Digital Accessibility Policies and Practices for PDF Forms | Australian National Report

Introduction

This report provides a thorough examination of digital accessibility practices across Australian federal and state governments, with a specific focus on PDF forms. As the public sector increasingly aims to deliver inclusive digital services, PDF forms present unique challenges, particularly for individuals relying on assistive technologies. Unlike adaptable, web-native formats such as HTML, PDF forms often lack the flexibility needed to meet the diverse accessibility standards set forth by the Australian Government.

Using guidelines like the Digital Inclusion Standard and the Australian Government Style Manual as a foundation, this report analyses accessibility policies at both the federal and state levels. The goal is to identify commonalities and differences in how each jurisdiction addresses PDF form accessibility, highlighting where HTML forms are preferred for their compatibility with assistive technology. Across Australia, a shift is underway as government entities progressively favour HTML-based forms over static PDFs, recognising HTML’s inherent benefits in adaptability, usability, and compliance with WCAG 2.1 standards.

Through this national comparison, the report seeks to inform government decision-makers of the barriers associated with PDF forms, underscore the advantages of digital-first, accessible form formats, and provide recommendations for achieving more inclusive, user-centred government services.

1. Core Accessibility Requirements Across Policies for PDF Forms

Executive Summary: Australian federal and state governments consistently mandate WCAG 2.1 Level AA compliance, which influences the handling of PDF forms. While static PDF forms are recognised as accessible under specific criteria, they are generally viewed as secondary to HTML-based forms due to accessibility limitations. This reflects a growing understanding of the challenges inherent to PDF forms, and federal policies further reinforce the importance of prioritising adaptable, accessible formats.

The review reveals that all Australian states, along with the federal government, mandate compliance with WCAG 2.1 Level AA as a minimum standard, demonstrating a commitment to accessible digital content, including forms. This compliance is integral to addressing the accessibility issues inherent in static formats like PDFs, which frequently fail to fully meet WCAG standards due to limited adaptability and integration challenges with assistive technologies.

At the federal level, the Digital Inclusion Standard reinforces this commitment by requiring accessibility across all government digital forms, in line with obligations under the Disability Discrimination Act 1992. This federal emphasis provides a unified framework for states, although each jurisdiction exhibits unique responses to the limitations of PDF forms, such as Tasmania’s ambition for AAA compliance in some cases.

While these standards represent a unified approach to accessibility, they also underscore a shared recognition that static formats like PDFs can hinder accessibility. The prioritisation of HTML over PDFs, as seen in both state and federal guidelines, reflects an understanding that PDF forms often require additional resources for accessibility compliance, while HTML-based forms inherently offer better support for diverse user needs.

2. PDF Accessibility Requirements Across Jurisdictions

Executive Summary: There is a clear and growing preference for HTML-based forms, with federal and state guidelines consistently discouraging PDF forms due to accessibility barriers. PDF forms are generally permitted only when absolutely necessary, reflecting a broad understanding that PDF forms lack the inherent flexibility required for full accessibility.

The approach to PDF forms varies across jurisdictions, but a clear trend emerges: states like NSW, Victoria, and Queensland actively discourage PDF forms, preferring HTML forms for accessibility and ease of use. South Australia, Northern Territory, and Tasmania show flexibility in allowing PDF forms, but emphasise alternative formats and accessible design to mitigate usability issues.

Federal guidance aligns with this trend, as outlined in the Australian Government Style Manual, which advises against PDF forms as a primary format. The Style Manual underscores that PDFs present numerous barriers to accessibility—especially in forms—due to challenges with tagging, navigation, and assistive technology compatibility. Federal recommendations advocate for web-native formats as a standard for forms, positioning PDF forms as a less preferable option that should be used only when absolutely necessary and supplemented with accessibility features.

3. Digital Transformation in PDF Form Design and Conversion

Executive Summary: Digital transformation strategies across Australia favour HTML-based forms, with a significant emphasis on replacing static PDF forms to improve accessibility. Federal policies further support this approach, advocating for HTML as the preferred form format, with limited allowances for PDFs in complex cases.

A shared goal of transitioning to HTML-based forms reflects the push for digital transformation across federal and state governments. NSW, Victoria, Queensland, and South Australia strongly advocate for HTML as the default format for forms, while Northern Territory and Tasmania support HTML as the preferred option but allow PDFs in limited cases for complex forms.

The Digital Inclusion Standard further strengthens this shift by prioritising HTML over PDFs at the federal level, urging agencies to create user-friendly, adaptable forms. This emphasis on HTML in form design underscores the broader digital transformation objective, encouraging the replacement of PDF forms with responsive, web-based alternatives that are easier to adapt to accessibility standards.

4. Common Barriers and Gaps in PDF Form Accessibility

Executive Summary: Both state and federal policies emphasise the accessibility gaps in PDF forms, especially around compatibility with assistive technology. HTML is consistently presented as a more accessible alternative for forms, with PDF forms viewed as a last-resort format due to inherent limitations.

All states highlight the inherent accessibility limitations of PDF forms, particularly when it comes to compatibility with assistive technologies. PDF forms often fail to meet adaptive needs, posing barriers to users who rely on screen readers, magnification, and other assistive tools. NSW, Victoria, and Queensland are particularly clear about these issues, explicitly advising against PDF forms when web-native options like HTML are available.

The Australian Government Style Manual at the federal level acknowledges these limitations, providing guidelines for PDF forms only when absolutely necessary and recommending that accessible HTML alternatives be provided whenever possible. This reinforces the idea that PDF forms are inherently limited, especially in accessibility features like reflow, tagging, and navigation.

5. Conclusion

This analysis underscores a critical shift within Australia’s federal and state governments toward prioritising accessible, adaptable digital forms, with HTML emerging as the preferred format over static PDFs. While PDF forms have traditionally been used across government services, they present notable barriers to accessibility, particularly for users relying on assistive technologies. Both federal guidelines, as outlined in the Australian Government Style Manual and Digital Inclusion Standard, and state-level policies highlight the limitations of PDF forms in meeting comprehensive accessibility standards.

Our findings reveal a consistent trend: HTML-based forms are viewed as inherently more flexible, easier to integrate with assistive technologies, and better suited to the evolving expectations of a digital-first public sector. While states vary in their allowances for PDF forms, the collective preference for HTML reflects an understanding that accessible, user-centred digital experiences require more adaptable formats. This momentum aligns with global best practices, demonstrating Australia’s commitment to inclusive, responsive digital services.

The implications of this shift are significant for agencies across all levels of government. By embracing HTML and reducing reliance on PDF forms, agencies can create digital services that are not only accessible but also future-proof, adaptable to new technologies and diverse user needs. Transitioning to HTML for form design will position government services to meet both current accessibility standards and future user expectations, building a foundation for long-term digital inclusivity.

References

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