PDF accessibility Archives

AI and Automated PDF Accessibility in Regulated Industries: Opportunity or Trap?

Written by Kalynovska Kateryna on January 19, 2026. Posted in PDF accessibility.

Let’s imagine you are a Product Owner on a quiet Friday afternoon (or perhaps there’s no need to imagine). The tea is warm, the sprint is closed, and life feels finally pretty calm. Then, an email lands from the Compliance Manager to your inbox.

It concerns the European Accessibility Act (EAA) agenda. Your task: ensure all historical customer documents are fully accessible. You aren’t worried, assuming these “legacy PDFs” are just a minor cleanup job. Next you casually message your Tech Lead for a total file count. When the reply comes back, the tea suddenly gets colder – this is not small pile of paperwork; your bank has 4.2 million accumulated documents that need to be compliant. And the clock is ticking for company audit.

Law is not a funny thing for BFSI: we’re talking about strictly enforced accessibility regulations such as WCAG 2.2 AA and PDF/UA in Europe, or their functional equivalent in the US, the Section 508. Non-compliance means lawsuits, reputational damage, and incomcliance fines.

Naturally, the first thought in our age is: “Let’s just use AI! It writes poetry and codes websites; surely it can tag a PDF.”

Is AI the magic solution that saves your weekend, or is it a trap that will land the company in court? Let’s dive in.

The AI Mirage: Why You Can’t “Chat” Your Way to Compliance

On paper, AI sounds like the dream employee. It doesn’t sleep and processes data at lightning speed.

When tasked with pdf accessibility remediation, this “digital employee” attempts a standard three-part approach:

OCR (Optical Character Recognition): Scanning pixels into text.
Auto-Tagging: Guessing the structure (Headings, Paragraphs, Tables).
Alt-Text Generation: Describing images.

For perfect, born-digital documents, the results can be impressive, but financial institutions rarely deal in them. They deal in complex legacies: scanned mortgage deeds, faded faxes, and financial tables with merged cells that would puzzle even a human editor.

The “Hallucination” Problem

Generative AI (LLMs like ChatGPT, Claude, or Grok) is a language model, not a structure model. It can predict the next word in a sentence, but it doesn’t inherently understand the binary tag tree structure of a PDF file.

As detailed in technical analyses of AI-powered checks, AI tools often create tags based on visual assumptions rather than code-level reality. Asking a chatbot to check your PDF accessibility is like asking a fish to climb a tree. It might flop around the trunk enthusiastically, but it isn’t getting to the top.

A Textbook Example of Failure

A recent experiment by GrackleDocs exposed the dangerous overconfidence of AI. They fed a perfectly compliant PDF to various leading AIs to see what would happen.

Grok declared the perfect PDF “Non-Compliant” and hallucinated missing tags that were actually right there.
Claude invented a compliance rating of “7.5/10,” listing “gaps” that simply did not exist.
ChatGPT confidently stated there was no Alt-Text (even though there was).

AI is programmed to be helpful, not necessarily honest. If you ask for a compliance report, it will happily invent one, complete with convincing technical jargon to give you a satisfying answer. In a regulated industry, relying on a tool that creates fiction just to make you happy is a dangerous game.

Industry’s Pragmatic Compromise: The Hybrid Approach

“AI-only” seems to be a reckless gamble, but on practice the hybrid model sounds more promising

AI handles 70-90% of the work (OCR, basic tagging), then human experts verify complex elements and test with screen readers like NVDA or JAWS. By keeping a human in the loop, you achieve 99% compliance. For critical documents where legal liability is high, this human verification provides the safety net that banks require. However, quality comes at a premium.

In a case study highlighted by AWS, Ohio State University faced the remediation of massive content volumes. The reality of manual or hybrid remediation is a simple equation of time and money: costs were estimated at $3 to $4 per page.

If your bank has 100,000 pages of legacy contracts (a conservative estimate), you’re looking at an investment of $300,000 to $400,000.

Moving from Remediation to Engineering

For organisations managing millions of transactional documents, the “per-page” cost model of the hybrid approach presents a scalability challenge with significantly higher price. And whilst 61% of organisations identify technical implementation as their biggest EAA compliance barrier, forward-thinking enterprises are discovering a more efficient solution. This has led some institutions to explore a different philosophy – template-based accessibility implementation and Rule-Based Automation.

Template-based Accessibility Implementation

The template-based approach represents the most strategic path to European Accessibility Act readiness for organisations managing high-volume customer communications. For enterprises already leveraging Customer Communication Management (CCM) systems for example Quadient Inspire, OpenText, Isys Papyrus or SmartCommunications, this methodology delivers a decisive advantage: implementing accessibility at the source of PDF generation ensures every document meets compliance standards while preserving brand identity and complex business logic.

Rather than stressfuly remediating thousands of individual PDFs under deadline pressure, industry leaders are embedding accessibility directly into their document templates. See how a Polish bank serving 1.5 million customers implemented 53 accessible templates in just two months, or explore how a Finnish banking group migrated over 100 legacy documents to fully accessible templates without disrupting daily operations. The elegance here is simple: fix the template once, and every document it generates is compliant forever.

Rule-Based Automation

The rule-based approach the philosophical cousin of template-based accessibility, but with a crucial difference. Instead of redesigning individual templates one by one, you’re essentially teaching your CCM system the rules of accessibility and letting it apply them automatically across your entire document ecosystem.

The logic flips on its head. Rather than fixing a PDF after it’s been born into the world (remediation), or manually coding accessibility (and brand designs) into each template, you define the rules of accessibility once and embed them into the document generation process itself. Every PDF that rolls off the production line emerges compliant – regardless of which template spawned it.

This is where platforms like Quadient Inspire Adapt distinguish themselves. Designed to act as a seamless overlay on top of existing Quadient CCM infrastructure, the engine uses proprietary parsing algorithms to “re-engineer” the document without significant altering of core setup. It interprets content objects and applies a strict set of rules aligned with PDF/UA standards.

The Comparison: Your Realistic Options

Criteria	Pure AI-based approach	Hybrid remediation approach	Template and Rule-Based PDF accessibility in CCM
Processing speed	Fast, but inconsistent	Slow, labour-dependent	Real-time, deterministic
Cost per page	$0.50-$1.00	$3-$4	Marginal for existing CCM users
Compliance guarantee	Unreliable – cannot verify structure	Can cover up to 95%with expert review	Depends on correct manual template setup
Risk of fines	High – false positives common	Low with proper oversight and professional supervision	Low if configured by CCM experts
Human factor	AI hallucinations, no validation	High impact (fatigue and time pressure affect quality at scale)	Expert oversight required
Suitable for high-volume legacy content	No (heterogeneity amplifies errors and validation effort)	Limited and expensive (manual review scales linearly with volume)	Yes, once rules and templates are in place, volume does not increase complexity
Audit trail & legal defensibility	None (probabilistic decisions lack full explainability)	Partial (actions logged, judgments remain subjective)	Full audit trail (rules, templates, and outputs are documented and repeatable)

Case Study from Quadient Inspire Adapt: The Italian Service Bureau

An Italian service bureau needed to make a very large invoice estate accessible – including documents with complex, nested tables. They implemented Quadient Inspire Adapt as a middleware layer, without rebuilding their upstream document sources.

Result: They processed millions of pages in batch mode. Because the rules were deterministic, every single PDF came out 100% accessible and compliant.

Conclusion: Automation is the Engine, Expertise is the Fuel

Generative AI offers incredible speed, but often mistakes visual layout for semantic structure, leaving you with “plausible” but non-compliant documents. This approach can put at real risks all the document acceptance processes with no mistake logging in afterwards.

PDF Document Hybrid Remediation offers security and high accuracy, but it binds your budget to a linear cost model – the more pages you have, the more you pay.

Template-Based Implementation and Rule-Based Automation (Quadient Inspire Adapt) breaks the linear cost model and enables true scale. But scale without expertise is meaningless: accessibility emerges only when automation is guided by deep architectural and standards-level knowledge.

If you attempt to implement rule-based automation without a deep understanding of PDF accessibility standards, you risk simply building a very fast machine for creating non-compliant documents. The software provides the engine, but it does not replace the need for a skilled “pilot”.

But how do you install this “engine” into a complex banking infrastructure without halting operations? To discover how to implement these strategies within your existing architecture, we recommend reading Making digital documents accessible without disrupting the workflow. It provides a practical roadmap for integrating accessibility rules directly into your current systems, ensuring compliance without forcing a complete operational overhaul.

FAQ

Q1: My IT team wants to use a simple auto-tagging script. Will that work for our needs?

A: Auto-tagging scripts can be a starting point, but they typically achieve 70-80% accuracy because they rely on pattern recognition rather than deterministic rules. For regulated industries where compliance must be verifiable, you’ll want to consider whether that accuracy level meets your risk tolerance, particularly when processing large volumes.

Q2: If an AI validator gives my PDF a green tick, is it audit ready?

A: No. Automated checkers test for syntax (is there a tag?), not semantics (is it the right tag?). An AI might mark “image_001.jpg” as valid Alt-Text. You technically “pass” the software check, but you still fail the law (WCAG).

Q3: What happens if we miss EAA compliance and get reported?

A: Penalties vary by member state, but can be substantial, potentially reaching €100,000 or more. Beyond fines, there’s the reputational impact and the possibility of customer lawsuits. For regulated institutions, non-compliance may also trigger broader regulatory reviews of your processes.

Structural Errors: The Foundation That Breaks Everything

1. No Proper Heading Structure

Walk into any compliance department, and you’ll find dozens of Word documents where headings are created by simply making text bold or increasing font size. Authors skip heading levels, jumping from H1 directly to H3, or scatter multiple H1 tags throughout a single document without understanding the semantic hierarchy this creates.

A Word document showing the Heading 1 style menu opened. The example illustrates a common accessibility mistake: using visual formatting instead of true heading styles. Screen reader users cannot navigate the document when headings are not properly tagged.

How Customers with Disabilities Experience It: Screen reader users hear the entire document as one long, undifferentiated text block. They cannot navigate by headings, jump to specific sections, or un derstand document hierarchy. A 30-page policy document becomes an audio marathon with no way to skip to relevant sections.

The business impact extends beyond user frustration. Long contracts, product guides, and policy documents become practically unusable for blind customers, triggering complaints and potential discrimination claims. Under EN 301 549 and the European Accessibility Act, this represents a fundamental failure, not an edge case regulators might overlook.

