web interfaces, they have important implications for interactive PDF forms. Multi-page PDF forms must respect redundant entry requirements, and form checkboxes must meet minimum target sizes.

How WCAG 2.2 AA Applies to PDF Documents

PDF documents must meet all applicable WCAG 2.2 AA success criteria to be considered accessible. Unlike web pages where criteria are immediately obvious, PDF accessibility requires understanding how each criterion translates to the document format.

Perceivable Requirements (Guidelines 1.1-1.4) Every image, chart, and graphic in your PDF needs alternative text (1.1.1). Your document structure—headings, lists, tables—must be conveyed through proper PDF tags, not just visual formatting (1.3.1). The reading order must be logical when accessed via assistive technology (1.3.2). Text must have sufficient contrast: 4.5:1 for normal text, 3:1 for large text (1.4.3).

Operable Requirements (Guidelines 2.1-2.5) All interactive elements like form fields must be keyboard accessible (2.1.1). Users must be able to navigate using bookmarks for documents over 20 pages (2.4.1). The new target size criterion (2.5.8) affects form checkboxes and buttons—they must be at least 24×24 pixels.

Understandable Requirements (Guidelines 3.1-3.3) The document language must be declared in metadata (3.1.1). Form fields need clear labels and instructions (3.3.2). The new redundant entry criterion (3.3.7) means multi-page forms shouldn't require re-entering information already provided.

Robust Requirements (Guideline 4.1) Your PDF structure must be valid and parse correctly with assistive technologies (4.1.1). All form fields need proper name, role, and value attributes (4.1.2).

Most Common WCAG 2.2 AA Failures in PDFs

Based on industry research and PDF accessibility audits, these are the accessibility failures that occur most frequently in enterprise documents—and that carry the highest compliance risk.

1. Missing or Incorrect PDF Tags (1.3.1) This is the #1 failure. Documents without proper tag structure are completely inaccessible to screen reader users. Even tagged PDFs often have incorrect tags—paragraphs marked as headings, tables without proper header cells, or lists formatted as plain text.

2. Images Without Alternative Text (1.1.1) Charts, graphs, logos, and photos frequently lack alternative text. Complex data visualizations need detailed descriptions, not just "chart" or "figure 1." Decorative images should be marked as artifacts to be ignored by assistive technology.

3. Improper Reading Order (1.3.2) Multi-column layouts, sidebars, and complex page designs often result in scrambled reading order. Screen readers may jump between columns unpredictably, making content incomprehensible.

4. Insufficient Color Contrast (1.4.3) Light gray text on white backgrounds, colored text on colored backgrounds, and charts using similar hues all fail contrast requirements. The 4.5:1 ratio for body text is non-negotiable.

5. Inaccessible Form Fields (4.1.2) Form fields without proper labels, missing field descriptions, illogical tab order, and checkboxes that can't be operated via keyboard are common in loan applications, registration forms, and government documents.

6. Missing Document Title and Language (2.4.2, 3.1.1) Many PDFs have filename as title ("report_final_v3.pdf") rather than a meaningful title. Document language is frequently undeclared, causing screen readers to mispronounce text.

Achieving WCAG 2.2 AA Compliance for Your PDFs

A systematic approach to WCAG 2.2 AA compliance ensures no requirements are missed and creates sustainable processes for ongoing compliance.

Step 1: Comprehensive Audit Begin with a full audit against WCAG 2.2 AA success criteria. Use automated tools like PAC (PDF Accessibility Checker) for initial screening, but don't rely on them exclusively. According to accessibility research, automated tools detect only about 40% of WCAG issues—manual testing with actual screen readers is essential for complete validation.

Step 2: Prioritized Remediation Plan Not all failures carry equal weight. Prioritize based on: legal exposure (customer-facing documents first), severity (complete barriers before inconveniences), and volume (template fixes that affect many documents). Critical failures like missing tags or absent alt text should be addressed immediately.

Step 3: Document Remediation Fix documents to meet all criteria. This typically involves: adding proper PDF tags and structure, writing meaningful alternative text, correcting reading order, ensuring form field accessibility, and setting document metadata. For high-volume documents, consider fixing source templates to prevent recurring issues.

Step 4: Validation and Certification After remediation, validate against WCAG 2.2 AA using both automated checks and manual testing. Test with multiple screen readers (NVDA, JAWS, VoiceOver) to ensure real-world usability. Document your compliance with a VPAT (Voluntary Product Accessibility Template) or accessibility statement.

Step 5: Ongoing Maintenance Accessibility isn't a one-time fix. Establish processes to ensure new documents are created accessibly from the start. Train content creators on accessibility requirements. Implement quality gates that check accessibility before publication.