How do I audit my PDF library for EAA compliance?

Start by crawling your website for all PDF links (wget --spider or your CMS export). For each PDF: run PAC 2024 for automated tag checks, zoom to 400% to test WCAG 1.4.10 Reflow, and navigate with a screen reader (NVDA or VoiceOver). Classify each as compliant, minor failure, reflow failure, or scanned. Remediate reflow failures by converting to EPUB3 with toolkit.bot. Document every check and remediation action as your compliance audit record.

What is the most common EAA accessibility failure in PDFs?

The most common and most serious EAA failure in PDFs is WCAG 1.4.10 (Reflow): content must be readable at 400% zoom without horizontal scrolling. PDFs fail this by design because they use a fixed-page layout. This failure cannot be fixed within the PDF format — it requires conversion to a reflowable format such as EPUB3, HTML, or Word. toolkit.bot converts PDFs to reflowable EPUB3 in about 30 seconds, free, without an account.

What tools do I need to audit PDFs for accessibility?

PAC 2024 (PDF Accessibility Checker, free, Windows) for automated structural checks. Adobe Acrobat Reader or a browser for the WCAG 1.4.10 zoom test. NVDA (free, Windows) or VoiceOver (built-in, macOS/iOS) for screen reader navigation testing. ACE by DAISY (npm install -g @daisy/ace) for EPUB3 validation after conversion. For the remediation step: toolkit.bot for PDF-to-EPUB3 conversion, or Adobe Acrobat Pro for PDF tagging fixes.

Which PDFs do I need to make accessible under EAA 2026?

PDFs distributed to consumers as part of a digital product or service in EU markets are in scope. Priority order: e-books and publications sold or distributed digitally (highest), product documentation and user manuals, e-learning and training materials, publicly accessible annual reports and investor docs, policy documents distributed to customers. Internal-only PDFs used by employees are generally out of EAA scope but may fall under other obligations.

How to Audit Your PDF Library for EAA 2026 Compliance

The European Accessibility Act enforcement date of June 28, 2026 has passed. If your organization distributes PDFs to consumers in the EU and has not audited them for accessibility, you are now exposed to enforcement action.

This guide covers how to audit a PDF library systematically: what to inventory, which checks to run, how to prioritize remediation, and how to document your compliance efforts for audit purposes.

Why PDF Libraries Are the Highest-Risk EAA Gap

Most organizations focus EAA remediation on their websites. PDFs — annual reports, product documentation, e-learning materials, publications — are frequently overlooked and represent the largest volume of non-compliant digital content in circulation.

Unlike websites, PDFs are not continuously monitored by automated accessibility crawlers. A single report published in 2019 can sit on a download page for years, accumulating compliance risk with each passing month of EAA enforcement.

Step 1: Build Your PDF Inventory

You cannot audit what you cannot find. Start with a complete inventory of PDFs in public distribution:

Website crawl

Use a web crawler to enumerate all PDF links on your domain. Many organizations are surprised by how many PDFs are reachable from their public site:

# Using wget to list all PDF links (no download)
wget --spider --force-html -r -l 3   --accept pdf   --no-verbose   https://yoursite.com 2>&1   | grep "^--" | awk '{print $3}' | grep ".pdf$"   | sort -u > pdf_inventory.txt

echo "Found $(wc -l < pdf_inventory.txt) PDFs"

CMS and document repository

Export a file listing from your CMS (SharePoint, Confluence, Drupal, WordPress media library) filtering for PDF MIME type. Document management systems typically have built-in export or search.

Inventory fields to capture

For each PDF, record: URL, filename, file size, date last modified, page count (if available), and a brief description of content type (report, form, publication, policy, e-learning). These fields drive your prioritization in the next step.

Step 2: Prioritize by Compliance Risk

Not all PDFs carry equal EAA risk. Rank by two factors: distribution reach and content type scope.

Distribution reach (highest priority first)

Linked from main navigation or product pages — actively directed to consumers
Referenced in marketing emails or customer communications — distributed directly to customers
Indexed and ranked in search engines — reachable organically by anyone
Linked from deep within the site but publicly accessible — lower reach, still in scope
In the sitemap but not actively promoted — archived content, lowest priority

Content type scope

Under EAA, digital products and services distributed to EU consumers are in scope. This includes:

E-books and digital publications (highest priority)
Product documentation and user manuals
E-learning materials and training resources
Annual reports and investor communications
Policy documents and terms distributed to customers
Marketing and sales materials linked from product pages

Internal-only documents (accessed only by authenticated employees) are not in scope for EAA, though equivalent obligations may apply under national transposition laws or sector-specific regulations.

