PDF/UA (ISO 14289) is the standard for accessible PDFs. Most government PDFs do not meet it.
PDF/UA, formally ISO 14289, is the international standard that defines what an accessible PDF must do. Australia adopted it as AS ISO 14289. The Australian Human Rights Commission names PDF/UA as the standard to meet where PDFs are provided. Most Australian government PDFs do not meet it.
That is not a technical failure. It is a governance failure.
What PDF/UA actually requires
PDF/UA tells you what an accessible PDF must contain. The list is not long.
Documents must be tagged with semantic structure. Headings must be marked as headings. Lists must be marked as lists. Tables must have row and column headers. Reading order must follow logical sequence.
Meaningful images must have alt text. Decorative images must be marked as artifacts. Document language must be set. Colour must not be the only way to convey meaning.
WCAG governs your web pages. PDF/UA governs your documents. Treating one as a substitute for the other is one of the most common compliance errors I see.
The Style Manual is right, and then it is not enough
The Australian Government Style Manual says to use HTML in preference to PDFs. That is the right starting position. PDFs are harder to maintain, harder to find, harder to update, and harder to make accessible than the equivalent web page.
But "do not publish PDFs" is not, in practice, a policy. It is a preference that gets overridden every time a business line decides a brochure, a form, a corporate plan, or a parliamentary report needs to be a PDF.
Why most agency PDFs fail PDF/UA
The pattern is consistent across the agencies I have worked with.
Authors produce the document in Word with default styles. They export to PDF with default settings. The export does not preserve heading structure, does not mark decorative images as artifacts, and does not set the document language.
Nobody runs a PDF/UA validator. Nobody is contracted to.
Compliance gets stamped because the agency's WCAG 2.2 audit covered the surrounding web page, not the PDF linked from it. The PDF inherits the page's compliance claim by adjacency, not by audit.
This is the same problem as the templated letter problem. Content owners produce thousands of artefacts at scale, and the content governance model cannot see them.
What a workable PDF/UA position looks like
It has three parts.
First, a decision rule. No PDF is published unless an HTML equivalent exists, or the format is required for legal status, archival, or print. This forces the question "should this PDF exist" before the question "is it accessible".
Second, a production standard. PDFs that must be published are produced through a templated workflow that tags structure, applies language metadata, and validates against PDF/UA before sign-off. The tool is less important than the gate.
Third, an inventory and audit cycle. The agency knows how many PDFs it publishes, who owns each one, when it was last reviewed, and whether it currently meets PDF/UA. Without this, the standard is theoretical.
The legal frame
The Disability Discrimination Act 1992 (Cth) makes inaccessible government information a barrier to access. WCAG 2.2 AA is the mandatory baseline for Australian Government digital content. PDF/UA is the specific standard for PDFs. None of this is optional.
The risk does not sit with the PDF author. It sits with the agency.
A practical question for your team this week
The question to put to your content team is not "are our PDFs accessible". That question never returns a useful answer.
The question is: how many PDFs do we publish, who owns them, and when was the last one validated against PDF/UA?
If you cannot answer those three questions in a meeting, you do not have a PDF accessibility problem. You have a PDF governance problem.
Photo by Rubaitul Azad on Unsplash.