Accessible PDFs in Canada and Australia: the rules in brief

Why this is less clear-cut than in the US

Neither Canada nor Australia has a single rule that says "every PDF must meet standard X by date Y." Instead, a general accessibility or anti-discrimination law sets the duty, and technical standards such as WCAG (the Web Content Accessibility Guidelines from W3C) describe what accessible looks like in practice.

This guide summarizes what official sources say. It is general information, not advice. If you need to know what applies to your organization, ask a qualified professional or your regulator.

Canada: the federal picture

The Accessible Canada Act

According to the Government of Canada's summary, the Accessible Canada Act came into force on July 11, 2019. Its purpose is to make Canada barrier-free by January 1, 2040.

Who it covers: federal government departments, agencies and Crown corporations, plus federally regulated private sector organizations such as banks, broadcasting and telecommunications providers, and interprovincial or international transportation providers. The Canadian Forces, the RCMP and parliamentary entities are included too.

What it covers: seven priority areas, one of which is "information and communication technologies." Documents and PDFs fall within that area.

What covered organizations must do:

• publish accessibility plans that address barriers, updated every three years unless the regulations say otherwise, prepared in consultation with people with disabilities;

• set up a process to receive and respond to accessibility feedback;

• publish regular progress reports.

The Act itself does not list technical rules for PDFs. Those come from standards.

The ICT standard: CAN/ASC - EN 301 549:2024

Accessibility Standards Canada has adopted the European standard EN 301 549 as a National Standard of Canada, called CAN/ASC - EN 301 549:2024. Its summary says the standard "states the accessibility requirements for ICT products and services" and applies to private and public sector organizations in federally regulated sectors.

It includes requirements for non-web documents, which covers "all documents that are not web pages and are not embedded in web pages," so downloadable PDFs and Word files are in scope. EN 301 549 builds on WCAG for its web and document requirements.

Whether a given organization must follow this standard, or treats it as guidance, depends on how it is referenced in regulations, policies or contracts. Check with the Accessibility Commissioner or your sector regulator.

Provinces have their own rules

The Accessible Canada Act covers federal jurisdiction only. Provinces set their own requirements for organizations they regulate.

Ontario is a well-known example. Under the Accessibility for Ontarians with Disabilities Act (AODA), the Government of Ontario says designated public sector organizations, and businesses and non-profits with 50 or more employees, must make public websites and web content meet WCAG 2.0 Level AA (except live captions and pre-recorded audio descriptions). The requirement took effect on January 1, 2021, and applies to web content posted after January 1, 2012.

Several other provinces have passed their own accessibility laws, with different scopes and timelines. Check your province's official accessibility page.

Australia

The Disability Discrimination Act 1992

Australia's main law is the federal Disability Discrimination Act 1992 (DDA). It makes disability discrimination unlawful in areas including the provision of goods, services and facilities. W3C's summary of Australian policy lists the DDA as a non-discrimination law covering government and the private sector.

The DDA does not name a technical standard for documents. The practical question is whether a person with disability can get the same information and service as everyone else.

Australian Human Rights Commission guidance

The Australian Human Rights Commission publishes Guidelines on equal access to digital goods and services. W3C's policy summary quotes its central message: "All organisations should aim to avoid discrimination by providing equal access to digital goods and services to everyone." In practice, organizations commonly use WCAG as the technical yardstick, since it is the standard named in Australian Government policy.

Government services: the Digital Service Standard

For Australian Government digital services, W3C lists the Digital Service Standard 2.0, part of the Digital Experience Policy, with WCAG 2.2 as the referenced version. W3C also lists AS EN 301 549, the Australian adoption of the same ICT standard Canada uses, under the Commonwealth Procurement Rules.

States and territories have their own policies for their agencies, so a state department may follow a different instruction from a federal one.

What this means for a PDF in practice

In both countries, the technical checklist is the same one used everywhere:

1. Real text, not scanned images.

2. Tags for headings, paragraphs, lists, tables and figures.

3. A logical reading order.

4. Alt text for meaningful images; decorative items marked as artifacts.

5. Table header cells identified.

6. A real document title and the right language set (for Canadian federal bodies, French and English versions are common, and each should have its language set).

7. Labelled form fields.

8. Sufficient color contrast.

A sample situation

Here is a fictional example. Northgate Freight, a federally regulated trucking company in Canada with 140 employees, publishes its accessibility plan and a customer service guide as PDFs.

Sensible steps:

• Make the accessibility plan itself accessible. It would be awkward to publish a plan about removing barriers in a file a screen reader cannot read.

• Offer an accessible format on request and say how to ask.

• Check the PDFs against WCAG using Acrobat's checker and a screen reader.

• Record the work in the next progress report.

A sister company in Melbourne would work against the same technical checklist, guided by the DDA and the Commission's guidelines rather than a fixed deadline.

Get your documents ready for review

EasyToDecode is launching soon with a tool that will turn an untagged PDF into a tagged version with headings, reading order and table structure, plus draft alt text for your review. It also gives a report against PDF/UA and WCAG checks that shows what still needs a person, and does not certify compliance. See how it works or join the waitlist.