Document accessibility | Purplsoft

// 01 · why now

An obligation, and a deadline already past

Digital accessibility has stopped being good practice and become an enforceable requirement. The essentials fit in eight lines.

The text: Directive (EU) 2019/882, the European Accessibility Act, transposed into French law by loi n° 2023-171.
Since when: Since 28 June 2025. Some deadlines run until 28 June 2030, but they mainly concern equipment already installed (kiosks, payment terminals) and customer contracts signed before that date, which may run to their term.
Documents: On the website or app of a bank, an online retailer, a telecom operator or a transport company, any document published since 28 June 2025 falls under the directive: terms and conditions, price lists, downloadable statements and invoices, electronic tickets. Only documents published before that date are excluded (article 2, paragraph 4). E-books are covered in their own right.
For whom: For the products covered, economic operators of any size. For services, only microenterprises are exempt: fewer than ten persons, and an annual turnover or balance sheet total not exceeding two million euros. A company with ten or more employees that provides a covered service is therefore in scope.
Which sectors: Products: consumer computers and their operating systems, payment terminals and self-service terminals (ATMs, ticket machines, check-in kiosks), smartphones and communication equipment, equipment used to access audiovisual media, e-readers. Consumer services: electronic communications, access to audiovisual media, air, rail, waterborne and coach passenger transport (websites, apps, ticketing, traveller information), consumer banking, e-books, e-commerce. The list is set by article 2 of the directive; apart from the 112 emergency number, also covered, it concerns commercial products and services.
Public sector, education, health: Public-law bodies (central government, local authorities, public universities and hospitals) and bodies entrusted with a public service mission do not fall under the list above, but under separate and older obligations. In France that is the RGAA, under article 47 of the law of 11 February 2005 and the decree of 24 July 2019. It covers websites, intranets and extranets, mobile applications, software packages and the interactive part of digital street furniture.
Which standard: EN 301 549 is the technical reference: it incorporates WCAG 2.1 level AA and extends it to hardware and non-web documents. Published in the Official Journal of the EU under the public sector web accessibility directive (2016/2102), it confers a presumption of conformity there. Under directive 2019/882, that presumption requires a harmonised standard published for it (article 15): a new version of EN 301 549 is being prepared for that purpose.
In France: The two regimes coexist: the directive adds to the RGAA rather than replacing it. The RGAA covers the public sector and private companies whose turnover in France exceeds 250 million euros, averaged over the last three financial years, so a single organisation may fall under both, for different perimeters.

Sources: Directive (EU) 2019/882 (articles 2, 3, 4, 15 and 32), loi n° 2023-171, article 16, loi n° 2005-102, article 47, décret n° 2019-768 (French texts). This summary is provided for information and does not constitute legal advice.

// 02 · four situations

Four situations, four answers

Whether a document is written by hand, produced in series or has been published for ten years, the gesture is not the same, and the most common mistake is to apply one situation's answer to another. These four situations coexist in most organisations.

A1The single document, at source

A letter, a memo, a presentation, a spreadsheet. What is written by hand is fixed by hand, or better, built right from the first keystroke. Google Docs, Sheets and Slides, Word and PowerPoint all offer some assistance with tagging, reading order and text alternatives, but it often falls short: add-ons exist to cover what is missing. The right choice depends on usage and scale, and Purplsoft advises on both, for a single workstation and for an enterprise estate.

A2Expertise, when tooling falls short

A heterogeneous archive, a PDF produced by a scanner, a two-way table, a site whose structure nobody remembers: some cases cannot be handled with a click. They call for an audit, a diagnosis, then remediation carried out by someone who knows what a screen reader actually announces. That holds for websites, for a single document and for an entire archive alike.

A3Volume

Everything changes beyond a few hundred documents. Making accessible every file published on a site or an intranet, or an entire variable-data production run (statements, notices, invoices, payslips) is a matter of industrialisation: batch processing, in SaaS or on premise, integrated into the existing chain rather than bolted onto it. This is where our document-factory experience transposes directly.

A4Governance, in a large organisation

Past a certain size, the question stops being technical. Who deployed what? Are the licences handed out actually being used? How do you recharge autonomous entities, and how do you demonstrate progress from one year to the next? Without that visibility, a rollout stops at the first budget review, and this is precisely what market tooling handles least well.

// 03 · level of ambition

Conformant, or genuinely accessible?

// 04 · frequently asked

What we are asked most often

Is a PDF exported from Word or Google Docs accessible?

Rarely as it stands. The export keeps some of the structure (headings, often lists), but frequently loses the reading order of complex layouts, table headers and text alternatives. A careful export from a well-built document is a good starting point; it almost always needs checking, and sometimes reworking.

Does everything already published need to be made accessible?

No, and that is the first decision to make. Part of any archive is out of date, superseded or ready to be retired: processing it costs without returning anything. The inventory always precedes remediation: it separates what must be fixed, what can be withdrawn, and what will simply be replaced by a new version, produced accessible.

PDF/UA or WCAG: do you have to choose?

They answer different questions and complement each other. PDF/UA describes how a document must be built, and a machine can verify it. WCAG requires the content to be genuinely understandable, which is a matter of human judgement. Aiming for PDF/UA alone produces documents that are conformant but sometimes unusable; aiming for WCAG without PDF/UA gives up the only check that can be automated.

Can document accessibility be fully automated?

Tagging, reading order, table structure and metadata can largely be automated, and that is indispensable as soon as there is volume. What cannot be automated: deciding whether a text alternative genuinely describes the image, whether a heading hierarchy follows the document’s logic, whether a table still makes sense read left to right. Tooling absorbs the volume; it does not replace review.

Where do you start?

With an inventory and a measurement. Knowing how many documents are involved, where they come from, which are written by hand and which come out of an automated chain: that is what determines whether the answer is workstation tooling, an expert engagement, industrialisation, or all three. A plan built without that survey picks the wrong lever.