Digital Accessibility Policies and Practices for PDF Forms | United States National Report
This report analyses USA federal and state digital accessibility policies, highlighting the shift from PDF to HTML forms to enhance inclusivity and meet accessibility standards.
Introduction
This report provides a comprehensive analysis of digital accessibility policies across key U.S. states, focusing on the unique challenges and limitations associated with PDF forms. Using federal standards, such as Section 508 and guidelines from Digital.gov, as a foundation, this analysis examines how state policies address or diverge from these federal standards in relation to PDF accessibility. This information is intended to guide public sector agencies in evaluating the impact of PDF forms on accessibility and to support the transition to more adaptable, fully digital formats for improved inclusivity and compliance.
1. Core Accessibility Standards and Requirements Across Federal and State Policies
Executive Summary: Federal standards, such as Section 508, discourage the use of PDFs for forms due to inherent accessibility challenges. Many states, including California, New York, and Washington, echo this sentiment, preferring HTML or other digital formats to ensure accessible user experiences.
Federal requirements, primarily Section 508 of the Rehabilitation Act and Digital.gov guidelines, mandate that all government digital content, including PDF forms, meets WCAG 2.0 Level AA standards. However, federal guidance discourages PDF forms when more adaptable formats, like HTML, are available, due to PDF accessibility limitations.
State policies vary in their adherence to these standards. While some states directly address the accessibility challenges of PDFs, others adopt general accessibility policies without providing detailed guidance for specific formats.
Jurisdiction | Accessibility Standard | Focus on PDF Form Accessibility |
Federal | Section 508, WCAG 2.0 Level AA | Prefers HTML to PDFs for forms, noting PDFs' accessibility challenges. |
Alabama | Web standards for accessibility | General focus on accessible government information; limited PDF-specific guidance. |
Arizona | AZ.gov accessibility model | Ensures accessibility across state websites; encourages compliant PDF forms. |
California | WCAG 2.0 AA | Advises HTML over PDF; requires accessible PDFs when used. |
Colorado | HB21-1110 | Strengthens protections for accessible government ICT; includes PDF compliance. |
Connecticut | Universal accessibility policy | Provides a checklist for accessible web design, covering PDFs in digital content. |
Illinois | IITAA | Mandates accessible PDF forms for state services. |
Indiana | IN.gov Accessibility Policy | Supports accessible state services with limited PDF-specific guidance. |
Kansas | ICT Accessibility Standards | Requires accessible ICT and usability for all state digital documents, including PDFs. |
Louisiana | Accessibility policy | Emphasises transparency and inclusivity; recommends accessibility checks for PDFs. |
Massachusetts | Enterprise IT Accessibility | Ensures IT solutions comply with accessibility standards; includes PDF forms. |
Minnesota | MN.gov Office of Accessibility | Oversees accessible state documents, including PDFs. |
Missouri | Missouri Assistive Technology | Requires accessible IT unless burdensome; mandates compliance for PDFs where feasible. |
New York | Hybrid of WCAG and Section 508 | Requires accessible alternatives to PDFs; supports HTML for flexibility. |
Oklahoma | EITA | Mirrors Section 508 for accessible state technology, including PDFs. |
Virginia | VITA Standard | Advises HTML for adaptability; regulates accessible PDFs when used. |
Washington | Policy 188 | Prioritises HTML-based formats for forms over PDFs due to accessibility concerns. |
2. PDF Accessibility Challenges and Federal Guidance
Executive Summary: Federal policies discourage PDF forms, citing accessibility limitations that require extensive modifications. States like Illinois, Washington, and Virginia echo these concerns, promoting HTML over PDFs to meet accessibility needs.
Federal guidelines from Section508.gov and Digital.gov highlight the challenges that PDF forms pose for accessibility. These formats require extensive tagging and other modifications to meet even basic accessibility standards, and they often fall short when compared to HTML’s inherent adaptability. The Delivering a Digital-First Public Experience policy advises that agencies minimise PDF use in favour of web-native formats to maximise accessibility.
