Navigating Government Procurement: Ensuring Accessibility Compliance for Your PDFs

We earn a commission if you make a purchase, at no additional cost to you.

Why a vendor’s documents can enter the accessibility review

The rule applies to web content and mobile apps that state and local governments provide or make available. That includes content supplied through contracts, licenses and similar arrangements.

The legal responsibility remains with the public entity, but vendors may still feel the practical effects through bid requirements, contract language, acceptance testing or requests to fix inaccessible work.

The DOJ’s guidance for small public entities is direct on this point. A government that hires another organization to provide public services must make sure the resulting web content or mobile app meets its Title II responsibilities. DOJ also defines web content broadly enough to include documents.

For a vendor, the sensible question isn’t “Does the rule regulate our company?” It’s “Which parts of our work will the customer publish or use to provide a public service?”

That could include a county benefits form, a software-generated transit report, a public university’s training manual or notices produced by a third-party platform. The document doesn’t become somebody else’s problem simply because a contractor created it.

Don’t assume every PDF exchanged with a government customer is covered. A brochure emailed to one buyer may be treated differently from a form the agency posts for residents. Ask the buyer what’s in scope while there’s still time to make changes.

Find the PDFs attached to the service

Companies tend to review the files inside a proposal and stop there. The bigger risk may be the documents the customer receives after the contract is signed.

Trace the whole service. What will your team create, upload, update or generate for the buyer? Which files could eventually reach a resident, student, patient, passenger or business owner?

• Forms people must complete
• Reports and notices generated by your software
• Manuals, instructions and training materials
• Templates the customer will edit and publish
• Recurring statements or letters
• Presentations and meeting documents
• Scanned records made available online

Include the editable source file for each document when it exists. A PDF is much easier to correct when someone can repair the headings, table structure and image descriptions in the original Word, PowerPoint or design file before exporting it again.

Then record who owns the document, where it will appear and how often it changes. Pay particular attention to files that people need to apply for a service, submit information, understand a decision or meet a deadline. A decorative brochure and an application form don’t carry the same consequences when something goes wrong.

StartupNation’s older advice to make sure you can deliver before you bid applies here. Accessibility belongs in that delivery check alongside staffing, financing and technical capacity.

Some older documents may qualify for an exception under the DOJ rule, including certain preexisting conventional electronic documents. Don’t build the inventory around that assumption. Updating a file may affect whether an exception still applies, and other ADA obligations may still require a public entity to provide accessible information to someone who needs it.

A PDF can look fine and still fail a real user

Visual inspection is a poor accessibility test. A clean page can hide missing tags, unnamed form fields, and text that a screen reader announces in the wrong order.

Take a two-column report. A sighted reader knows to finish the left column before moving to the right. If the file’s structure is wrong, assistive technology may read straight across the page, joining unrelated sentences into nonsense.

Reading order is one of the checks described in the W3C’s PDF accessibility technique. W3C explains that tag order helps determine how a PDF is read and that complex layouts don’t always convert correctly, even when the source document looks orderly.

A useful first review should ask:

• Can the text be selected, or is the document only a scanned image?
• Do headings, paragraphs and lists have meaningful structure?
• Does the reading order follow the intended meaning?
• Do informative images have useful text alternatives?
• Can someone understand a table from its headers and cell relationships?
• Do links make sense without the surrounding sentence?
• Are form fields named, explained, and placed in a sensible tab order?
• Can every interactive part be reached with a keyboard?
• Are the document title and language identified?

This is where website accessibility and document accessibility part ways. A company may have fixed its navigation, page headings, and color contrast while leaving dozens of downloadable files untouched.

Automated checkers can catch some defects, but a green result doesn’t settle the matter. Software can detect a missing image description.

Improving Document Accessibility: A Comprehensive Guide

Document accessibility is crucial for ensuring that all individuals, regardless of their abilities, can access and understand the content. However, it can be challenging to determine whether a document is truly accessible. While tools may flag certain issues, they may overlook critical aspects that affect a person’s ability to navigate the document effectively.

One effective way to ensure document accessibility is to enlist the help of a knowledgeable individual to review the file using assistive technology. For important documents such as forms or public notices, having a reviewer who understands PDF structure and accessibility can make a significant difference. It’s essential that the document not only passes a scan but also functions seamlessly for all users.

Integrating Accessibility into the Workflow

Addressing accessibility needs early in the document creation process is key. By considering accessibility requirements during the bid or discovery phase, companies can set clear expectations for the final deliverables. This includes determining the accessibility standards, file types, testing requirements, and approval processes. Using accessible templates and incorporating accessibility features during the content creation stage can streamline the production process and reduce the need for extensive post-production corrections.

For multi-team projects, establishing a shared document accessibility workflow can help ensure consistency and accountability throughout the project lifecycle. This workflow should include scoping the files, creating from an accessible source, testing before delivery, and maintaining the document integrity post-delivery.

1. Scope the files: Define the documents included and align on accessibility expectations.
2. Create from an accessible source: Provide templates with proper structure for writers and designers.
3. Test before delivery: Conduct automated checks and manual reviews to meet contract requirements.
4. Maintain the work: Keep track of source files, assign responsibility for fixes, and retest after updates.

Regular testing and maintenance are essential to ensure ongoing document accessibility, especially for recurring reports and when subcontractors are involved in content creation.

Remediating Existing Files

When existing files require remediation, it’s essential to address accessibility issues directly at the source whenever possible. This approach ensures that the company retains editable files for future revisions. Some documents may necessitate PDF remediation, involving adjustments to tags, headings, table structures, reading order, alternative text, form labels, bookmarks, and document properties.

Simply providing an accessible alternative alongside an inaccessible file may not suffice, as per DOJ guidelines. It’s crucial to prioritize remediation efforts based on the documents’ importance and frequency of use.

Proactive Accessibility Measures

Proactively addressing accessibility concerns before they become urgent is key. By selecting a target account or customer and assessing the accessibility of key documents, companies can identify and rectify accessibility issues early on. This proactive approach can prevent accessibility issues from becoming obstacles during critical contract negotiations.

Whether the documents are in good shape or require significant improvements, addressing accessibility concerns promptly is essential for ensuring inclusivity and compliance.

Take the time to assess and improve document accessibility before it becomes a pressing issue.

Image by pressfoto on Magnific

Transform the following:

Before: I have not seen her in months.

After: It has been months since I last saw her.