2. Empty Lines for Spacing

It seems harmless enough: pressing Enter repeatedly to create visual spacing between sections. Yet, this common habit creates a peculiar experience for assistive technology users. Screen readers faithfully announce each empty line: “blank… blank… blank… blank…” It creates confusion about document structure. Users cannot distinguish between intentional section breaks and formatting errors.

How Customers with Disabilities Experience It: Screen readers announce each empty line: “blank… blank… blank… blank…” This creates confusion about document structure and wastes time. Users cannot distinguish intentional breaks from formatting errors.

When embedded in CCM templates, this issue multiplies across thousands of generated documents.

3. Fake Lists Using Manual Numbering

Consider how many business documents contain numbered procedures or bulleted features created by typing “1.” followed by a space, or manually inserting dashes as text characters. Authors avoid Word’s built-in list formatting tools, creating what appears visually as a proper list but contains no semantic structure underneath.

How Customers with Disabilities Experience It: Screen readers read fake lists as continuous paragraphs without announcing list structure. Users cannot navigate list items, understand hierarchies, or know how many items exist. Numbered steps in contracts or instructions become incomprehensible.

This increases support tickets, creates confusion about contractual obligations, and exposes the organisation to claims that critical information wasn’t properly communicated.

Tables: Where Complexity Meets Chaos

4. Over-Complex or Malformed Tables

Tables present unique accessibility challenges, and most business documents handle them poorly. Authors create tables with merged cells to achieve specific visual layouts, nest tables within tables, insert blank rows for spacing, or simply forget to define which rows and columns serve as headers.

How Customers with Disabilities Experience It: Screen readers track position by counting cells. Merged or split cells break this logic, causing users to hear “cell… cell… cell…” with no context. Financial tables in statements, tariffs, or fee schedules become meaningless sequences of numbers.

For banks and insurers, this creates particularly high risk because core financial information like interest rates, payment schedules, fee tariffs, transaction histories, becomes meaningless sequences of numbers. Customers cannot understand critical financial data affecting their accounts, creating clear grounds for discrimination claims under accessibility law.

5. Tables Used for Layout Purposes

What people do? They use multi-column tables to position text or create visual layouts, rather than for actual data presentation.

How Customers with Disabilities Experience It: Screen readers treat layout tables as data tables, announcing nonsense rows and columns. Content appears out of order, creating a chaotic and fragmented reading experience.

When layout tables appear in CCM templates generating customer letters, every single document becomes structurally inaccessible, and batch remediation for thousands of historical documents becomes prohibitively expensive.

Images and Visual Content: The Silent Barriers

6. Missing or Meaningless Alt Text

Images pepper business communications – charts showing payment projections, promotional banners announcing limited-time offers, process diagrams explaining how services work. Yet most contain either no alternative text descriptions or meaningless placeholders like “image1,” “logo,” or “chart.”

How Customers with Disabilities Experience It: Blind users receive no information about image content. If charts show payment schedules, promotional banners contain deadline warnings, or diagrams explain processes, visually impaired customers never learn this critical information.

This constitutes “information not provided” – a clear discrimination violation under accessibility law. In CCM workflows, the problem often affects marketing banners, legal disclaimers embedded in images, and data visualisations that organisations consider essential communication elements.

7. Text Embedded in Images

Perhaps more problematic still is the practice of embedding text within images – promotional banners designed in graphics software, infographics containing statistics and explanations, or scanned documents where text appears only as part of an image rather than selectable content.

How Customers with Disabilities Experience It: Screen readers see nothing. The document contains blank space where critical information should be. Even sighted users with low vision cannot zoom or reflow text embedded in images.

A blind customer literally cannot read documents your legal team considers as “successfully delivered.” This creates high litigation risk, as organisations cannot prove information was made accessible to all customers.

Links and Navigation: Breaking the Journey

8. Non-Descriptive Links (“Click Here”)

Open a business related document, and you’ll likely find links labelled “click here”, “read more”, or raw URLs stretching across three lines of text. These seem innocuous until you understand how screen reader users navigate documents.

How Customers with Disabilities Experience It: Screen reader users navigate by pulling up a list of all links. When they hear “click here, click here, click here, click here,” they have no idea where any link leads and must open each one blindly to find relevant content.

This affects everyone, not just assistive technology users. Furthermore, this creates particular barriers when regulatory materials, disclosures, and support resources remain effectively hidden behind meaningless link text. Support centre volume increases as customers cannot self-serve using document navigation.

Language and Metadata: The Invisible Foundation

9. Missing Document Title and Metadata

Documents live or die by their metadata, yet most Word files leave property fields blank. When exported to PDF, these become identified only by filename. Often something like “doc_final_v3_really_final.pdf” that makes sense only to the person who saved it.

How Customers with Disabilities Experience It: Screen readers announce only the filename. Users cannot distinguish between similar documents in portals or archives, creating navigation chaos and wasting time.

Customer portals become unusable for organising and accessing statements, contracts, or correspondence. During regulatory audits, organisations struggle to prove which documents were provided and when.

10. Wrong or Missing Document Language

European financial institutions serve multilingual markets, yet document language settings often remain on default English even when content contains Polish, French, or German text. Authors don’t mark foreign phrases or financial terms with correct language tags, assuming visual presentation suffices.

How Customers with Disabilities Experience It: Screen readers use incorrect pronunciation rules, making bilingual documents sound like gibberish. Polish financial terms pronounced with English phonetics become incomprehensible.

For multi-language markets common in European banking, this creates frequent hidden failures. It triggers complaints from language minorities and cross-border customers who cannot understand documents supposedly provided in their language.

Visual Design: When Appearance Excludes

11. Low Colour Contrast

Light grey text on white backgrounds. Text overlaid on decorative images. Font sizes shrinking to 9 or 10 points in legal sections and disclaimers. These design choices create documents that technically contain all required information whilst rendering it functionally invisible to significant customer populations.

How Customers with Disabilities Experience It: Low-vision users see faded shapes instead of readable text. On mobile screens or in bright sunlight, content becomes completely unreadable. People with cataracts or ageing vision struggle with insufficient contrast.

The “small print” becomes literally unreadable, creating extreme risk in contracts, fee schedules, and consent forms where regulators may interpret poor contrast as intentional obscuring of important information.

12. Colour as the Only Indicator

Red text signals overdue amounts. Green indicates approved status. Yellow highlighting marks mandatory fields. These colour-coded systems seem intuitive until you remember that approximately 8% of males and 0.5% of females experience colour blindness.

How Customers with Disabilities Experience It: Colour-blind users see similar shades and cannot distinguish between states. They miss critical warnings, payment statuses, or required actions.

Payment status indicators, approval workflows, and error messages become ambiguous, leading to financial mistakes, missed deadlines, and complaints that create both compliance and operational risk.

Word-to-PDF Export: Where Accessibility Dies

13. Wrong PDF Export Method

Here’s where many organisations trip at the finish line. They’ve invested time ensuring Word documents use proper heading styles, alt text, and semantic structure. Then someone exports the document using “Print to PDF” instead of “Save As → PDF” with accessibility options enabled, and every bit of that structure vanishes.

How Customers with Disabilities Experience It: Despite the source Word document having proper headings and structure, the PDF contains none of it. Screen readers announce: “This document has no headings, no structure.” Users experience long, undifferentiated text blocks.

This represents the most common trap banks and public bodies fall into when implementing EAA compliance. They believe they’re compliant because “we used Word styles correctly”, yet final PDFs sent to customers fail accessibility audits. The visual appearance remains identical, whilst the underlying accessibility completely disappears.

14. Critical Content in Headers/Footers

Account numbers in headers. Reference IDs in footers. Deadlines and contract numbers repeating across every page. This seems logical: important information visible throughout the document.

How Customers with Disabilities Experience It: Many screen readers skip headers and footers entirely or read them inconsistently. Critical information becomes invisible, even though it visually appears on every page.

Customers cannot find reference numbers needed to call support, account identifiers required for transactions, or deadlines for contract actions. This generates complaints and increases support centre volume.

15. Justified Text Alignment

Apply full justification (flush left and right margins) because it “looks professional and clean.”

How Customers with Disabilities Experience It: Justified text creates uneven spacing between words, making it difficult for people with dyslexia or cognitive disabilities to track lines. The irregular spacing disrupts reading rhythm and comprehension.

Long contracts, policies, and product documentation become harder to read for a significant portion of customers. This increases abandonment rates and reduces comprehension of important terms.

The Template Multiplication Effect

We are happy you went so far, and now you can see the broader perspective on how inaccessible documents and templates create back and forth both for operations and clients. Here’s why these document accessibility mistakes matter more than you think: when document accessibility mistakes exist in CCM templates (Quadient Inspire, OpenText Exstream, or similar platforms), they multiply across every generated document.

One inaccessible template generating 10,000 monthly bank statements = 10,000 compliance violations monthly, which can lead up to 120,000 violations annually.

At €1,000 per violation (conservative estimate based on Swiss and Norwegian precedents), that’s €120 million in potential exposure – from a single broken template.

Manual remediation at €15-30 per document would cost €1.8-3.6 million annually just to fix outputs from one template. Meanwhile, fixing the template once costs €5,000-15,000—a 99% cost reduction.

This is why template-based accessibility is the only sustainable approach for document-heavy organisations.

Tiding Up the Accessibility Before 2026 Audits Season Begin

Audit Your Word Templates: Start by auditing your Word templates rather than assuming documents are accessible because they “look fine visually.” Microsoft’s built-in Accessibility Checker catches only 30-40% of issues, so commission professional audits that include manual testing with actual screen readers and assistive technologies.
Fix Templates, Not Individual Documents: Focus more remediation efforts on templates rather than individual documents. Remediate PDFs and ready documents, which your organisation uses “forever”.
For CCM platforms, fixing accessibility at the source means one accessible template generates unlimited compliant outputs, eliminating recurring remediation costs that would otherwise compound monthly.
Train Content Creators: Business analysts, compliance officers, and document designers must understand accessibility requirements. Budget 40-60 hours per person for proper training on accessible document creation, understanding this as infrastructure investment rather than overhead.
Validate Export Processes: Validate your export processes to ensure Word-to-PDF conversion preserves accessibility tags and semantic structure. Test with actual assistive technologies like PAC 2024, screen readers, and keyboard navigation rather than relying solely on automated checkers that miss contextual problems.
Document Your Compliance: Document your compliance efforts meticulously. Maintain records of accessibility audits, remediation work, and testing results. Regulators increasingly demand proof of proactive compliance efforts, rather than reactive fixes implemented only after complaints arrive.

Ready to audit your document templates before regulators do? We’ve detailed the complete implementation process in our latest case study: EAA-Ready Document Communications for Banking, where a leading Polish bank implemented accessible templates at scale.

