Selling to Government? Your PDFs May Be Part of the Accessibility Test

A startup can spend months preparing for a government contract, then discover that the problem isn’t its price, staffing plan or product. It’s a PDF.

The company website may work well with a screen reader. The product may meet the buyer’s technical requirements. But if the service includes an unlabeled form, a poorly tagged report or a manual with a scrambled reading order, the accessibility review may reach those files too.

The Department of Justice has given state and local governments another year to meet its web and mobile accessibility rule. That’s useful breathing room. It’s also a good time for vendors to find the documents that could cause trouble later.

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Why a vendor’s documents can enter the accessibility review

The rule applies to web content and mobile apps that state and local governments provide or make available. That includes content supplied through contracts, licenses and similar arrangements.

The legal responsibility remains with the public entity, but vendors may still feel the practical effects through bid requirements, contract language, acceptance testing or requests to fix inaccessible work.

The DOJ’s guidance for small public entities is direct on this point. A government that hires another organization to provide public services must make sure the resulting web content or mobile app meets its Title II responsibilities. DOJ also defines web content broadly enough to include documents.

For a vendor, the sensible question isn’t “Does the rule regulate our company?” It’s “Which parts of our work will the customer publish or use to provide a public service?”

That could include a county benefits form, a software-generated transit report, a public university’s training manual or notices produced by a third-party platform. The document doesn’t become somebody else’s problem simply because a contractor created it.

Don’t assume every PDF exchanged with a government customer is covered. A brochure emailed to one buyer may be treated differently from a form the agency posts for residents. Ask the buyer what’s in scope while there’s still time to make changes.

Find the PDFs attached to the service

Companies tend to review the files inside a proposal and stop there. The bigger risk may be the documents the customer receives after the contract is signed.

Trace the whole service. What will your team create, upload, update or generate for the buyer? Which files could eventually reach a resident, student, patient, passenger or business owner?

• Forms people must complete
• Reports and notices generated by your software
• Manuals, instructions and training materials
• Templates the customer will edit and publish
• Recurring statements or letters
• Presentations and meeting documents
• Scanned records made available online

Include the editable source file for each document when it exists. A PDF is much easier to correct when someone can repair the headings, table structure and image descriptions in the original Word, PowerPoint or design file before exporting it again.

Then record who owns the document, where it will appear and how often it changes. Pay particular attention to files that people need to apply for a service, submit information, understand a decision or meet a deadline. A decorative brochure and an application form don’t carry the same consequences when something goes wrong.

StartupNation’s older advice to make sure you can deliver before you bid applies here. Accessibility belongs in that delivery check alongside staffing, financing and technical capacity.

Some older documents may qualify for an exception under the DOJ rule, including certain preexisting conventional electronic documents. Don’t build the inventory around that assumption. Updating a file may affect whether an exception still applies, and other ADA obligations may still require a public entity to provide accessible information to someone who needs it.

A PDF can look fine and still fail a real user

Visual inspection is a poor accessibility test. A clean page can hide missing tags, unnamed form fields, and text that a screen reader announces in the wrong order.

Take a two-column report. A sighted reader knows to finish the left column before moving to the right. If the file’s structure is wrong, assistive technology may read straight across the page, joining unrelated sentences into nonsense.

Reading order is one of the checks described in the W3C’s PDF accessibility technique. W3C explains that tag order helps determine how a PDF is read and that complex layouts don’t always convert correctly, even when the source document looks orderly.

A useful first review should ask:

• Can the text be selected, or is the document only a scanned image?
• Do headings, paragraphs and lists have meaningful structure?
• Does the reading order follow the intended meaning?
• Do informative images have useful text alternatives?
• Can someone understand a table from its headers and cell relationships?
• Do links make sense without the surrounding sentence?
• Are form fields named, explained, and placed in a sensible tab order?
• Can every interactive part be reached with a keyboard?
• Are the document title and language identified?

This is where website accessibility and document accessibility part ways. A company may have fixed its navigation, page headings, and color contrast while leaving dozens of downloadable files untouched.

Automated checkers can catch some defects, but a green result doesn’t settle the matter. Software can detect a missing image description. It can’t always tell whether the description is useful. It may flag a reading order, yet fail to recognize that the order makes no sense to a person following the document.

Use the tools, then have someone check the file with a keyboard and assistive technology. For an important form or public notice, include a reviewer who understands PDF structure and accessibility. The file has to work, not merely pass a scan.

Put accessibility into the bid-to-delivery workflow

The best time to fix a PDF is before it becomes a PDF.

Ask about accessibility during the bid or discovery process. Which standard does the buyer expect? What file types will your company provide? Does the buyer require test results, an accessibility statement or a particular review process? Who decides whether a deliverable is accepted?

Once production begins, use an accessible source template. Set up real heading styles, simple tables, clear link text and image descriptions while the content is being written. Exporting first and repairing everything afterward usually creates more work.

If several teams create or update files, a shared document accessibility workflow for public-sector deliverables can keep the source, checking, remediation and approval steps from falling to different owners.

The process itself can stay small:

1. Scope the files. Agree on which documents are included and what the buyer expects.
2. Create from an accessible source. Give writers and designers templates that already contain the right structure.
3. Test before delivery. Combine automated checks with manual review, then save the results the contract calls for.
4. Maintain the work. Keep the source file, name the person responsible for fixes and retest after meaningful changes.

Recurring reports need extra care. Testing the template once is a reasonable start, but generated data can alter page breaks, table structures and reading order. Sample the finished output as well.

The same rule applies when subcontractors produce part of the content. Tell them which requirements apply, who reviews their files and what happens when a document needs to be corrected. Otherwise, the accessibility gap may sit inside a handoff that everyone assumed somebody else owned.

When existing files need remediation

Some documents can be fixed at the source and exported again. That’s usually the cleanest route because it leaves the company with an editable file that can support future revisions.

Others need direct PDF remediation. This may involve adding or correcting tags, headings, table structure, reading order, alternative text, form labels, bookmarks and document properties. 

Don’t assume that publishing an accessible alternative beside a broken file solves the problem. DOJ guidance limits when conforming alternate versions can be used instead of making the primary content accessible.

For a large archive, start with the documents people currently depend on. A benefits application used every day deserves attention before an old event flyer that nobody opens. Keep a queue for the rest, record what has been tested and check repaired files again after later edits.

Use the extra time before the RFP forces the issue

Pick one public-sector customer or target account. List the five files most likely to reach the public, ask what the buyer expects and manually test one of them this week.

You may find that the files are in good shape. You may find a form that nobody can complete without a mouse or a report that sounds like word salad through a screen reader. Either result is useful now.

It’s much less useful when the contract is waiting for a signature.

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