The European Accessibility Act (Directive (EU) 2019/882) entered into force on 28 June 2025 and applies to public-facing PDFs the same conformance expectations it applies to web pages. The PDF estate that most enterprises ship by the thousand, white papers, datasheets, regulatory filings, contracts, training materials, is the surface most regulators will look at first.
Penalties run from approximately ten thousand euros for minor violations to one hundred thousand euros or more for major or repeated non-compliance, with significantly higher figures available against large enterprises. The numbers vary by member state; the obligation does not.
What the EAA Asks For
The act asks public-facing PDFs to be accessible to users with disabilities. In practice the conformance baseline is ISO 14289-1 (PDF/UA), the international tagged-PDF standard. A conformant document carries:
- A complete structure tree (paragraphs, headings, lists, tables, figures all properly tagged).
- An explicit language declaration and document title.
- Alt text on every figure and decorative image marked as artefact.
- A reading order that matches the visual order.
- A declared
accessibilityConformanceclaim the publisher can defend. - An XMP packet recording the conformance level (PDF/UA-1 Part 1 / Level 2 today).
Most PDFs in the wild carry none of these. They are byte streams with structure only the original author could reconstruct.
What We Deliver
Three engagement shapes, sized to your estate.
Triage Audit
From £3,000. A representative subset of your PDF estate runs through our automated audit pipeline plus human review. The deliverable is a written report covering ISO 14289-1 tagged structure, MX metadata presence, AI-governance provenance, and per-document Level 1, Level 2, and Level 3 conformance findings. You leave the engagement with a ranked remediation plan and a credible internal case for prioritising the work.
Remediation Engagement
From £15,000. A representative subset of your estate is remediated to Level 3 conformance by our team. We tag the structure, declare the conformance, and record the check trail. The engagement includes training so your team can do the same for the residual estate; the methodology and the toolchain stay with you, not with us.
PDF Car Wash (Retained Service)
From £2,000 per quarter. A retained service that wraps an automation pipeline (Adobe Acrobat Pro guided actions, Adobe AutoTag API, or equivalent low-code orchestration via Microsoft Power Automate or SharePoint flows) around your publishing workflow so newly-created PDFs are tagged before they reach the public site. The pipeline runs on your infrastructure; we operate it, monitor it, and report on it.
The MX Document Accessibility Note
The discipline behind every engagement is the MX Document Accessibility note, the open-standard specification we authored and contribute through The Gathering. The note makes the remediation auditable: tag the structure, declare the conformance, record the check. A document that carries the MX Document Accessibility metadata can be checked by any verifier; you do not have to trust the publisher.
Reading: Tagged PDFs are MX (blog), PDF Inspector tool (drag any PDF onto the public inspector to see what the EAA verifier would see).
Honest Limits
This service does not grant compliance with the EAA or any other regulation. Compliance remains a legal duty of the publisher. What the service helps with is the documentation: tagged, conformance-declared, independently-verifiable PDFs and the check trail an auditor expects to see. The commercial position is symmetrical with the legal position; the service is sold as a remediation and documentation discipline, never as a compliance grant.
Next Step
If you publish PDFs to a European audience, the EAA already applies. Tell us about your estate and the timeline you are working against; we will reply with a triage scope and a price within two working days.
The contact form routes EAA enquiries to me directly. If you would rather email, info@cognovamx.com reaches the same inbox.