Contact us for a Word template accessibility audit or explore our comprehensive PDF accessibility services designed specifically for financial institutions facing EAA compliance deadlines.

Calculating the Accessibility Non-Compliance Costs: Real Cases & Financial Impact

Written by Kalynovska Kateryna on November 14, 2025. Posted in PDF accessibility.

“Accessibility penalties are not theoretical” – that what we hear from every newspoint from the Europen Accessibility Act inforcement. Though in truth, they never were. In the USA and some EU countries, accessibility violations have long been treated as discrimination issues with legal consequences. Yet many businesses dismissed them as rare enforcement actions that “wouldn’t happen to us.”

The European Accessibility Act has changed that calculation entirely.

We analysed not only the headline-grabbing EAA announcements but dug deeper, and discovered something striking: accessibility topic has evolved from quiet supervision to loud enforcement. The cases below aren’t distant warnings or isolated incidents. They’re recent, high-profile examples where inaccessible digital services triggered significant financial penalties, operational restrictions, and reputational damage. More importantly, they serve as early indicators of how enforcement under the EAA and related regulations will evolve across Europe.

As we approach 2026, digital-based industries like e-commerce and already heavily regulated services like online banking face unprecedented scrutiny. Learn those real-world cases that illustrate how inaccessible digital services lead to measurable consequences and serve as early indicators of how EAA enforcement will evolve across Europe.

Vueling – A Well-Known Spannish Lowcost Airlines (Spain, 2024)

Spain’s National High Court fined Vueling €90,000 and temporarily barred the airline from receiving public funds after its website was ruled inaccessible under national law. Vueling’s website failed to meet accessibility standards required under Spanish Royal Decree 1112/2018, which mandates WCAG 2.1 Level AA compliance for all public-facing digital services. The court found that customers with disabilities could not independently book flights, check in, or manage reservations — the core functions of an airline’s digital platform.

The Consequence: Beyond the direct fine, Vueling’s exclusion from public funding eligibility represented a significant operational restriction. For airlines dependent on government contracts, subsidies, or participation in public transport programmes, this penalty creates cascading financial impact far exceeding the initial €90,000.

What Does This Mean?

This was one of the first major private-sector enforcement cases directly linked to EAA implementation, setting a precedent that non-compliance results in both financial penalties and operational sanctions. Spanish regulators demonstrated willingness to use multiple enforcement mechanisms simultaneously — a strategy other EU member states are now replicating.

AccessiBe – Web Accessibility Company Powered With AI (USA, 2024)

The U.S. Federal Trade Commission fined AccessiBe $1 million for making deceptive claims about its AI-powered widget’s ability to make websites WCAG compliant. AccessiBe marketed its automated overlay tool as capable of achieving full WCAG compliance through AI-driven code injection. The FTC found these claims misleading — the widget could not deliver genuine accessibility and, in many cases, actually created new barriers for assistive technology users.

The Consequence: Beyond the $1 million penalty, AccessiBe must cease making unsubstantiated accessibility claims and notify customers that their widget does not guarantee compliance. The settlement sends a clear regulatory signal: automated shortcuts will not satisfy legal obligations.

What Does This Mean for EU Businesses?

Many European companies currently rely on similar overlay solutions, assuming they provide adequate EAA protection. This case signals rising regulatory scepticism towards automated fixes across jurisdictions. Genuine accessibility work includes manual audits, proper code remediation, template-level fixes. Theywill be required to meet compliance obligations. Overlays may supplement accessibility efforts but cannot replace them.

SAS: The “Impossible to Use” Website (Norway, 2017–2018)

Again we have case with customer-first communication channel, which does not meet the minimal accessibility. Norwegian regulator Difi threatened Scandinavian Airlines with daily fines of approximately €15,000 after its redesigned booking website failed 20 of 28 tested WCAG success criteria.

In 2017, SAS launched a redesigned website that immediately drew complaints from disability organisations. Norway’s Agency for Public Management and eGovernment (Difi) conducted an audit under the country’s Equality and Anti-Discrimination Act, which mandates WCAG 2.0 AA compliance.

The results were damning. Specific failures included:

No keyboard navigation support – interactive elements couldn’t be reached without a mouse (violating WCAG 2.1.1, 2.1.2)
Insufficient colour contrast for text (failing WCAG 1.4.3)
Missing alt text for images, icons, and even the SAS logo
Inaccessible CAPTCHA with no non-visual alternative
Unlabelled form fields and error messages relying solely on colour cues

Difi’s official verdict described the site as “impossible to use” for disabled customers — a quote that became infamous in Norwegian media.

The Enforcement Timeline

November 2017: Difi releases audit findings, gives SAS one year to remediate.
Mid-2018: Follow-up audit shows significant problems remain unresolved.
August 2018: Difi issues 10-day ultimatum with threat of NOK 150,000 (~€15,000) daily fines.
Final deadline: SAS resolves critical issues just in time to avoid penalties.

The Consequence: Whilst SAS ultimately avoided the daily fines by achieving compliance before the final deadline, the case generated extensive negative publicity. Headlines like “SAS website gets failing grade” and “SAS risks fines for new website” ran in major Norwegian newspapers. The threat of €15,000 daily accumulating fines forced immediate action and resource allocation.

What Does This Mean?

The SAS case demonstrates how daily penalty mechanisms work: an initial audit identifies violations, a compliance period allows remediation, then escalation to accumulating fines when progress stalls. Norway’s enforcement model shows that even large private companies face accountability for WCAG failures, and that daily fines create powerful incentives for rapid compliance.

By the way, SAS’s competitor, Norwegian Air, had invested in accessibility proactively and passed its Difi inspection with only minor comments — a fact widely noted during the controversy, demonstrating competitive advantage for early adopters.

Union Bank of Switzerland

UBS faced a 20,000 CHF fine plus mandatory remediation after its online banking platform was found to exclude visually impaired customers from basic operations like account login and transactions.

UBS’s digital banking interface was not screen reader-friendly or keyboard-navigable, effectively denying blind users independent access to their accounts. This violated Switzerland’s accessibility standards (based on WCAG 2.0/2.1 Level AA) and constituted discrimination under Swiss disability law.

Specific issues included:

Missing screen reader labels and alt text (violating WCAG 1.1.1)
Inadequate keyboard navigation (violating WCAG 2.1.1, 2.4.7)
Critical interactive elements rendered inaccessible to assistive technology users

Swiss authorities ordered:

Immediate payment of 20,000 CHF fine
Mandatory accessibility improvements within 6 months
Compensation for affected customers who had been unable to use online services
Accessibility training for staff to prevent recurrence

What Does This Mean?

The UBS case demonstrates that financial services face particularly strict scrutiny. Banking accessibility isn’t just about compliance. But it’s about fundamental access to financial services, which courts and regulators treat as essential infrastructure.

Notably, Swiss law allows individual discrimination claims with awards up to CHF 5,000 per person. For banks with thousands of affected customers, the potential liability extends far beyond the initial fine. The requirement to compensate affected users sets a precedent that inaccessibility creates measurable financial harm requiring restitution.

Common Patterns Across Enforcement Cases

These cases reveal consistent enforcement approaches emerging across jurisdictions:

1. Multiple Penalty Mechanisms: Financial fines (fixed or daily accumulating), operational restrictions (funding eligibility), mandatory remediation timelines, customer compensation requirements, and staff training obligations.

2. Focus on Core Functionality: Regulators prioritise accessibility failures that prevent users from completing essential tasks—booking flights, accessing bank accounts, completing purchases. Cosmetic or minor issues receive less scrutiny than barriers to critical services.

3. No Safe Harbours for Large Companies: Major airlines and multinational banks face the same enforcement as smaller entities. Brand recognition and market position provide no protection from accessibility requirements.

4. Automated Solutions Face Scepticism: The AccessiBe ruling signals that overlay widgets and AI-driven “quick fixes” will not satisfy regulators. Genuine code-level accessibility and manual validation are increasingly required.

5. Daily Fines Create Urgency: The SAS case demonstrates how daily accumulating penalties (€15,000/day = €450,000/month) force immediate resource allocation and executive attention in ways fixed fines may not.

Visual diagram titled ‘Steps to Accessibility Enforcements’ showing an upward arrow with four ascending steps. From bottom to top: Customer Complaints as Triggers (customers or advocacy groups file complaints), Formal Investigations (regulators launch investigations based on complaints), Systematic Audits (regulators conduct proactive accessibility audits), and Escalating Penalties (failure to fix issues leads to larger fines and restrictions). Icons accompany each stage, illustrating complaints, investigations, audits, and penalties.

Calculate Your Exposure

Ask yourself:

How many customer-facing channels your organisation operate?
What percentage meet PDF/UA and WCAG 2.1 AA standards?
If each inaccessible online communication a potential violation, what’s your total exposure?

For example, for a bank generating 50,000 monthly PDF statements:

If 0% are accessible and individual fines reach €1,000 per violation (conservative estimate)
Potential exposure: €50 million monthly

Even if only 1% of customers file complaints, that’s €500,000 in immediate risk—before considering reputational damage, operational restrictions, or daily accumulating penalties for non-remediation.

The organisations thriving post-EAA aren’t debating whether accessibility matters. They fixed their digital communication channels before enforcement arrived.

A digital banner titled “Field Notes on Inclusion” by Quertum introduces a section on real-world accessibility projects. The main headline reads “EAA Compliance Examples: European Banks Accessibility Cases.” The background features a dark navy design with stylized purple file icons connected by white circuit-like lines, symbolizing digital communication and compliance systems.

EAA Compliance Examples: European Banks Accessibility Cases

Written by Kalynovska Kateryna on November 6, 2025. Posted in PDF accessibility.

Living in the business world, we are getting used to seeing the opportunities, when most people have no attention to. This is a great ability, which helps not only earn but also make our life better.

In the World Health Organization (WHO) European Region, an estimated 90 million people have vision impairment or blindness and 190 million have hearing loss or deafness.
We collected some great examples of companies, which managed to treat Accessibility as an opportunity and got not only better ROI, but earned trust.

Now people with impairments can use the service of the next companies and live their best life. They can buy a ticket, hear the banking statement and monitor the usage clearly with utility service bills.

Points of Development for Banking Leaders: Observing the Demand to Fill It In

Despite growing regulation and awareness, the majority of digital services and documents remain inaccessible to people with disabilities. The WebAIM Million study (2025) found that 95% of the world’s top websites contained detectable WCAG 2 failures, highlighting how pervasive accessibility gaps remain – even among large and regulated companies that are expected to lead by example.