State responses to PDF accessibility vary significantly. States like Illinois and Washington enforce strict requirements for accessible PDFs but encourage alternatives due to the technical barriers associated with PDF forms. Other states, such as Alabama and Kansas, generally promote accessible digital content but do not provide extensive guidance specific to PDF forms.
Jurisdiction | Approach to PDF Forms | PDF Accessibility Emphasis |
Federal | Strongly discourages PDFs; recommends HTML | Requires PDFs to be accessible with tagging and navigation features. |
Alabama | Limited PDF guidance | Adopts general accessibility standards without specific PDF recommendations. |
Arizona | Accessible PDFs encouraged | Requires tagging and navigation in PDF forms for accessibility. |
California | Prefers HTML; requires accessible PDFs | Notes tagging and navigation challenges in PDF forms. |
Colorado | Requires accessible PDFs | Stipulates compliance for PDF forms in line with ICT accessibility standards. |
Connecticut | Limited PDF guidance | Adopts broad accessibility policies but lacks specific PDF accessibility recommendations. |
Illinois | Mandates accessible PDFs | Requires tagging and compatibility with screen readers. |
Indiana | Accessible PDFs encouraged | Focuses on broad accessibility; limited specifics for PDF modifications. |
Kansas | PDF accessibility checks required | Mandates tagging and structure modifications for compliant PDF forms. |
Louisiana | Accessible PDF checks recommended | Emphasises inclusivity in PDF forms with accessibility testing. |
Massachusetts | PDF accessibility enforced | Enforces compliance for PDF tagging, navigation, and assistive technology compatibility. |
Minnesota | PDF accessibility promoted | Encourages compliance for state-produced PDFs, ensuring tagging and readability. |
Missouri | Accessible PDFs where feasible | Requires tagging, headings, and navigation within PDFs for accessibility. |
New York | Prioritises HTML; discourages PDFs | Identifies HTML as preferred due to PDF limitations with assistive technologies. |
Oklahoma | PDF accessibility encouraged | Adheres to Section 508 but advises limited PDF use where possible. |
Virginia | Limited PDF use; prefers HTML | Recommends HTML for accessibility but provides for accessible PDF use when necessary. |
Washington | Discourages PDFs for forms | Prioritises HTML for forms due to extensive tagging needs in PDF documents. |
3. Digital Transformation and Adaptability in Form Design
Executive Summary: Federal policies push for a digital-first approach that limits PDF use in favour of HTML for forms. States like New York, Virginia, and Washington align closely with this directive, while others offer general guidance without firm format preferences.
The federal Delivering a Digital-First Public Experience policy mandates a digital-first approach for government services, prioritising adaptable formats like HTML for accessible forms. This digital-first directive, reinforced through Section 508 and Digital.gov guidelines, encourages the reduction of PDF reliance to facilitate inclusivity.
States such as New York, Virginia, and Massachusetts align closely with this federal direction by promoting HTML forms over PDFs, while states like Alabama and Connecticut focus on general accessibility without specifying format preferences. California and Colorado have implemented flexible digital transformation policies that allow PDF use but recommend alternatives where feasible.
