Managing Accessibility:
Why your vendors must provide accessible deliverables

Within the last week, 2 clients have submitted projects for us to review and make accessible. In both cases, the files were created by the clients’ outside vendors who submitted inaccessible digital files.

Should the vendors have provided accessible digital files to the clients?

This technical advisory helps you manage your organization's accessibility requirements.

The answer: Yes, contractors and vendors must supply accessible ICT deliverables.

Here’s why:

  • In these cases used as examples, US federal law requires accessibility because the files will be available to the public (aka, be public-facing) on US federal government websites.
  • The law also states that all ICT procured by federal agencies must be accessible.

1. The law

In the US, Section 508 governs the accessibility of all federal government digital information, called ICT or information communications technology. Section 508 states what must be accessible, but doesn’t say how to make ICT accessible. Like most regulations, it defines the final result and how it will be measured, not the method used to achieve the end result.

Section 508 mandates the accessibility of:

  • websites,
  • documents (word processing, spreadsheets, presentations, PDFs, EPUBs),
  • social media,
  • email,
  • 9 categories of internal agency ICT, mainly HR-related, and
  • other ICT defined in Section 508 or delineated at, the GSA’s website portal.

E205.2 Public Facing and E205.3 Agency Official Communication

— Section 508

Note that the US’s Section 508 applies only to US federal government ICT, not state or local government ICT, or commercial and private ICT..

Nothing prevents a government agency from requiring additional accessibility features, and the US Department of Health and Human Services (HHS) provides their policies and requirements on their public website. They are informally known as the HHS Guidelines.

State and local governments

Many states have adopted to follow the federal law and now require that state, county, and local ICT be accessible, including ICT used in education from public schools to state universities and colleges. See Policy & Management, State Policy.


The US has other federal legislation that requires equal access to education, such as ESSA (Every Student Succeeds Act) and IDEA (Individuals with Disabilities Education Act). Visit the US Department of Education's portal website to view these and other programs.

Although Section 508 doesn't directly specify accessibility in educational ICT, the standards referenced in Section 508 are used by educational regulations to evaluate whether textbooks, class handouts, forms, tests, and online learning systems are compliant. The most commonly used standards are WCAG and PDF/UA described below.

Outside the US

Other countries have adopted similar laws, some including commercial ICT as well as government:

  • European Union — EN 301 549
  • Ontario, Canada — Accessibility for Ontarians with Disabilities Act (AODA)
  • Canada — Accessible Canada Act
  • United Kingdom — Equality Act
  • Australia — Disability Discrimination Act (DDA)
  • And others listed at Countries / Regions

2. Federal contractors and vendors are covered

GSA (Government Services Agency) states clearly that any ICT developed by a US federal agency, developed by an outside contractor on the agency’s behalf, or procured by the agency must comply with Section 508.

GSA gives excellent guidance on how federal contracts are covered at

"All technology your agency buys, builds, maintains or uses, including software, hardware, electronic content, and support documentation and services, must conform to the Revised 508 Standards."

— cited from GSA

Contractors and vendors include companies or individuals that provide services or products for the agency, such as research firms, consultants, accountants, auditors, graphic designers, writers/editors, architects, engineers, trainers, and IT technicians.

In the 2 examples that came across my desk this week, one was from an auditing firm that provided their findings in an inaccessible PDF to the agency. The agency combined that PDF into a longer report written by agency staff, all of which is public-facing on the agency’s website.

The second example was a series of PDFs developed by a major university under a grant from a federal agency to provide services to the general population. All documents created under the grant are the property of the federal agency and are available on the agency’s website, too.

Regardless of who created the content, the final published version will reside on a US federal website and, therefore, must be fully accessible.

Nongovernment work is exempted

It's important to note that any ICT created by a contractor that is outside the government contract is not required to be accessible, such as the contractor's other non-government projects, marketing materials, and internal ICT.

E202.4 Federal Contracts
ICT acquired by a contractor incidental to a contract shall not be required to conform to the Revised 508 Standards.

— cited from Section 508

3. Costs can be insane

We’ll look at the two examples on my desk. They showcase what goes wrong when vendors and contractors aren’t required to supply accessible files.

In the first one, an outside auditors’ report in PDF format, the project was well written, very informative, and nicely designed. But it wasn’t accessible at all, and because of its complex design and construction, was a hot mess to remediate into compliance.

  • “Hot mess” is our polite term to describe atrocious code in a file that is a royal PITA to correct into compliance.
  • “PITA” — pain in the “anatomy” — was coined by my long-time co-trainer at GPO, Les Greenberg, for polite use in government classes.

The accessibility tasks — which should have been completed by the contractor as they created their original report — now had to be fixed after-the-fact at an additional cost to the agency.

It takes longer to fix a bad PDF than it does to make it accessible from the start.

The second project is a 100+ page PDF created from a graphic design layout in an ancient version of Adobe InDesign. Again, well-written and a very nice design, but totally inaccessible. It’s very difficult to remediate this PDF because of its complex visual design, the way it was constructed by the designer, and the bugs the old version of InDesign built into the PDF.