The issue extends beyond websites. In academia, where digital publications should be a cornerstone of inclusive knowledge sharing, the situation is equally problematic. Kumar and Wang (2024) examined scholarly PDFs published between 2014 and 2023 and found that fewer than 3.2% met basic accessibility standards such as tagging, alternative text, language metadata, and structured tables. This neglect reflects a broader trend across industries: documents, though widely used for contracts, policies, billing, and customer communications, are rarely designed with accessibility in mind.

Even with accessible websites, PDFs remain a weak link in the compliance chain. However, the reality is that many companies still struggle with both – non-compliant websites and inaccessible documents often coexist, and either can trigger enforcement. Most companies don’t realise how many critical documents (onboarding, billing, contracts) fall outside centralised systems and therefore skip routine audits.

The institutions below recognized this reality and took action. Their implementations offer practical roadmaps for organizations still planning their compliance strategies.

Case #1: Eurobank (Greece) – Comprehensive EAA Alignment

Not every bank has created a document that officially recognises their accessibility gaps and development plans. Eurobank deserves recognition for this transparency—they’ve formally aligned their accessibility strategy with the European Accessibility Act through Greek Law 4994/2022, publishing a comprehensive public statement that most competitors avoid.

What They’re Doing

In their 2025 accessibility statement, Eurobank commits to making all services and channels, including digital content like “files in PDF format”, accessible and comply with EN 301 549:2021 and WCAG 2.1 AA standards. This means customer-facing PDFs (forms, statements, brochures, account documents) are being updated to meet technical accessibility requirements.

Eurobank emphasizes that accessibility is both a legal obligation and “a fundamental expression of respect, inclusion, and customer-centred service.” The bank’s digital channels are currently partially compliant and undergoing continuous improvements toward full accessibility.

Strategic Approach

Rather than treating accessibility as a one-time project, Eurobank frames it as core to their customer experience strategy. This positioning signals to customers, regulators, investors that accessibility improvements are sustainable, not superficial.

Case #2: Bank of England (UK) – Public Sector Leadership

As a public-sector entity, the Bank of England follows UK accessibility regulations, requiring all new content meet WCAG standards.

What They’re doing

The Bank’s accessibility statement notes they “strive to make any new PDFs and Word documents we publish meet accessibility standards.” In practice, newly published reports, consultation papers, and policy documents are designed for assistive technology compatibility, tagged PDFs with alternative text, proper reading order, and semantic structure.

Legacy documents (pre-2018) may not all be remediated, but accessible versions are provided upon request. This pragmatic approach acknowledges resource constraints while ensuring ongoing compliance for new publications.

Strategic Approach

The Bank of England adopted an “accessibility by default” policy for new documents rather than attempting to retroactively fix decades of archives. This forward-looking strategy prevents accumulation of new accessibility debt while managing legacy content requests case-by-case.

Case #3: Honda Bank GmbH (Germany) – Forward-Looking Compliance

Honda’s finance arm in Germany issued an accessibility (Barrierefreiheit) statement aligned with the EAA under German law (Barrierefreiheitsstärkungsgesetz – BFSG).

What They’re Doing

Honda Bank acknowledges that some PDFs on its website currently lack accessibility features (missing tags, insufficient alt-text). However, the bank “plans to design future PDF documents to be barrier-free, in order to meet the required standards.”

All newly generated PDFs for customers—product information, account documents, contract terms—will be created to PDF/UA and WCAG specifications before the June 2025 enforcement deadline.

Strategic Approach

Honda Bank’s transparency about current gaps paired with concrete remediation timelines demonstrates regulatory compliance without overpromising. By focusing on template-level changes for future document generation, they can build scalable accessibility into their customer communication workflows rather than pursuing expensive per-document fixes.

For the financial industry, these cases signal a clear shift from one-off document fixes to systematic, scalable accessibility management. This transparency shows that real compliance depends on embedding accessibility into every customer communication template, not just polishing a few visible reports.

Opportunities in Numbers

These implementations aren’t just regulatory responses, they unlock measurable business opportunities. Approximately 24% of the EU population lives with some form of disability. By providing accessible PDFs and digital services, banks can serve this demographic that competitors are neglecting. For context, UK households with disabled members control £274 billion in annual spending power. Banks and building societies lose an estimated £935 million monthly by maintaining accessibility barriers that drive these customers away.

Where to Start Your PDF Accessibility Implementation Journey

The institutions above share common implementation patterns your compliance team can replicate:

1. Conduct Honest Accessibility Audits: Don’t assume website compliance means document compliance. Most organisations have accessible web properties but inaccessible PDFs in contracts, onboarding, billing, and customer communications outside centralised systems.

2. Prioritise Template-Level Fixes: Following Honda Bank and Bank of England’s model, focus on making new document templates accessible rather than remediating entire archives. One compliant CCM template generates thousands of accessible outputs—precisely what banks and enterprises need at scale.

3. Document Your Progress Publicly: Like Eurobank, publish accessibility statements with specific standards and timelines. Transparency builds trust with customers and demonstrates good faith to regulators.

Here we broke in our article PDF Accessibility and EAA: Guide for Compliance, where you can find you need to know where you start to document accessibility strategy and how to lead this process painlessly.

Ready to start your accessibility journey? Learn more about PDF accessibility requirements or request a free PDF audit to identify gaps in your customer communications before regulators do.

Bonus Case: Easy Jet and Accessible Application

EasyJet, British multinational low-cost airline and package holiday group, builds reliable customer experience while taking maximum from the market. In this short case, we welcome you to immerse yourself in the world of people with visual impairments and discover the principles of accessible customer experience in less than 5 minutes.

Our simple question: Have you ever tried to book a flight with closed eyes?

This sounds like a real challenge, but anyway EasyJet gets things solid, and lets people actually book the flight just with the voiceover. In this short video, you can try these shoes and understand the approach of accessibility better.

Comparing the service of Ryanair, Jet2 and Tui, Adi Latif, the well-known accessibility consultant, is booking a flight to Alicante, Spain. With no loud market data or buzzwords, but with real usage he showcased the ease of use of the EasyJet application for people with visual impairments.

This real-world example gave approximately 340,000 people with vision impairments a comfortable way to travel, whilst opening the door to market dominance among people with impairments. EasyJet proves that accessible customer experiences aren’t just compliant —they’re competitive advantages.

Visual comparison showing four major PDF accessibility checker logos — PAC, Adobe Acrobat, PDFix, and CommonLook PDF Validator — beside a computer monitor displaying the text “PDF Accessible” with an accessibility icon, symbolizing the evaluation of tools for ensuring accessible PDF documents.

Top PDF Accessibility Tools in 2025: Comparative Review for Those Starting Their Accessibility Journey

Written by Kalynovska Kateryna on October 30, 2025. Posted in PDF accessibility.

Checking PDFs for accessibility may sound straightforward, until you realise this: automated tools only catch 30-40% of real accessibility barriers. The European Accessibility Act has made PDF compliance mandatory across banking, insurance, utilities, and public sectors. Yet most compliance teams still rely solely on automated checkers to shape their EAA compliance strategy, missing critical issues that only manual testing reveals. And the the loop is clear: the more company relys on automated checkers, the more it puts financials at risk. Read our article about fines and penalties here.

This guide offers practical techniques for evaluating PDF accessibility tools and services in 2025. We’ll compare the most popular free and paid validators: PAC 2024, Adobe Acrobat Pro DC, PDFix Desktop Lite, and CommonLook PDF Validator. We’ll explain why even the best automation must be paired with manual accessibility audits by people who understand how assistive technologies actually work.

If you’re starting your accessibility journey post-EAA, this is your roadmap to choosing the right pathways without wasting budget on features you don’t need.

Visual diagram titled 'EAA-Ready PDF Accessibility Workflow' showing a linear four-step process. Step 1: ‘PDF Checker’ – automated tool validation. Step 2: ‘Manual Audit’ – human review for accessibility compliance. Step 3: ‘Template Fix’ – correction of document templates. Step 4: ‘Regulatory Approval’ – final compliance confirmation. All steps are displayed in connected purple boxes with arrows on a dark blue gradient background.

Understanding What PDF Accessibility Tools Actually Check

Before comparing specific tools, understand what automated checkers can and cannot do.

What automated tools check well:

PDF/UA conformance (tagged structure, reading order)
WCAG 2.1 AA technical checkpoints (color contrast ratios, language attributes)
Missing alt text or table headers
Document metadata and title display
Font embedding and Unicode mapping

But what automated tools miss:

Whether alt text is meaningful (tools can’t tell if “image1.png” describes the content)
Logical reading order across complex layouts
Table structure usability for screen reader users
Form field instructions clarity
Real-world navigation with keyboard or assistive tech

This gap is why EN 301 549 and national EAA implementations require both automated and manual testing. Tools provide technical compliance baselines. But humans verify usability.

PAC 2024 Accessibility Checker: The Free Industry Standard

PAC (PDF Accessibility Checker) 2024 is the first worldwide ISO 14289-1 (PDF/UA) validator and remains the go-to free tool for PDF accessibility testing. Developed by axes4 company, it’s trusted by European accessibility professionals.

Key Features:

WCAG 2.1 checks with all machine-testable checkpoints
Quality Checks feature to simplify visual inspection during manual assessments
Screen reader preview showing logical document structure
Detailed error reports highlighting specific PDF/UA violations
Completely free with no feature restrictions

Strengths	Limitations
Precise document language checking adhering strictly to PDF/UA and WCAG specifications	Windows-only (Mac users need axesCheck online alternative)
User interface remains consistent across all screen resolutions	Manual visual review still necessary because PAC primarily focuses on technical elements
Soft hyphen highlighting in screen reader preview for better differentiation	No remediation features—purely a validation tool
Generates comprehensive PDF reports documenting compliance status	Learning curve for interpreting technical error messages

Best For: European organisations needing free PDF/UA validation for EAA compliance; teams with technical accessibility knowledge; audit documentation preparation.

Real-World Use Case: A Nordic insurance company used PAC 2024 to validate 12,000 policy documents before the EAA deadline. The tool identified 78% structural compliance but flagged 4,200 documents requiring manual alt text review—work PAC couldn’t assess automatically.

Adobe Acrobat Pro DC: The All-in-One Automated Remediation Solution

Adobe Acrobat Pro DC includes built-in accessibility checking, tagging, and remediation tools. It’s the most comprehensive single-tool solution but comes with complexity and cost.