Jurisdiction | Digital Transformation in Form Design | Preferred Format for Forms |
Federal | Advocates digital-first, prioritising HTML over PDFs | HTML |
Alabama | Limited digital transformation focus | Adopts broad accessibility standards without specifying a preferred format for forms. |
Arizona | Encourages accessible formats | Promotes compliance across formats but favours HTML for flexibility. |
California | Supports digital transformation; limited PDF use | HTML preferred; accessible PDFs allowed when necessary |
Colorado | Encourages adaptable, web-native forms | Prioritises HTML for form accessibility and usability. |
Connecticut | Limited digital-first guidance | General accessibility focus; does not mandate HTML as a default form format. |
Illinois | Digital-first approach promoted | Prioritises HTML for forms; allows PDFs only with extensive accessibility measures. |
Indiana | General accessibility for forms | Supports HTML for forms but lacks specific digital-first policies. |
Kansas | Emphasises accessible digital formats | Prioritises HTML, though accessible PDFs are permitted under rigorous testing protocols. |
Louisiana | Limited PDF focus in digital strategy | Prioritises inclusivity but lacks specific digital-first guidance. |
Massachusetts | Digital-first design encouraged | Strongly advocates HTML as the preferred format for forms. |
Minnesota | Encourages digital-first form design | HTML is promoted as default; accessible PDFs allowed only where necessary. |
Missouri | Recommends adaptable formats | Supports HTML for usability and adaptability; PDFs permitted with accessibility measures. |
New York | Digital-first with phased PDF reduction | HTML |
Oklahoma | PDF use with restrictions | Advises limited PDF use; promotes accessible digital formats for all public services. |
Virginia | Strongly encourages HTML for adaptability | HTML |
Washington | Prioritises HTML-based digital forms | HTML |
4. Accessibility Gaps in PDF Forms and Challenges with Assistive Technology
Executive Summary: Federal and state policies consistently identify PDFs as problematic for assistive technology, reinforcing the shift toward HTML for accessible form design. Limited guidance on PDFs in states like Alabama suggests potential gaps in comprehensive accessibility strategies.
PDF forms, due to their static nature, present significant accessibility challenges, particularly for users relying on assistive technologies. Federal guidelines on Section508.gov and Digital.gov underscore the limitations of PDFs, which require tagging and extensive formatting to achieve basic accessibility compliance. HTML, in contrast, offers inherent adaptability and improved compatibility with assistive technologies.
Jurisdiction | Assistive Technology Compatibility for Forms | Noted Gaps in PDF Form Accessibility |
Federal | Supports HTML for assistive compatibility | Significant challenges with PDF forms, such as lack of reflow and tagging issues. |
Alabama | Limited guidance | Lacks specific recommendations for assistive technology compatibility in PDF forms. |
Arizona | Accessible PDF design promoted | Identifies limitations in PDFs for screen reader compatibility and navigation. |
California | HTML recommended for assistive compatibility | Notes accessibility barriers in PDFs, including navigation and screen reader issues. |
Colorado | Advocates for HTML | Acknowledges assistive technology limitations in static PDFs. |
Connecticut | Broad accessibility focus | Limited PDF-specific guidelines for assistive technology. |
Illinois | Supports HTML over PDF for accessibility | Addresses assistive tech challenges, such as lack of reflow in PDF forms. |
Indiana | General accessibility for forms | Does not address PDF-specific compatibility issues in detail. |
Kansas | Requires accessibility testing | Stresses tagging and navigation improvements needed in PDFs for compatibility. |
Louisiana | Accessibility testing for PDFs | Recommends testing but lacks detailed guidance for PDF accessibility with assistive tech. |
Massachusetts | Promotes HTML for assistive tech | Highlights screen reader challenges and flexibility limitations in PDF forms. |
Minnesota | Discourages PDF for assistive users | Emphasises HTML to avoid limitations in PDF navigation and reflow. |
Missouri | Limited PDF guidance | Addresses assistive compatibility but allows PDFs with significant modifications. |
New York | Strongly encourages HTML | Notes static nature of PDFs and limited compatibility with assistive tech tools. |
Oklahoma | PDF use with restrictions | Advises HTML to avoid navigation issues in PDFs. |
Virginia | Limited PDF use due to assistive limitations | Strong preference for HTML for better adaptability with assistive technologies. |
Washington | Prioritises HTML for assistive users | Discourages PDF forms due to screen reader and navigation barriers. |
5. Policy Summary and Recommendations for Accessible PDF Form Alternatives
Federal standards, established by Section 508 and Digital.gov, prioritise HTML and adaptable formats over static PDFs for accessible forms. States such as New York, Virginia, and Washington adopt similar digital-first policies to minimise PDF usage, while others, including California and Colorado, permit PDF forms with extensive accessibility modifications.
