UK public sector PDFs: the 2018 regulations, the 23 September 2018 cutoff, WCAG 2.2, and the accessibility statement

The UK's public sector accessibility regulations are older than the American rules, cover every public body from central government to parish councils and NHS trusts, and have a specific answer to the question every records team asks: what about our old PDFs? This guide sets out the regulations as they stand in 2026, the document exemption and its limit, the monitoring and enforcement arrangements, and the format advice from GOV.UK that most affects how documents should be published.

The regulations

The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (SI 2018/852) implemented the EU Web Accessibility Directive in UK law and were retained after the UK left the EU. They came into force for public sector bodies on 23 September 2018. GOV.UK's guidance summarises the duty as making a website or mobile app "perceivable, operable, understandable and robust", which in practice means meeting the WCAG 2.2 AA standard, and publishing an accessibility statement that explains how accessible the site is and is reviewed regularly. Monitoring moved from WCAG 2.1 to WCAG 2.2 in October 2024, which makes the UK the regime in this series that names the current WCAG version.

Documents and the 23 September 2018 cutoff

GOV.UK lists among the content that does not have to meet the requirements "PDFs or other documents published before 23 September 2018, unless users need them to use a service, for example a form that lets you request school meal preferences". The regulation itself frames the limit as content needed for active administrative processes relating to the body's tasks. Read together, the exemption is narrow: a 2016 committee report kept for the record is exempt; a 2016 application form, fee schedule, or set of instructions that a resident still needs is not, and neither is anything published or updated since September 2018. Intranet and extranet documents follow a similar pattern with a 2019 cutoff, and the regulations exclude some content types (such as pre-recorded media published before the date and some third-party content), but a document a member of the public needs today is in scope whatever its date.

Publish HTML where you can

GOV.UK's guidance on meeting the regulations is unusually direct about format: content published in document form can be made accessible by converting the document into accessible HTML or by making the document itself accessible, and "if using a document can be avoided, the information should be presented as HTML content on a web page", whether as text, a web form, an online map, or a combination. That is also the approach GOV.UK itself takes. For a public body, the practical policy is that new information goes out as HTML, existing documents that people still need are remediated or converted, and documents are published as PDF only where the fixed page is genuinely necessary. DocAccessible's remediation options page describes the same two outputs: hosted accessible HTML and a remediated PDF.

The accessibility statement and documents

The accessibility statement must say how accessible the site is, which content is not accessible and why, and how to request an accessible alternative. Documents are usually the largest item in it. A statement that says "our older PDFs are not accessible" is acceptable only where the exemption genuinely applies; for documents in scope, the statement should record the plan and date for fixing them. Keeping a live inventory of what is published is the only way to keep that section honest; the free website PDF scanner lists the PDFs a public website links to, and website PDF monitoring keeps the inventory current.

Monitoring and enforcement

GOV.UK states that the Government Digital Service monitors public sector bodies' compliance on behalf of the Minister for the Cabinet Office, and that the Equality and Human Rights Commission in England, Scotland, and Wales and the Equality Commission for Northern Ireland enforce the requirement. GDS monitoring involves sampling sites, reporting issues to the body, and requiring fixes; enforcement action can follow from the commissions under the Equality Act 2010 or the Disability Discrimination Act 1995 in Northern Ireland. In practice, an inaccessible form that prevents someone using a service is also a reasonable-adjustment matter under equality law, independent of the regulations.

What to do with a document estate

1. Inventory every published document and note its publication date and whether anyone needs it to use a service.
2. Treat anything needed for a service as in scope regardless of date and fix it first; forms are the priority, and the PDF forms guide explains what a fillable form needs.
3. Convert information that does not need to be a document into HTML pages.
4. Remediate or replace the remaining in-scope documents to WCAG 2.2 AA; the WCAG 2.2 AA document checklist maps the criteria to document failure patterns.
5. Record what remains inaccessible and why in the accessibility statement, with a date, and provide alternatives on request.

Frequently asked questions

Sources

The statements above rest on the primary sources below. Where a source is a law or standard, the version and date named in the text are the ones checked on the review date. This guide is general information, not legal advice.

1. GOV.UK: Understanding accessibility requirements for public sector bodies . WCAG 2.2 AA, the document exemption wording, the accessibility statement, GDS monitoring, and the enforcement bodies.
2. GOV.UK: Meet the requirements of equality and accessibility regulations . The advice to present information as HTML where a document can be avoided.
3. legislation.gov.uk: The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018