Key Features:

Strengths	Limitations
Industry standard—most accessibility professionals know it	Checks many characteristics but doesn’t match PAC’s PDF/UA certification rigor
Combines checking and fixing in one environment	Expensive licensing (€180–240/year per user)
Handles complex table remediation	Steep learning curve for accessibility features
Integration with Adobe Creative Suite	Tag editing can be tedious for large documents
–	Automated tagging often creates more problems than it solves

Best For: Organisations with dedicated accessibility teams; high-volume remediation needs; complex document workflows requiring both creation and validation.

Important Note: Adobe’s checker is excellent for identifying issues, but experienced teams often use PAC 2024 as final validation because it’s specifically designed for PDF/UA conformance certification.

PDFix Desktop Lite: Lightweight Free Alternative

PDFix Desktop Lite offers basic accessibility checking and repair capabilities in a simpler interface than Acrobat. It’s designed for occasional users who need quick assessments without professional remediation features.

Key Features:

Automated tagging for simple documents
Basic accessibility checks
Reading order verification
Free for non-commercial use
Cross-platform (Windows, Mac, Linux)

Strengths	Limitations
Simpler interface than Acrobat	Less comprehensive than PAC or Acrobat checkers
Free tier available	Automated tagging quality varies significantly
Automatic tagging works well for straightforward documents	Limited manual remediation tools
Good for quick preliminary checks	Lacks detailed PDF/UA compliance reporting

Best For: Small teams testing occasional PDFs; preliminary document screening before professional remediation; educational purposes.

CommonLook PDF Validator: Enterprise-Grade Free Validation

CommonLook PDF Validator works as an Adobe Acrobat Pro plugin, identifying and highlighting accessibility concerns within PDF documents. Now part of Allyant, it’s widely used in US federal agencies and large enterprises.

Key Features:

Tests against Section 508, WCAG 2.0 AA, PDF/UA, and HHS guidelines
Guides users through manual tests necessary for complete accessibility compliance
Tag-based content highlighting—select content in PDF and immediately see corresponding tags
Provides certification report documenting compliance for each tested document

Strengths	Limitations
Divides checks into structure (ISO 32000) and accessibility conformance categories	Requires Adobe Acrobat Pro DC (adds to total cost)
More comprehensive standard coverage than PAC’s PDF/UA focus	Interface differences from PAC may require learning adjustment
Table summaries accuracy validation improves comprehension of tabular data	US-centric standard focus (though PDF/UA applies globally)
Accepted by regulatory agencies for compliance documentation	–

Best For: Organisations serving US and EU markets; federal contractors; enterprises needing multi-standard certification reports; teams already using Acrobat Pro.

Quick Sheet for PDF Accessibility Chekers

Tool	Cost	PDF/UA Check	WCAG Check	Remediation	Best For
PAC 2024	Free	Certified – provides highly accurate validation aligned with PDF/UA and WCAG 2.1 standards, widely accepted across the EU.	Level AA – verifies accessibility according to WCAG 2.1 AA, ideal for compliance audits.	No correction or editing options; used purely for validation and reporting.	EU compliance validation, auditors, and accessibility specialists needing a certified, trusted tool.
Acrobat Pro DC	€180–240/year per user	Good – performs detailed PDF/UA checks, including tagging and structure validation.	Broad WCAG coverage integrated with accessibility features and reports.	Full remediation workflow – allows manual and semi-automated fixes directly within documents.	Organizations seeking an all-in-one tool for creating, editing, and remediating accessible PDFs.
PDFix Lite	Free (limited version)	Basic – performs basic structure and tag checks for small or simple documents.	Basic – supports quick accessibility validation but lacks deep analysis.	Simple – includes limited remediation features like auto-tagging and metadata editing.	Occasional checking or small teams that need a quick, lightweight accessibility validator.
CommonLook Validator	Free (requires Adobe Acrobat)	Multi-standard – supports PDF/UA, WCAG, Section 508 (US Accessibility Standard), and HHS standards.	Extensive cross-standard compliance validation with detailed reports.	Validation only; remediation requires other CommonLook products.	Enterprise-level – large organisations, and government audits.

Why Automated Chekers Alone Fail EAA Compliance?

Here’s the uncomfortable truth: checkers and automated remediators primarily focuse on technical elements of accessibility, so manual review is still necessary, other wise the document can make no sence to a real person. Every major accessibility standard, like WCAG, PDF/UA, EN 301 549, requires human evaluation. It requires manual check because of:

Automated Tools Can’t Judge Context

A checker sees <Figure alt="graph"> and marks it compliant. A screen reader user hears “graph” with no data context. It is completely useless for person with impairment. A human auditor would flag this as non-compliant despite passing automated checks.

Reading Order Logic Requires Human Understanding

Tools verify that content has a reading order. They can’t assess whether the order makes sense. Multi-column layouts, sidebars, and callout boxes often pass technical checks while creating incomprehensible experiences for assistive tech users.

Form Usability Is Invisible to Automation

Validators check if form fields have labels. They don’t assess whether instructions are clear, whether error messages are helpful, or whether tab order follows logical completion flow.

Real-World Example: A Swedish bank we audited had 100+ PDF templates passing PAC 2024 checks at 98% compliance. Manual testing by accessibility specialists revealed:

40% of alt text was generic (“chart,” “logo”) without meaningful descriptions
29% of tables had correct tags but illogical header associations
16% of forms lacked keyboard navigation hints despite having technical labels

Fixing these issues at the template level eliminated manual remediation costs and ensured genuine accessibility, not just checkbox compliance.

How Quertum Combines Tools with Human Expertise

We use automated validators as the first screening layer, not the final answer. Our process includes automated scanning, manual accessibility audits with actual screen readers (NVDA, JAWS) and keyboard navigation, plus contextual review of whether alt text and form instructions actually communicate meaning—not just whether they exist.

However, for banks, insurers, and enterprises generating thousands of documents monthly, individual file remediation quickly becomes unsustainable. That’s why template-based accessibility implementation is the only approach that makes sense at scale.

The Template-First Strategy:

Instead of fixing 50,000 customer statements one by one, we remediate your CCM templates once. For Quadient Inspire, OpenText Exstream, Smart Communications or other enterprise systems, this means:

One compliant template = unlimited accessible outputs – Every bank statement, insurance policy, or invoice generated from that template automatically meets PDF/UA and EN 301 549 requirements
Future-proofing – New regulations or standard updates require template adjustments, not archive-wide remediation
Operational continuity – No disruption to document generation workflows; accessibility becomes built-in, not bolted-on

This template-centric approach is precisely what European banks and large enterprises need: scalable compliance that doesn’t require armies of remediators or disrupt customer communications.

Final Takeaway: Tools Are Your Starting Point, Not Your Finish Line

PAC 2024, Acrobat Pro, and CommonLook Validator are excellent tools when used correctly. They identify technical violations efficiently, but they’re screening tools, not compliance guarantees.

The European Accessibility Act doesn’t ask, “Did your PDF pass an automated checker?” It asks, “Can people with disabilities actually use your documents?” That second question requires human testers who understand assistive technology, not just software that counts tags.

Organisations that thrive in the post-EAA era understood this early. Read our case study on how a leading Finnish bank met the EAA deadline and future-proofed its reputation. By combining automated tools for technical checks with expert manual audits, they ensured real usability and lasting compliance.

Ready to move beyond checkbox compliance? Contact Quertum for a comprehensive accessibility audit combining automated validation with expert manual testing or explore our PDF accessibility services designed specifically for EAA requirements.

Graphic with the title "WCAG, PDF/UA, and EN 301 549 Standards – What Do They Stand For?". It shows three visual elements: On the left, a PDF icon labeled PDF/A/UA with a green checkmark. At the top, a W3C WAI-AA WCAG 2.1 label. On the right, a blue rectangle with yellow text EN 301 549. In the center, a large universal accessibility symbol (a person with outstretched arms in a blue circle) represents digital accessibility. The background has a dark gradient from black to blue and purple.

WCAG vs PDF/UA vs EN 301 549: What Each Accessibility Standard Means for Your Business Communication

Written by Kalynovska Kateryna on October 20, 2025. Posted in PDF accessibility.

Three acronyms dominate accessibility compliance conversations in 2025: meet WCAG, PDF/UA, and EN 301 549 standards. Yet most compliance managers struggle to explain which standard applies to their business communications and what is the strategy for its implementation to be compliant. With the European Accessibility Act enforcement deadline behind us and audits ramping up, confusion isn’t just inconvenient but it’s highly expensive.
Learn more about penalties which apply with EAA noncompliance.

This article breaks down what each standard actually does, where they overlap, and how to apply them to your business communications and operations without drowning in technical jargon.

What is WCAG and Why It Became the Digital Accessibility Baseline?

WCAG (Web Content Accessibility Guidelines) is the The World Wide Web Consortium (W3C) framework for making digital content perceivable, operable, understandable, and robust. There are several versions of it, but to stay compliant with EAA the business should apply Version 2.1 Level AA as minimum. This Version is the de facto global benchmark for web accessibility and the foundation for most national laws, including the EAA.

WCAG applies primarily to websites, web applications and digital outcomes (documents, presentations, spreadsheets), but its principles influence everything digital. The standard defines success criteria across four principles: perceivable information, operable interfaces, understandable content, and robust technology compatibility.

What WCAG 2.1 Accessibility Standard Stands for?

WCAG focuses on user experience. Ensuring that people using screen readers, keyboard navigation, or magnification tools can access content without barriers.

For business communication, WCAG compliance means:

Proper heading structures for navigation
Sufficient color contrast (4.5:1 for normal text)
Alt text for images
Keyboard-accessible forms
Consistent, predictable layouts

Where WCAG Falls Short: While WCAG defines what accessibility looks like, it doesn’t dictate how to implement it for specific formats like PDFs. That’s where PDF/UA enters the picture and makes things right not only theoretically but practically.

PDF/UA: The Technical Rulebook for Accessible PDF Documents

PDF/UA (PDF Universal Accessibility, ISO 14289) is the only ISO standard dedicated exclusively to PDF accessibility. Think of it as WCAG’s technical translator for PDF files.

Where WCAG says “provide text alternatives,” PDF/UA specifies how: through tagged PDF structures, alt text embedded in specific dictionary entries, and defined reading order using structure trees.

Why Does the PDF/UA Accessibility Standard Matter for Business Communication?

Most banks, insurers, and utilities send thousands of PDFs monthly: contracts, statements, invoices, policy documents. If these aren’t PDF/UA compliant, they’re inaccessible to screen reader users, violating EAA requirements.