Adobe InDesign can be the most powerful and sophisticated program to create accessible PDFs — IF the designer is trained in how to use it for accessible documents, and IF they use current software.

Neither of those 2 IFs were evident in this file, making it a Carolina-Reaper-hot mess. The problems in this file are so severe and complex that we’ll have to rebuild the original InDesign layout and re-export a new, nearly compliant PDF from the revised layout. We’ll need to maintain the original design, even down to the line and hyphenation breaks, page breaks, and white space so that it matches the original file. That’s a lot of labor.

It probably will cost more to fix this file than it cost to originally build it.

4. How to foster sanity … and retain your budget

Better planning and tighter contract language could have prevented the problems and additional costs in these 2 examples.

If your department or agency hires outside vendors, then work with your contracting office to tighten up your contract language and RFQs.

GSA’s website has excellent guidance on clauses to include in your initial RFQs and finalized contracts.

Note: Most of Section 508 refers to the WCAG standard (Web Content Accessibility Guidelines) as the benchmark for meeting accessibility requirements.

However, the PDF/UA standard is also in the Section 508 law and is recommended for document files because it specifies features that are only in documents, but not in websites. Here are 2 references from the US Access Board:

"PDF/UA is required (as an option) for software that can create ‘modern and good’ PDFs."

—Bruce Bailey
Accessibility IT specialist at the US Access Board
as quoted by the PDF Association

Ensure your contracts cite the correct accessibility standard for the projects you are outsourcing.

5. Which standard to reference in your RFQs and contracts

Our recommendations are:

  • If the deliverables are HTML products (websites and online forms), they must meet WCAG 2.1 AA (at this time).
  • If the deliverables are PDF files, they must meet the PDF/UA-1 standard (ISO 14289).
  • If they are EPUB files, the law at this time doesn’t require a specific standard. We recommend the EPUB 3.2 standard, which was developed to harmonize with WCAG while addressing EPUB's unique features.
  • And if the deliverables include the native source files from MS Word, Excel, PowerPoint, or Adobe InDesign, then we recommend using PDF/UA because there is no standard for these file types at this time, and PDF/UA is a good, practical standard for accessible documents, regardless of the file format.

“Too often I see WCAG being used for PDF document files. Using WCAG for PDFs is like forcing a square peg in a round hole. Although WCAG claims to be ‘technology neutral,’ that catchy phrase applies only to HTML technologies, not other types of document files. WCAG can’t address all the features of a PDF and produces only a barely accessible PDF. Let's do better than that! Use PDF/UA for PDFs and fill in the gaps with WCAG.”

—Bevi Chagnon
Accessibility specialist ADS,
and director of accessibility services at

6. What PubCom uses and teaches

In our classes, we use the PDF/UA-1 standard with a little bit of WCAG to shore up some of the standard’s shortcomings.

We also include some additional accessibility features that make the file more easily used by most assistive technologies (AT) and provides a better experience for all users, whether they use AT or conventional computers, tablets, and mobile devices.

Our approach is to create a fully accessible file right from the start that require little or no remediation afterwards — Born Accessible, is the current catch-phrase.

Our goal is to minimize the cost of making accessible document files.

7. Accessibility briefing for managers

Throughout the year, we hold a short but in-depth high-level briefing to guide managers on building accessibility into their organization’s workflow. It covers:

  • Build accessibility within the agency: staffing, training, workflow, legal requirements,
  • Manage accessibility in contracts and grants to outside vendors and recipients,
  • Set up quality assurance checking of ITC created by in-house staff and outside contractors.

Check our online calendar for the next webinar.

PubCom's accessibility training

PubCom has a full array of courses on accessibility topics, as well as traditional desktop publishing, digital media, and website development. We started offering accessibility training to the federal government in 2001 right after Section 508 went into effect.

Sign up for our upcoming classes or we can bring a custom curriculum to your agency that can train your writers, editors, desktop publishers, and webmasters.

We’re committed to making documents accessible for the nearly 35% of our fellow citizens who have disabilities that make it difficult for them to use computer technologies.

We teach how to make your documents accessible.

We teach how to fish!



Untitled Document

Logo, Pub Com dot com.

Learn to fish. Save money. Time. Hassle.

Our services help you maximize your technology, streamline your workflow, and seamlessly build accessibility into your digital publications. Our mission is to train and coach you so well that you no longer need us or outside remediation services.

By teaching you how to fish — and make accessible PDFs right out of the box — we hope to work ourselves out of our jobs!

PubCom has a full suite of courses on accessibility topics, as well as traditional desktop publishing, digital media, and website development. We started offering accessibility training to the federal government in 2001 right after Section 508 and WCAG 1.0 went into effect in the US. That was 23+ years ago and we haven't stopped yet!

The takeaway: we know publishing, from editorial to design to distribution (print and digital) — and we're accessibility experts (Bevi Chagnon is a delegate to the ISO committee for PDF accessibility that creates the PDF/UA standard). We share our knowledge and help you learn to fish. Our little fisherman keeps us on our goal.

Sketch: Our fisherman has learned to fish and is now inclusive and accessible.

""Drop us a line and let us know how we can help.