A common question at UWM and across other UW institutions is whether a PDF posted on the university’s website solely for the purpose of downloading and printing still needs to be digitally accessible. The guidance below answers this question based on current WCAG 2.1 AA and ADA Title II requirements.
Is PDF the Right Format?
First, confirm that PDF is the right format for publishing content. If the answer is yes, then use the following guidance to ensure you are publishing the PDF in a way that’s compliant with digital accessibility.
When a PDF is Downloadable from a Website, It is Considered Digital Content
Even if the document is designed for print and published only for the purpose of making it available to be downloaded and printed, the moment it is posted online for download, it becomes part of the university’s digital information environment. As a result, a downloadable PDF must meet WCAG 2.1 AA if it contains program, service or activity information that a user may rely on.
Exception: The PDF May Be Labeled as a “Print Version” Only if an Accessible Webpage Provides the Same Complete Information
If the full, accurate content is already available on an accessible webpage—and the PDF clearly points users to that webpage—you may also provide a print-formatted PDF for convenience.
In this scenario, compliance is achieved when all the following conditions are met:
- The webpage is a complete, accurate and fully accessible source of the information.
- The PDF is clearly labeled as a print-only version, not for digital distribution.
- Each PDF directs users to the webpage for accessible content.
- A contact is provided for users who request an accessible version of the PDF: “To request an accessible version or a reasonable accommodation due to disability, please email [insert email address]”.
If an accessible version of the PDF is created in response to an accommodation request, that accessible version should replace the original PDF and be maintained going forward.
Example text on the link:
Print Version (PDF for printing only, not for digital distribution; use the webpage for accessible content).
This labeling makes it clear that the PDF is optional and intended for print, while the webpage is the primary format for digital access.
Why This Matters Under WCAG 2.1 AA
WCAG requires that digital program information be perceivable, operable, understandable and robust.
- If a PDF contains any unique content or additional details not available on the webpage, the PDF itself must be fully accessible.
- If the webpage already includes the complete set of information, the PDF may be treated as supplemental print material.
Summary: Requirements for Downloadable PDFs Intended for Printing
To Stay Compliant:
- Ensure the program webpage is fully accessible and includes all required information.
- Mark the PDF as a “Print Version” and note that the webpage is the accessible source.
- If the PDF includes any information not contained on the webpage, then the PDF must be made accessible.
Alternative Option
An alternative option is to not publish the PDF on the website and instead have a list of print materials and an email contact so people can request the materials directly, and a note these are not digitally accessible and are for print only.