PDF/UA compliance requires:

Semantic tagging (headings, lists, tables)
Logical reading order for assistive technology
Embedded fonts and Unicode mapping
Tab order definition
Alternative descriptions for non-text elements

Real-World Impact: A leading Finnish bank we audited had over 100 PDF templates in its CCM system, including bank statements, insurance contracts, and balance sheets. The system was generating thousands of documents daily, none of which were tagged. Manually remediating each file would have cost around €15–30. By implementing automated template fixes and full accessibility compliance, the bank not only eliminated manual remediation costs but also safeguarded itself against future audits.

Critical Distinction: WCAG checks if content is accessible. PDF/UA defines how to make PDFs structurally accessible at the file level.

EN 301 549: The Legal Compliance Umbrella for EU Markets

EN 301 549 is the European harmonised standard referenced in the EAA. It’s not a separate framework, but a comprehensive specification that incorporates WCAG 2.1 Level AA for web content and adds requirements for hardware, software, documentation, digital outcomes, and support services.

Think of EN 301 549 as the enforcement mechanism: it’s the standard EU member states cite in national laws and the benchmark for conformity assessments.

What EN 301 549 Accessibility Standard Covers Beyond WCAG?

This standard covers:

ICT products (hardware interfaces, kiosks)
Software applications (desktop and mobile)
Documentation and support services
Authoring tools (like your CCM templates)
Real-time text communication

For business communication, EN 301 549 compliance means your entire documentation workflow must be accessible. It means not just the final PDF, but also the authoring tools, templates, and customer support channels.

Why This Matters for CCM Users: If your Quadient Inspire or OpenText Exstream templates aren’t designed with accessibility in mind, you’re producing non-compliant outputs at scale. Therefore fixing 50,000 documents after the fact is prohibitively expensive compared to fixing the template once.

The standards decoded for communication

Standard	Communication channels	What it means for business	Why to invest in compliance?
WCAG 2.1/2.2	Websites, mobile apps, HTML emails, online forms	To make digital content usable for everyone it provides principles: perceivable, operable, understandable, robust. Applies to navigation, colour contrast, alt text and keyboard support across digital communications.	Widely adopted benchmark; referenced in many laws and lawsuits. Meeting WCAG ensures your web‑based communications are inclusive and reduces legal risk.
PDF/UA (ISO 14289)	Invoices, statements, proposals, brochures, reports	Defines how to structure PDFs so that assistive technologies can read them: tagged headings, logical reading order, alt text, searchable text and keyboard accessibility.	Required to meet EAA obligations(and Section 508 in US); Ensures that PDF documents used for billing or marketing are as accessible as your website.
EN 301 549	All ICT including websites, PDFs, software, hardware	Harmonised EU standard built on WCAG that adds documentation and testing requirements. Compliance provides a presumption of conformity under the European Accessibility Act (EAA).	Proves your products, documents, and systems meet legal accessibility requirements under the European Accessibility Act — helping you avoid fines, win contracts, and serve all users effectively.
BONUS: PDF/A (A‑1a/A‑2a)	Archived documents	Specifies technical requirements for long‑term preservation. Important for records management but does not guarantee accessibility.	Use PDF/A for compliance with archiving rules, but add PDF/UA tagging when documents will be read by customers.

How These Standards Overlap and Where They Diverge

Here’s the simplified relationship:

WCAG 2.1 AA = Accessibility principles (what accessibility looks like)
PDF/UA = PDF implementation spec (how to make PDFs accessible)
EN 301 549 = Legal compliance standard (what the EAA requires)

Consequently, EN 301 549 incorporates WCAG 2.1 AA verbatim for web content. PDF/UA aligns with WCAG principles but adds PDF-specific technical requirements.

Divergence Points:

WCAG doesn’t specify PDF structure; PDF/UA does
PDF/UA doesn’t cover websites; WCAG does
EN 301 549 adds hardware, software, and documentation requirements neither WCAG nor PDF/UA address

Venn diagram titled "How Accessibility Standards Interconnect". Three overlapping circles represent:

WCAG 2.1 AA – defines what accessibility looks like.

PDF/UA (ISO 14289) – defines how to make PDFs accessible.

EN 301 549 – makes both legally enforceable in the EU.
Their intersection in the center is labeled EAA, showing that the European Accessibility Act connects and enforces all three standards together.

If your business operates in the EU, and produces digital documents, you need all three perspectives which allow you to shape your compliance strategy and stay ahead of the curve. EN 301 549 sets the legal bar. WCAG defines the user experience standard. PDF/UA provides the technical roadmap for document compliance.

Which Standard Should Business Prioritise for Communications Accessibility?

Most compliance teams waste time auditing the same documents against three different checklists — only to discover conflicting results and unclear priorities. The smart approach is simpler: match the standard to your content type, then build from there.

So the answer depends on your content type:

For websites and web apps: WCAG 2.1 Level AA
For PDFs (statements, contracts, forms): PDF/UA (ISO 14289-1)
For EAA legal compliance: EN 301 549 (which references both)

Our team recommends not auditing against three separate checklists. EN 301 549 can be used as your primary framework as it already incorporates WCAG and aligns with PDF/UA. Then apply PDF/UA validation to ensure your documents pass technical checks. Contact us for a free communication accessibility audit.

If you’re using Quadient, OpenText, or another CCM platform, fix accessibility at the template level. One compliant template generates thousands of compliant outputs. One broken template creates thousands of liabilities.

How Quertum Helps Businesses Navigate Multi-Standard Compliance

We work with European banks, insurers, and public sector organisations to ensure their business communication meets WCAG, PDF/UA, and EN 301 549 requirements — without disrupting operations.

Our Approach is designed to meet not the green checkmarks, but reshape the whole communicational landscape and make it truly accessible and future-proofing:

Template Audits: We analyse your CCM templates (Quadient, OpenText) for accessibility gaps
Bulk Document Remediation: Automated tagging + manual QA for existing PDF archives
Compliance Documentation: Detailed technical files proving conformity for regulatory reviews

Final Takeaway: Standards Aren’t Optional Anymore

WCAG defines accessibility principles. PDF/UA specifies how to implement them in PDFs. EN 301 549 makes both legally enforceable across the EU.

Your compliance team doesn’t need to become ISO experts. You need a clear implementation plan, accessible templates, and documentation proving conformity. The businesses thriving post-EAA aren’t the ones debating standards—they’re the ones who fixed their templates six months ago.Ready to audit your PDF templates and ensure EAA compliance? Contact Quertum’s accessibility specialists for a no-obligation assessment.

EAA and Accessible Documents: What Business Must Know About

Written by Kalynovska Kateryna on September 12, 2025. Posted in PDF accessibility.

Accessible documents have become a hidden challenge under the European Accessibility Act (EAA) and its implementation. Many organisations are still trying to understand what the EAA means for their processes and management. In this article, we explore the areas most often overlooked by Operational and Product Managers — document libraries, templates, and customer communications. In short, we focus on PDFs, Word documents, spreadsheets, and presentations published on websites, embedded in apps, or made available online — the everyday materials every organisation relies on.

For banking, financial structures, insurance, utility firms or public sector companies the EU Accessibility Act isn’t just another compliance hurdle to jump over. The EAA represents a fundamental shift in how we think about digital communications and user access. Understanding these changes now will save you significant headaches (and budget) down the road.

Read our full guide and discover:

How business communications became the new frontier of the European Accessibility Act;
What EAA rules apply to documents and communications in Germany, France, Poland, the Netherlands, and the Nordics;
How to protect your budget by remediating document templates instead of fixing files one-by-one;
Practical steps to future-proof your Document Management Systems (DMS/CCM) for accessibility;
Why accessibility isn’t just compliance — but also efficiency, market reach, and brand strength.

Clearing Up the European Accessibility Act for PDFs and Documents

The most common question we hear is: “Does the EAA actually cover documents, or just websites and apps?” Documents are absolutely must comply with European Accessibility Act, especially when they’re part of digital services and offer a constant communication bridge between business and the client. Perfect example is a bank – PDF statement – client.

The EAA aligns with POUR accessibility guidelines to ensure digital content is Perceivable, Operable, Understandable, and Robust. Organisations must follow standards like WCAG 2.1 AA for web/mobile content and PDF/UA (PDF/Universal Accessibility) for electronic documents and PDFs to fully comply with EU Accessibility Act. WCAG (Web Content Accessibility Guidelines) covers websites, HTML emails, and other web content, while PDF/UA is the ISO standard for making PDF documents readable via assistive technology.

Key Requirements for Accessible Documents and PDFs

Alternative text for images (so screen readers can describe images)
Correct document subject, author, keywords for search and indexing.
A logical reading order and navigability (using headings, bookmarks, and links for easy navigation)
Sufficient color contrast, minimum 4.5:1 contrast ratio for normal text.
Proper labeling of form fields for keyboard use, and general compatibility with assistive tech like screen readers and adaptive keyboards.
And many more.

We’ve turned the core accessibility rules into a clear 1-page infographic, which you can share with your team and use to start you accessible business communication journey. Download the PDF Accessibility Infographic here:

Get the Infographic

In short, digital documents must be properly structured for screen reader compatibility and clear navigation to be accessible for people with impairments.

Think about your customer journey as an EAA auditor: loan applications, insurance policies, investment statements, regulatory disclosures. These aren’t just accessible documents, but the integral parts of your digital service delivery.

When a customer downloads their policy document from your portal, that PDF needs to meet the same accessibility standards as your website, to make the whole communication “omniaccessible”. This creates a ripple effect throughout your organisation. Your Document Management Systems, client portals, and digital workflows all need to ensure accessibility compliance.

“When we talk about accessibility, we’re not just talking about websites. Every document our customers download — whether it’s a loan offer, an insurance policy, or an investment report — is part of their digital experience with us. If it’s not accessible, we’re not truly inclusive.”

– Says Maciej Majewski, a CEO at Quertum

Accessible Documents and Business Communications in Germany, France, Poland, the Netherlands and Nordics Region

Here’s where things get interesting and slightly complicated. The EAA is a directive, which means each EU country implements it through their own national legislation. This creates variations that matter for your compliance strategy – both for documents, applications, website and offline accessibility.

The EAA’s enforcement framework mirrors the EU’s existing product safety regime, but with adaptations for services. There is no centralised EU “accessibility police”; instead, each Member State has designated one or more national authorities to monitor and enforce compliance within their jurisdiction.

Click on your country to learn more about local EAA regulations, and how to adapt your communications for operating on the region.

Germany: German implementation puts significant focus on financial services accessibility. BaFin has been particularly clear about expectations for customer-facing documents. If you’re serving German customers, your loan agreements and insurance policies are under enhanced scrutiny.

