PDF/UA featured in the 2015 Section 508 Refresh

The US Access Board today released its "proposed rule" via an NPRM (Notice of Public Rule Making) for the long-awaited update to the US Federal Government's "Section 508" requirements for electronic content and website accessibility. This rule-making is expected to be final or near-final.

As expected, the proposed text refreshing the old Section 508 language is oriented on WCAG 2.0. PDF/UA is nonetheless prominently featured; indeed, the ISO standard for accessible PDF technology is positioned, for the most part, as an alternative to WCAG 2.0.

The proposed Rule requires PDF/UA "where appropriate" in some cases, but the example provides makes clear the Board's intent:

The US Access Board says in V. Major Issues, A. Electronic content:

The central principle underlying the accessibility requirement for public-facing content is the notion that federal agencies must ensure equal access to electronic information that they themselves directly make available to the general public by posting on a public fora. So, for example, if a federal agency posts a PDF version of a recent settlement agreement on its website as part of a press release, that document would need to comply with PDF/UA-1. (Emphasis added)

In the Access Board's proposed text for the Section 508 refresh PDF/UA is referenced most significantly in the following places:

E205 Content

E205.2 Public Facing. Content that is public facing shall conform to the accessibility requirements specified in E205.4.

E205.3 Agency Official Communication. Content that is not public facing shall conform to the accessibility requirements specified in E205.4 when such content constitutes official business... [examples].

E205.4 Accessibility Standards. Content shall conform to Level A and Level AA Success Criteria and Conformance Requirements specified for Web pages in WCAG 2.0 (incorporated by reference in Chapter 1) or, where applicable, ISO 14289-1 (PDF/UA-1) (incorporated by reference in Chapter 1).

C203 Electronic content

C203.1 General. Regardless of the medium or the method of transmission and storage, electronic content integral to the use of ICT shall conform to Level A and Level AA Success Criteria and Conformance Requirements specified for Web pages in WCAG 2.0 (incorporated by reference in Chapter 1) or ISO 14289-1 (PDF/UA-1) (incorporated by reference in Chapter 1).

6 Support Documentation and Services

602.3 Electronic Support Documentation. Documentation in electronic format, including Web-based self-service support, shall conform to all Level A and Level AA Success Criteria and all Conformance Requirements in WCAG 2.0 (incorporated by reference in Chapter 1), or ISO 14289-1 (PDF/UA-1) (incorporated by reference in Chapter 1).

The PDF Association staff will produce a more extended analysis of the NPRM in due course.

The single-file version of the NPRM.