This report recommends minimising PDF use in favour of HTML, supporting a digital-first approach that aligns with federal standards and enhances accessibility for all users, particularly those relying on assistive technologies.
Conclusion
This comparative analysis demonstrates a consistent preference for adaptable, accessible formats like HTML over PDFs in federal and state policies. While federal guidelines discourage PDF forms, states such as New York, Virginia, and Washington reflect this approach by prioritising digital-first strategies for improved accessibility. States like Alabama and Louisiana, with general accessibility focuses, could strengthen their policies by incorporating specific guidance on PDF accessibility.
This report underscores the need for ongoing digital transformation and reinforces the value of HTML as a universal, accessible format for government services.
References
Alabama: Alabama.gov Accessibility Policy
Retrieved from https://www.alabama.gov/terms-of-use
Arizona: AZ.gov Accessibility Policy
Retrieved from https://az.gov/policy/accessibility
California: CA.gov State Digital Accessibility Laws
Retrieved from https://www.dor.ca.gov/Home/Laws
Colorado: Colorado Laws For Persons With Disabilities
Retrieved from https://leg.colorado.gov/bills/hb21-1110
Connecticut: State of Connecticut Universal Web Site Accessibility Policy for State Web Sites
Retrieved from https://www.access.state.ct.us/policies/accesspolicy40.html
Illinois: Illinois Information Technology Accessibility Act (IITAA)
Retrieved from https://doit.illinois.gov/initiatives/accessibility/iitaa.html
Indiana: IN.gov Accessibility Policy
Retrieved from https://www.in.gov/core/accessibility.html
Kansas: State of Kansas Information and Communication Technology Accessibility Standards
Retrieved from https://www.ebit.ks.gov/resources/governance/it-executive-council/itec-policies-standards/1210-information-and-communication-technology-accessibility-standards
Louisiana: Louisiana.gov Accessibility Statement
Retrieved from https://www.louisiana.gov/accessibility-statement/
Massachusetts: Mass.gov Policy Advisory Enterprise Information Technology Accessibility Policy
Retrieved from https://www.mass.gov/policy-advisory/enterprise-information-technology-accessibility-policy
Minnesota: MN.gov Office of Accessibility
Retrieved from https://mn.gov/mnit/about-mnit/accessibility/
Missouri: Missouri Assistive Technology
Retrieved from https://at.mo.gov/it-access/
New York: New York Office of Technology Services Accessibility Compliance Reporting
Retrieved from https://its.ny.gov/document/accessibility-web-based-information-and-applications-compliance-reporting
Oklahoma: Oklahoma Electronic and Information Technology Accessibility Law (EITA)
Retrieved from http://www.ok.gov/accessibility
U.S. Access Board. (n.d.). ICT Accessibility Standards and Guidelines. Retrieved from https://www.access-board.gov/ict/
U.S. General Services Administration. (n.d.). Digital Accessibility Resources. Digital.gov. Retrieved from https://digital.gov/topics/accessibility/
U.S. General Services Administration. (n.d.). PDF Accessibility Guidelines. Section 508.gov. Retrieved from https://www.section508.gov/create/pdfs/
U.S. Office of Management and Budget. (n.d.). Delivering a Digital-First Public Experience. White House. Retrieved from https://digital.gov/resources/delivering-digital-first-public-experience/#what-does-it-mean-to-digitize-forms-and-services-2
U.S. Office of Management and Budget. (n.d.). OMB Memorandum M-23-22: Delivering a Digital-First Public Experience. White House. Retrieved from https://www.whitehouse.gov/omb/management/ofcio/delivering-a-digital-first-public-experience/#IIIB
Virginia: Virginia Information Technologies Agency (VITA) Accessibility Standards
Retrieved from https://www.vita.virginia.gov/
Washington: Washington State’s Accessibility Policy 188
Retrieved from https://watech.wa.gov/policies/accessibility-policy
World Wide Web Consortium (W3C). (2008). Web Content Accessibility Guidelines (WCAG) 2.0. Retrieved from https://www.w3.org/TR/WCAG20/
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