EAA in Germany

France: French regulations emphasise public service accessibility, with strict requirements for any documents that interface with government processes. Private companies with public contracts face additional oversight.

EAA in France

Poland: Polish implementation includes specific provisions for fintech and digital financial services, reflecting the country’s growing role as a regional fintech hub. KNF (the Polish Financial Supervision Authority) and government accessibility offices are expected to audit customer-facing statements, onboarding documents, and regulatory disclosures.

EAA in Poland

The Netherlands: Dutch enforcement builds on the existing WCAG-based accessibility law that already applies to public sector websites and documents. The focus is on harmonisation — ensuring that both government and private contractors deliver accessible PDFs, invoices, and digital communications. Enterprises bidding for public contracts must demonstrate full compliance in their document workflows.

EAA in The Netherlands

Nordics Region: Sweden, Denmark, Finland, and Norway already have long-standing accessibility cultures, often going beyond EU minimums. National agencies place strong emphasis on public procurement and utilities. For example, banking and telecom statements are under scrutiny to ensure accessible billing. Nordic regulators are likely to enforce consistently and demand proof of accessibility at the template level, not just on websites.

EAA in Nordics

The practical takeaway? If you operate across multiple EU markets, you’ll want to meet the highest standard across all jurisdictions. It’s more efficient than trying to manage different compliance levels for different countries.

Accessible Documents for Enterprises: Business Communications Within CCM and DMS

Enterprise Document Management and Customer Communications Management (CCM) systems have traditionally prioritised efficiency, security, and version control. However, with European Accessibility Act (EAA) coming into force, digital accessibility has become a compliance “wild card” that organisations can no longer ignore.

The EAA introduces new requirements that affect:

Document Creation Workflows: Every template, automated generation process and approval workflow needs accessibility checkpoints built in.
Search and Retrieval: Users with disabilities must be able to find and access documents as efficiently as anyone else. This affects your search algorithms, metadata standards, and user interface design.
Version Control: When documents are updated, accessibility features must be maintained and improved, not accidentally removed.
System Integration: APIs, third-party connections, and data export functions must preserve accessibility across all touchpoints.

The good news is that most leading DMS/CCM platforms like Quadient Inspire, OpenText or Smart Communications have evolved to support accessibility features. The best practice is to incorporate accessibility at the template and content design stage, rather than fixing documents after the fact.

For example, Quadient Inspire – a leading CCM platform – has introduced robust features to help enterprises meet accessibility requirements. Inspire’s design tools allow template creators to define document structure (headings, reading order, etc.), text alternatives, and other tags so that the output PDFs are compliant with PDF/UA and the output emails or web content meet WCAG standards.

Quadient confirms that its Inspire portfolio can create accessible documents and emails when used properly, and it encourages organisations to bake accessibility into the design phase of communications. This means a bank using Inspire to generate monthly statements can configure templates such that each PDF statement comes out tagged and accessible by default, minimising the need for later fixes.

The silver lining? Addressing these challenges often improves overall system performance and user experience for everyone.

How to Check Your PDFs for Accessibility

The million-dollar question: “How do we assess our current documents for accessibility compliance?” And we’ve got you covered.

Again we recommend you to check our latest material about PDF Accessibility or Download our Beginner Guide, which will lead you through the complete process of checking, remediation and creation of accessible PDF.

EAA Prediction: What Business Should Expect Next?

Since we’re now past the official EAA implementation date, enforcement is becoming increasingly active. Companies that haven’t addressed compliance face potential penalties and market access restrictions. More importantly, non-compliant businesses may find themselves excluded from public procurement opportunities. Here’s what regulated industries can expect in the coming years:

2025-2026: The Enforcement Ramp-Up
Regulatory audits may begin, particularly in sectors like finance and telecom where the impact of inaccessibility is highest. National authorities are issuing formal warnings and corrective action orders to organisations with non-compliant digital services. User complaint mechanisms are fully operational, meaning individual users and advocacy groups can trigger investigations.

The key shift is that regulators now require documented evidence of progress, not just promises to fix issues eventually. Your business communications, PDFs, and digital portals need to show measurable compliance improvements. In 2026 The first financial penalties are likely to be imposed — particularly on providers who failed to act on earlier warnings.

2027-2029: Market Maturity, Procurement Shifts, and Sector-Wide Compliance Pressure
Accessibility becomes a standard procurement requirement in public tenders and B2B agreements. Public sector buyers, utilities, and large enterprises will increasingly demand EAA-aligned compliance from their vendors and technology partners.

We expect to see industry-wide benchmarking: banks and telecoms will be compared based on accessibility, and those lagging behind may lose competitive ground or face reputational risk. Accessibility will factor into ESG metrics, investor reporting, and even board-level audits — especially in regulated sectors under public scrutiny.

2030: Legacy System Phase-Out
The final enforcement milestone requires all legacy equipment and digital touchpoints to meet current accessibility standards, regardless of when they were introduced.

The Strategic Opportunity Hidden in Compliance Requirements

EAA compliance may seem like just another regulatory task, but accessible documents can streamline operations, lower risks, and build stronger customer relationships. The companies that treat it as “just a tick” usually end up firefighting — retrofitting fixes, patching templates, and paying twice when audits catch what was missed.

The companies that bake accessibility into their document workflows discover something different: efficiency, market reach, and even stronger positioning in tenders.

Here’s what that looks like in the real world:

1. Expanded Market Reach = More Customers Served

Your website may already be compliant. But if a policy document, billing statement, or loan agreement is inaccessible, a customer with low vision or using a screen reader is left out.
Aging customers & people with disabilities benefit from well-tagged, accessible PDFs. For a bank, that could mean tens of thousands of customers able to independently read their monthly statements without calling the hotline.

2. Operational Efficiency = Fewer Support Tickets

Think about the cost of all the “I can’t open my bill” or “this form won’t let me type” calls. Those support requests don’t just frustrate customers, they drain service teams. Well-structured, accessible documents reduce these pain points. Templates that follow standards are easier

to process with automation;
for customers to navigate;
for staff to update.

3. Stronger Brand Positioning = Competitive Edge

Procurement processes are already asking about accessibility. A utilities company bidding for a public contract that can prove its PDFs meet EAA standards has a measurable advantage over a competitor who can’t. Accessibility is a visible signal that you take inclusion and regulatory maturity seriously. That resonates with customers, regulators, and partners.

4. Future-Ready Operations = Built for What’s Next

AI assistants, voice technologies, and automation tools depend on structured content. An accessible document isn’t just better for screen readers today — it’s also machine-readable for tomorrow.

That means your investment in accessible templates pays dividends when future systems pull data from the same PDFs. Whether it’s a chatbot reading out an insurance policy or an AI tool parsing invoices, structured content keeps you ahead of the curve.

Moving Forward: Your Next Steps in Accessible Documents and Communications

You don’t need to fix every communication type overnight. The most effective approach is to start small, focus on the customer-facing documents and PDFs with the highest visibility — account statements, policy documents, regulatory disclosures, billing notices — and build from there. Templates of those business communications are vital.

Here’s how to approach it without overwhelming your teams:

Set Up Continuous Monitoring
Accessibility isn’t “done once.” Templates change, regulations evolve, and audits are ongoing. Build monitoring and review into your workflows so you’re always one step ahead.
Audit What You Have
Gather a sample of your recurring PDFs and digital templates. Map what’s customer-facing, what’s critical to compliance, and where accessibility gaps exist.
Prioritise High-Impact Templates
Focus first on documents that directly affect customer experience or regulatory risk. Loan offers, insurance policies, and bills get far more scrutiny than internal memos.
Build Accessibility Into Templates, Not Files
Fixing documents one by one is a losing game. Embedding accessibility at the template level means every future statement, invoice, or policy document comes out compliant by default.

This is where our team steps in. We are proud to be a partner of the most well-known banks, insurances and utility companies in EMEA in their PDF Accessibility journey. Together we make compliance scalable. We review your current PDFs, templates, and workflows to identify high-risk gaps. We transform legacy templates into PDF/UA- and WCAG-compliant outputs, future-proofed against audits. Whether you use legacy or modern CCM or DMS, we ensure accessibility is embedded at the system level — not patched after the fact.

A presentation slide from a company named Quertum titled "How European Accessibility Act Affects Nordic Businesses." The slide features a green map of the Nordic countries (Norway, Sweden, Finland, and Denmark) with each country's flag and an accessibility icon over the map. The background is a dark blue-purple gradient with light green grid lines.

EU Accessibility Act in the Nordics: Consistent, Contextual, and Culturally Anchored

Written by Kalynovska Kateryna on September 3, 2025. Posted in PDF accessibility.

In our previous articles, we outlined how countries like France, Poland, Germany, and the Netherlands have implemented the Accessibility Directive, so it’s time to have a closed view to European Accessibility Act in the Nordics region. Sweden, Denmark, Finland, and Norway stand out for its long-standing digital accessibility culture. These countries are not starting from scratch: accessibility is already a legal and social expectation.

In this article, we examine how the European Accessibility Act applies across the Nordics and what companies need to prepare for, whether they operate locally or cross-border.

How the European Accessibility Act Affects Nordic Businesses?

The Nordic approach to the EAA is marked by integration rather than reinvention. Instead of building entirely new frameworks, each country has chosen to embed the EAA into existing national legislation. This reflects the region’s long tradition of treating accessibility as both a legal right and a cultural norm.

Sweden has incorporated the EAA into Lag (2023:254), broadening its existing accessibility framework to cover sectors such as banking, e-commerce, transport, and telecom. Oversight is shared between the Swedish Consumer Agency (Konsumentverket) and the Agency for Digital Government (DIGG).
Denmark enforces accessibility through Act no. 801 of 07/06/2022, with a strong emphasis on consumer protection. The Danish Business Authority (Erhvervsstyrelsen) is the lead body, taking a guidance-led approach while retaining the power to issue fines and corrective measures.
Finland aligns the EAA with Government Decrees 179/2023 and 180/2023, building on the accessibility requirements already established under the Act on the Provision of Digital Services. Compliance is supervised by the Finnish Transport and Communications Agency (Traficom).
Norway, while not an EU member, implements equivalent rules via the Anti-Discrimination and Accessibility Act and related ICT regulations. Enforcement is handled by the Agency for Public Management and eGovernment (Digdir), ensuring alignment with the EEA Agreement.

For businesses, this creates continuity with national traditions but also complexity: obligations are consistent in principle, yet enforcement models and regulatory expectations differ across the region. Multinationals must be prepared to navigate these nuances while ensuring compliance with a baseline set of EAA requirements.