Step 3: Run Accessibility Checks

For each PDF in your priority list, run the following checks:

Automated PDF accessibility check (PAC 2024)

PDF Accessibility Checker (PAC 2024) is a free Windows tool that checks PDFs against PDF/UA and WCAG standards without requiring Acrobat. For each PDF, it produces a pass/fail report in under a minute:

Document is tagged
Reading order is logical
Language is declared
Images have alt text
Tables have headers
Links have descriptive text

For macOS, CommonLook PDF Validator provides similar automated checking.

WCAG 1.4.10 Reflow check (critical)

WCAG 1.4.10 (Reflow) is the single most common PDF failure under EAA: content must be readable at 400% zoom without horizontal scrolling. Test this manually:

Open the PDF in Adobe Reader or a browser
Zoom to 400%
Check if text is readable without horizontal scrolling on a 1280px-wide viewport

The overwhelming majority of PDFs — even well-tagged ones — fail this check because the fixed-page format is structurally incompatible with reflow. This is not a tagging problem; it is a format problem. The remediation is conversion to a reflowable format (EPUB3, HTML, or Word).

Screen reader check (NVDA or VoiceOver)

Open the PDF and navigate it using only a keyboard with NVDA (Windows, free) or VoiceOver (macOS/iOS, built-in). Check:

Headings are announced at the correct level (H1, H2...)
Reading order matches visual presentation (especially in multi-column layouts)
Table cells are announced with their column headers
Images are announced with meaningful alt text (or "decorative" if presentational)
The document language is announced at the start

Step 4: Classify and Record Findings

For each PDF, record the outcome of your checks in a spreadsheet or tracking system. Use four classification states:

State	Meaning	Action
Compliant	Passes PAC check, reflows at 400%, screen reader navigable	No action required; schedule for annual re-audit
Minor failures	Fails PAC checks but reflows adequately; fixable with tagging	Remediate with Acrobat or axesPDF; re-check
Reflow failure	Fails WCAG 1.4.10 — fixed layout, no reflow possible	Convert to EPUB3 using toolkit.bot
Scanned / image PDF	No text layer at all — completely inaccessible	Convert with OCR via toolkit.bot (includes OCR)

Step 5: Remediate — Fastest Path by Failure Type

Reflow failures (most common) — convert to EPUB3

PDFs that fail WCAG 1.4.10 cannot be fixed within the PDF format. Convert them to EPUB3 — EPUB3 reflows by design at any viewport width or zoom level:

Go to toolkit.bot/pdf2epub
Upload the PDF — conversion takes 30–60 seconds for text-based documents
Download the EPUB3 and validate with ACE by DAISY
Publish the EPUB3 alongside or instead of the PDF

For large volumes, use the toolkit.bot API to batch convert in parallel. See the batch conversion guide for EAA compliance.

Minor PDF tagging failures

For PDFs that have a text layer and reflow adequately but fail PAC checks on heading tags, alt text, or table headers: remediate in place using Adobe Acrobat Pro (Make Accessible action) or axesPDF. Re-run PAC after remediation to confirm.

Scanned / image PDFs

Scanned PDFs contain no text — screen readers see only images. toolkit.bot includes OCR (Tesseract) and converts scanned PDFs to searchable, reflowable EPUB3. For high-accuracy OCR on archival or complex scanned materials, consider a hybrid workflow: OCR with toolkit.bot, then human review of the EPUB3 output.

Step 6: Document Your Compliance Audit

EAA enforcement relies on demonstrated good-faith effort. Keep an audit record that includes:

Inventory date and method (crawl, CMS export, manual)
Check results per document: PAC report, reflow check outcome, screen reader notes
Classification: compliant / minor failure / reflow failure / scanned
Remediation action: what was done, when, by whom
ACE by DAISY report for each EPUB3 produced (primary compliance artifact)
Publication location: where the accessible version is available

This documentation is your evidence of compliance activity if a complaint is filed or an enforcement body requests audit materials.

Start remediating your highest-priority PDFs now — free, no install, no account required.

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For accessibility teams managing EAA compliance workflows, see our dedicated guide at toolkit.bot/for/accessibility-teams →