Does WCAG Apply to PDFs?

Yes. While the Web Content Accessibility Guidelines were originally written with websites in mind, WCAG applies to all digital content — including PDF documents. Every major accessibility law around the world, from ADA Title II in the United States to the Disability Discrimination Act in Australia and EN 301 549 in Europe, references WCAG as the standard and explicitly includes documents published online.

If your university uploads a PDF to a website, an LMS, or a shared drive, that document falls under the same accessibility requirements as the web page hosting it.

What WCAG Actually Requires

WCAG stands for Web Content Accessibility Guidelines, a set of standards published by the World Wide Web Consortium (W3C). The guidelines are organised around four principles — content must be Perceivable, Operable, Understandable, and Robust (POUR). Each principle contains specific success criteria at three conformance levels: A, AA, and AAA.

Most laws and institutional policies require conformance to WCAG 2.1 Level AA. For a deeper look at the differences between WCAG versions, see our guide on WCAG 2.0 vs 2.1 vs 2.2.

The critical point that many people miss: the "Web" in WCAG refers to web content, not websites. The W3C defines web content as "information and sensory experience to be communicated to the user by means of a user agent." A PDF opened in a browser, a document viewer, or assistive technology is web content.

Which WCAG Success Criteria Apply to PDFs?

Not every WCAG criterion is relevant to static documents, but many are — and they cover the most common accessibility failures found in university PDFs.

1.1.1 Non-text Content (Level A) — Every image, chart, graph, and diagram in a PDF must have alternative text that conveys the same information. Decorative images must be marked as artifacts so screen readers skip them.

1.3.1 Info and Relationships (Level A) — The structure of your document must be encoded in the PDF's tag tree, not just made to look structured visually. Headings need heading tags. Lists need list tags. Tables need proper row and column headers. A screen reader cannot infer structure from font size alone.

1.3.2 Meaningful Sequence (Level A) — The reading order of the PDF must make logical sense when read linearly by a screen reader. Multi-column layouts, sidebars, and text boxes frequently break reading order in ways that are invisible to sighted users but disorienting for anyone using assistive technology.

2.1.1 Keyboard Accessible (Level A) — All interactive elements in a PDF, including form fields, links, and buttons, must be operable via keyboard. Users who cannot use a mouse must still be able to complete every task the document offers.

2.4.2 Page Titled (Level A) — The PDF must have a descriptive title set in its document properties (not just a filename like syllabus_final_v3.pdf).

3.1.1 Language of Page (Level A) — The primary language of the document must be specified in the PDF metadata so screen readers pronounce words correctly.

1.4.3 Contrast (Minimum) (Level AA) — Text must have a contrast ratio of at least 4.5:1 against its background (3:1 for large text). This applies to PDFs just as it does to web pages.

These are not obscure technicalities. They represent the baseline for making a document usable by people who are blind, have low vision, or have motor impairments.

WCAG and PDF/UA: How They Fit Together

If WCAG tells you what to achieve, PDF/UA (Universal Accessibility, formally ISO 14289) tells you how to achieve it in PDF format.

PDF/UA is a technical standard that specifies exactly how tags, metadata, fonts, and structure must be implemented within a PDF file for it to be accessible. Think of it as the PDF-specific implementation of WCAG's requirements:

• WCAG 1.3.1 says content structure must be programmatically determinable — PDF/UA specifies how to use the PDF tag tree to encode that structure.
• WCAG 1.1.1 says images need alt text — PDF/UA specifies where and how alt text is stored in the PDF's tag attributes.
• WCAG 1.3.2 says reading order must be meaningful — PDF/UA requires the tag tree to reflect the logical reading order independent of visual layout.

A PDF that conforms to PDF/UA will satisfy the relevant WCAG success criteria. The two standards are complementary, not competing.

Why "Our Website Passed" Does Not Mean Your Documents Are Compliant

This is the most common misconception we encounter. A university runs an automated scan of its website, achieves a passing score, and assumes the institution is compliant. But website scanners do not open and evaluate the PDFs, Word documents, and PowerPoints linked from those pages.

Consider what is typically published as a PDF on a university website: syllabi, course outlines, faculty handbooks, admissions guides, financial aid forms, research publications, committee minutes, policy documents, and event flyers. These documents often outnumber web pages, and they are frequently the most critical content a student or prospective applicant needs.

A website can score perfectly on every automated accessibility check while linking to hundreds of inaccessible PDFs. Under the law, each of those documents is a potential compliance failure.

What the Law Says

Multiple laws explicitly require document accessibility, not just website accessibility:

United States — ADA Title II requires state and local government entities, including public universities, to ensure their digital content is accessible. The April 2027 compliance deadline (extended from 2026 via the IFR) applies to all web content, which includes documents posted online.

United States — Section 508 applies to federally funded institutions and explicitly covers electronic documents, including PDFs, as information and communication technology (ICT).

Australia — DDA and DSE require educational institutions to provide accessible materials to students with disabilities. The Disability Standards for Education 2005 make it clear that course materials in any format must be accessible.

European Union — EN 301 549 references WCAG 2.1 Level AA and applies to documents published by public sector bodies, including universities, under the European Accessibility Act and the Web Accessibility Directive.

In every jurisdiction, the legal standard for document accessibility is WCAG. The format of the content — HTML, PDF, DOCX — does not change the obligation.

What To Do About It

If you are responsible for accessibility at a university, the practical steps are straightforward:

1. Audit your existing PDFs against WCAG 2.1 criteria. Prioritise high-traffic and student-facing documents first.
2. Fix structural issues — add tags, set reading order, include alt text, specify document language and title. For a detailed walkthrough, see our guide on how to make a PDF accessible.
3. Build accessible workflows so new documents are created correctly from the start, rather than remediated after the fact.
4. Use tooling that understands both WCAG and PDF/UA so you are not guessing at compliance.

Aelira scans your PDFs against WCAG 2.1 criteria and fixes what it finds — try it free. You can also explore how our PDF remediation pipeline works to see what automated remediation looks like in practice.

The Bottom Line

WCAG is not a website-only standard. It is the accessibility benchmark for all digital content, and PDF documents are squarely within its scope. If your university publishes PDFs — and every university does — those documents must meet WCAG 2.1 Level AA to satisfy legal requirements in the US, Australia, Europe, and beyond.

The good news: PDF accessibility is a solved problem. The standards exist, the tools exist, and the path to compliance is well-defined. The only question is whether your institution starts now or waits for a complaint to force the issue.