What the European Accessibility Act in the Nordics Requires?

The baseline obligations are the same across all Nordic countries, as they derive from the EU Directive:

Digital content must comply with WCAG 2.1 AA (websites, apps, PDFs)
Products and services must be compatible with assistive technologies
Accessibility statements, documentation, and feedback mechanisms are mandatory
Labels, instructions, and user interfaces must be legible, perceivable, and understandable
Identification, security, and payment functions must meet POUR principles

Banking and e-commerce services carry extra requirements:

Identification methods, e-signatures, and payment services must be perceivable, operable, understandable, and robust
Financial information must be written at B2 language level or lower, ensuring clarity
E-commerce operators must provide information about the accessibility of products and services where available

This mirrors the approach in the Netherlands and highlights how financial services are under special scrutiny across the EU, including the Nordics.

Exemptions and Exceptions for European Accessibility Act in the Nordics

The Nordic countries follow the general EAA exemptions:

Microenterprises: Fewer than 10 employees and turnover/balance sheet below €2M are exempt. Regulators in Sweden, Denmark, and Finland nevertheless encourage voluntary compliance to remain competitive in the digital single market.
Disproportionate burden: Businesses may be exempt if compliance would create costs disproportionate to the accessibility benefit, based on Annex VI of the Directive. Lack of time or knowledge is not a valid reason.
Fundamental alteration: When accessibility requirements would alter the service so substantially that it becomes a different service.
B2B services: The EAA applies only to business-to-consumer services, not pure B2B contexts.

Timeline and Transition Rules

The enforcement date is consistent across the EU and the EEA:

28 June 2025: All new services and modified contracts must comply with the EAA
Existing contracts signed before this date may run until expiry, but no longer than five years, meaning by 28 June 2030 all must comply
Physical products used in service delivery (e.g., payment terminals, e-ID devices) have the same five-year transition period. Products placed on the market before June 2030 may be used temporarily, but must be upgraded or replaced to meet the new requirements.

What Penalties for Non-Compliance in the Nordic Region?

The penalty framework varies slightly across Nordic countries, but follows similar patterns:

Administrative fines are the main tool, with amounts depending on turnover and severity
Regulators may impose recurring penalties until compliance is achieved
In serious cases, providers may face suspension of services or public disclosure of violations

Sweden’s model is considered stricter, with higher fines and stronger inspection powers, while Denmark and Finland lean on consumer law enforcement traditions.

Key Differences at a Glance for Nordic Countries

To make the national differences clearer, the table below outlines how each Nordic country has embedded the EAA into its legal framework, who supervises compliance, and what businesses should be aware of in terms of scope and enforcement.

Country	Main Law / Framework	Supervisory Authority	Special Features	Penalties & Enforcement
Sweden	Lag (2023:254)	Swedish Consumer Agency (Konsumentverket) and Agency for Digital Government (DIGG)	Broad scope, covering banking, e-commerce, transport, and telecom; one of the earliest comprehensive accessibility laws in Europe.	Fines, corrective orders, and strong inspection powers; considered among the strictest in the EU. Fines range up to EUR 200 000.
Denmark	Act no. 801 of 07/06/2022	Danish Business Authority (Erhvervsstyrelsen)	Strong consumer protection focus; guidance-led enforcement with emphasis on business accountability.	Administrative fines, warnings, and recurring penalties until compliance is achieved. Fines range up to EUR 10 000 for initial non-compliance.
Finland	Government Decrees 179/2023 & 180/2023	Finnish Transport and Communications Agency (Traficom)	Builds on existing Digital Services Act (2019), where WCAG 2.1 AA was already mandatory for public bodies.	Fines and corrective measures, applied proportionately to scale and impact. Fines range up to EUR 150 000.
Norway (EEA country)	Anti-Discrimination and Accessibility Act + ICT regulations	Agency for Public Management and eGovernment (Digdir)	Applies to both public and private services despite Norway being outside the EU; aligns with EEA obligations.	Administrative penalties and corrective measures, supported by Norway’s strong ICT audit tradition.

Summary

The Nordics are well-positioned to implement the EAA thanks to their strong pre-existing accessibility laws. For businesses, this means compliance is not just about meeting EU standards but aligning with national frameworks that often go further.

From Sweden’s early adoption of a broad accessibility act, to Norway’s strict ICT obligations, the Nordic region sets high expectations. Companies operating here must take accessibility seriously, integrate it into product and service design from the outset, and prepare for close scrutiny by multiple regulators.

European Accessibility Act in the Nordics region is treated as integral to society, law, and commerce, rather than as a formal obligation alone.

EU Accessibility Act in the Netherlands: Systematic and Sector-Integrated

Written by Kalynovska Kateryna on August 28, 2025. Posted in PDF accessibility.

In our previous articles, we reviewed how France, Poland, and Germany implemented the EAA, and now we are turning to the EU Accessibility Act in the Netherlands. Dutch law takes a highly structured approach, embedding EAA requirements across existing laws and delegating enforcement to multiple sectoral authorities.

In this article, we break down how the EAA (or Toegankelijkheidsrichtlijn in Dutch) has been transposed in the Netherlands, what it means for businesses, and how companies, whether local or global, must navigate this new legal landscape.

How the European Accessibility Act Affects Business in the Netherlands?

The Netherlands transposed the EAA via the Dutch Implementation Act, passed in April 2024. Instead of creating a single omnibus law, the obligations have been embedded into existing sector-specific legislation.

Examples include:

Telecommunications Act: For telecoms and digital communication services
Civil Code: For e-commerce and consumer contracts
Financial Supervision Act: For banking and financial services
Equal Treatment of Disabled and Chronically Ill People Act: For transport and audiovisual media

This decentralised transposition means that a business operating across multiple sectors, such as a bank that also sells products via e-commerce, will need to comply with several pieces of legislation at once, each enforced by a different authority. While this allows for more targeted oversight, it also makes compliance more complex, requiring cross-departmental coordination and robust legal oversight.

What the EU Accessibility Act in the Netherlands Requires?

Across all sectors, companies must:

Ensure products and services are accessible in line with Annex I of the EAA, using EN 301 549 as the functional standard.
Publish accessibility statements and implement feedback mechanisms for users.
Maintain documentation and evidence of compliance, and take corrective actions when necessary.

These requirements reflect the EAA’s functional performance principles, which focus on how users experience a product or service rather than prescribing exact technical methods. By centring on perceivability, operability, understandability and robustness, the legislation gives businesses flexibility, but also holds them accountable for delivering genuinely usable services.

Requirements for Banking Services under EU Accessibility Act in the Netherlands

For banking services, the following apply:

Identification methods, electronic signatures, security, and payment services must be perceivable, operable, understandable, and robust.
Information must be understandable without exceeding B2 level of the Council of Europe’s Common European Framework of Reference for Languages.

Additional Requirements for (Financial) E-Commerce Services

For (financial) e-commerce services, businesses must:

Provide information about the accessibility of products and services being sold when such information is provided by the responsible economic operator.
Ensure accessibility of identification, security, and payment functionalities when these are delivered as part of a service, making them perceivable, operable, understandable, and robust.
Provide identification methods, electronic signatures, and payment services in line with POUR principles.

What are Exemptions for EAA in the Netherlands?

The EAA in the Netherlands allows exemptions in specific cases:

Microenterprises: Businesses with fewer than 10 employees and an annual turnover or balance sheet total not exceeding €2 million are exempt. The AFM encourages these businesses to meet EAA standards where possible to improve competitiveness;
Disproportionate burden: When the costs of compliance outweigh the benefits for persons with disabilities, following the criteria in Annex VI of the EAA. Legitimate reasons must be used; lack of priority, time, or knowledge is not acceptable;
Fundamental alteration: When compliance would change the essential nature of the service;
B2B services: The EAA does not apply to business-to-business services.

Even when exemptions apply, Dutch regulators stress that accessibility should be seen as a market opportunity. Complying voluntarily can open access to cross-border customers, increase brand trust, and reduce the risk of future legal changes removing exemptions altogether.

If external funding is provided to improve accessibility, providers cannot claim disproportionate burden or fundamental alteration.

Sectoral Implementation & Enforcement of EAA on Dutch Market

Supervision of the EAA accessibility requirements in the Netherlands is divided among:

ACM (Authority for Consumers and Markets) – telecom, e-commerce
RDI (Digital Infrastructure Inspectorate) – infrastructure-related services
CvdM (Dutch Media Authority) – audiovisual services
ILT (Human Environment and Transport Inspectorate) – transport
AFM (Authority for the Financial Markets) – financial services

The Ministry of Health, Welfare and Sport (VWS) maintains an accessibility monitoring website with detailed enforcement guidelines.

Physical Products Used in Service Provision

If physical products are used when providing a service, such as bank cards, random readers, or e-identifiers, they must also meet the EAA’s accessibility requirements.

There is a five-year transition period for products already placed on the market before 28 June 2025. During this time, services can continue using them, but they must be upgraded or replaced to comply with the EAA before the deadline.

For instance, an older random reader device may not support screen reader functionality or tactile feedback, making it difficult for users with visual impairments. During the transition period, such devices can still be used, but they must be upgraded or replaced with fully accessible alternatives before the 2030 deadline.

Timeline and Transition Rules

28 June 2025 – EAA obligations apply for all new services and modified contracts.
Existing service contracts signed before this date can continue without changes for up to five years, until 28 June 2030.

During the transition period, physical products used in providing services must be made accessible before the final deadline.

This dual timeline, services first, products later, means businesses will need to manage two parallel compliance tracks. While the product deadline may seem far away, procuring, testing, and deploying new accessible hardware can take years, making early planning essential.

This applies equally to banking services and financial e-commerce services.

What are Penalties for EAA Non-Compliance in the Netherlands?

Failing to meet the EAA requirements can lead to significant consequences:

Regulator	Penalty Potential
ACM	Fines up to €90,000 or higher based on turnover
AFM	Financial penalties and additional sanctions such as market restrictions
Other sector regulators	Sanctions relevant to their domain, potentially including suspension of services

Non-compliance may also lead to service suspensions and reputational damage, as demonstrated in documented cases of enforcement and public backlash.

Summary

The Netherlands embeds EAA obligations into existing sectoral laws, creating a targeted yet comprehensive enforcement model. Businesses, especially in finance and e-commerce, face detailed accessibility requirements for identification, security, and payment functions, as well as clear rules on product accessibility and transition periods. With multiple regulators and penalties of up to €90,000 or more, companies should start preparing now to ensure compliance as soon as possible.