Are your business's documents (PDF, Word) accessible to your own staff?
Usually not, and nobody notices until a staff member who relies on a screen reader opens the file. A PDF scanned from paper with no text layer, a PDF with no structure tags, and a Word document formatted with bold text instead of heading styles are all a problem. They sound like noise to a screen reader, or do not read at all. The check is concrete: you open the document with Word's or Acrobat's built-in accessibility checker, then listen to it with a screen reader.
Why do internal documents sit outside the European Accessibility Act?
The Accessibility Act targets services for consumers, not internal tools between an employer and a staff member. The scope definition in Article 2 speaks of products and services provided to consumers. An internal document one colleague prepares for another is not a service provided to a consumer. So it carries no obligation under this specific law. That does not make the question unimportant, only that the reason for it is not a fine but something more practical. If your own team cannot read your documents, you lose hours in every department. Once you hire a staff member with low vision or your team ages into worsening eyesight, the problem stops being hypothetical. Documents you give customers through an in-scope service, such as a PDF of terms in an online shop, are different. Article 2(4) exempts only files published before 28 June 2025.
What makes a PDF accessible?
The foundation is a "tagged PDF". It is a file where every element, heading, paragraph, list, table, image, carries a label telling the screen reader what it is and in what order to read it. The international standard for this is PDF/UA (ISO 14289). It sets out exactly what a file must contain for people using a screen reader, a magnifier or a braille display to use it reliably. In practice an accessible PDF has selectable text, not a scanned image of a page. It has a logical reading order that follows the visual order, not the reverse. It has consistent heading levels and a text alternative for every meaningful image or graphic. It has labelled fields if the file is a form, and enough contrast between text and background. Simply converting a document to PDF does none of this automatically; the structure has to be set deliberately, starting in the source file.
What makes a Word document accessible?
Most of the same principles apply to Word, before the file ever becomes a PDF. Headings are set through Word's styles (Heading 1, Heading 2), not by bolding or enlarging text by hand, and levels are not skipped. Every meaningful image or graphic gets a short description in the Alt Text field, describing its purpose, not its appearance. Tables are used for data only, not for page layout, and carry a marked header row. Every link's text says where it goes, not just "click here." Word has a built-in tool, reached through Review, "Check Accessibility." It lists the gaps as warnings, errors and tips, and explains how to fix each one.
How can you quickly check whether your documents are accessible?
The first step is the built-in tool: in Word, Review, then "Check Accessibility"; in Acrobat, the accessibility check panel. Both catch missing alt text, missing table headers and structural errors in seconds. The second step is listening. You open the document with the free screen reader NVDA on Windows, or the built-in VoiceOver on Mac. Then you check whether headings are heard in order, whether images carry meaning spoken aloud, and whether a data table reads row by row rather than as a stream of disconnected numbers.
Questions
If the document is for internal use only, do we really need to fix it?
You are not obliged to under the European Accessibility Act, because it does not cover internal, staff-facing documents. But if a staff member cannot read an internal procedure or report, that is already lost working time, regardless of the law.
Is it enough to scan a paper document and save it as a PDF?
No. A scanned image of a page, with no recognised text, is completely unreadable to a screen reader, even if the page looks normal on screen. An extra step is needed: text recognition (OCR) and adding structure on top of it.
Is there a free tool you can use to check whether a PDF meets the PDF/UA standard?
Yes. PAC (PDF Accessibility Checker) is a free tool, in use since 2010. It checks a PDF against both PDF/UA and WCAG and shows the file's structure and a screen-reader preview. The current version is funded by Germany's Federal Ministry of Labour and Social Affairs.
Sources
- W3C, "PDF7: Performing OCR on a scanned PDF document to provide actual text," WCAG 2.2 technique.
- BOIA, "PDF Accessibility: Understanding the Basics," 2026.
- Recite Me, "Guide to PDF Accessibility," 2026.
- Microsoft, "Make your Word documents accessible to people with disabilities."
- PDF Association, "ISO 14289-1, the PDF/UA Standard."
- PAC (PDF Accessibility Checker), home page, 2026.
- Does the European Accessibility Act apply to a company that sells only to other businesses?If you sell only to businesses, the European Accessibility Act (Directive 2019/882) generally does not apply. It applies where an individual can buy online.
- What is the compliance deadline for the European Accessibility Act if my service already exists?Services must comply from 28 June 2025. Three narrower exceptions reach 2030 or later: old products, old contracts, and self-service terminals.
- What are the fines for not complying with the European Accessibility Act?The directive itself sets no fine; each country writes its own. Bulgaria's transposing law caps a company's sanction at about EUR 10,226 for a first violation.
Next step
Documents are part of the review, not just the website.
A Digital Accessibility Review also goes through your documents, orders and reports, not only the website. It shows in writing which files your own team actually cannot read.
Ask about a Digital Accessibility Reviewor write to contact@ergostrat.com