PDFs, menus and documents: the accessibility gap most websites miss

Many websites are reviewed page by page, while the documents linked from those pages are left out. Yet a menu, price list, intake form or policy is often the very thing a customer came for. This article covers the most common document problems and the practical ways to fix them.

Why documents are in scope

Manitoba's Accessible Information and Communication Standard Regulation, Man. Reg. 47/2022, requires web content to meet WCAG 2.1 Level AA if it was published on or after the applicable date or is needed to access the organization's goods or services (s. 7(1) (opens in a new tab)). For organizations with one or more employees in Manitoba, the date was May 1, 2025. A PDF menu, a booking form or a product guide linked from your website is generally part of that content. If customers need it, it needs to be accessible. Our page on the Manitoba standard summarizes the requirements.

Separately, s. 5 (opens in a new tab) requires organizations to let people know that information is available in accessible formats and with communication supports on request. That notice is useful, but it is not a substitute for making the documents customers rely on every day accessible in the first place.

The common problems

Scanned PDFs

A scanned document is a photograph of paper. To a screen reader, it is a picture with no words in it. The person hears nothing, or only "image". Text cannot be searched, copied, enlarged cleanly or reflowed on a phone. This is common with older forms, signed policies and printed brochures that were scanned and uploaded.

Image-only menus

Restaurants often post their menu as a JPEG or as a PDF exported from design software with the text converted to outlines. It may look good, but a screen reader user cannot read the dishes or prices. Someone with low vision who zooms in sees blurred text, and on a phone they have to pan back and forth to read each line. This fails 1.1.1 Non-text Content and 1.4.5 Images of Text, and usually 1.4.10 Reflow as well.

Untagged PDFs

A PDF can contain real text and still be inaccessible. Accessible PDFs have tags: an invisible structure that marks headings, paragraphs, lists, tables and images, much like HTML does on a web page. Without tags, a screen reader may read the text as one long stream, skip content, or read columns in the wrong order. Headings cannot be used to navigate, and tables lose their row and column relationships.

Wrong reading order

Even tagged PDFs can have a reading order that jumps around: a sidebar read in the middle of a paragraph, a footer read before the title, or a two-column layout read straight across both columns. This fails 1.3.2 Meaningful Sequence.

PDF forms

Fillable PDF forms often have fields with no labels, so a screen reader announces "edit text, edit text, edit text". Check boxes may have no names, the tab order may be random, and required fields may be shown only by colour.

Practical fixes

Publish an HTML version first

For most small businesses, the best fix is to put the content on a regular web page. A menu, price list, hours of service or policy is usually simpler to keep accessible as HTML than as a PDF. It also reflows on phones and is easier to update. If you still want a printable version, offer the PDF as an extra rather than the only option.

Turn online forms into web forms

Intake forms, quote requests and registration forms work best as web forms with proper labels, clear instructions and helpful error messages. That also makes it easier to meet 3.3.1, 3.3.2 and 3.3.3, and, for legal or financial submissions, 3.3.4 Error Prevention.

When a PDF is needed, make it a tagged PDF

• Start from an accessible source. Use real heading styles, list styles and table tools in your word processor or design software, then export with the option to create a tagged PDF.
• Replace scans with real text. Recreate the document from the source file where possible. Optical character recognition can help, but the result must be checked and corrected by a person.
• Set the document title and language in the document properties.
• Check and correct the reading order so it follows the logical sequence of the content.
• Mark up tables properly, with header cells identified.

Write alt text for images in documents

Photos, charts, maps and logos inside documents need alt text that serves the same purpose as the image, just as they do on a web page. Purely decorative images should be marked as artifacts so they are skipped. For a chart, give the key finding in the alt text and put the underlying figures in the document text or a table.

Check contrast and links

The contrast rules apply in documents too: 4.5:1 for normal text and 3:1 for large text. Links should have meaningful text, not a bare web address or "click here".

Test with real tools

Automated PDF checkers can confirm whether tags exist. They cannot tell you whether the reading order makes sense or whether alt text is useful. Reading the document with a screen reader such as NVDA or VoiceOver is the reliable check. Our method page describes how we test documents alongside web pages.

Where to start

1. Make a list of every document linked from your website.
2. Remove what is outdated. Old newsletters and expired forms are often easier to retire than to fix.
3. Prioritize documents customers need to access your goods or services: menus, price lists, forms, booking information.
4. Convert to HTML where you can, and produce tagged PDFs where you cannot.
5. Set a rule for new documents so the problem does not return. Training for whoever maintains web content is required under s. 4 (opens in a new tab) of the regulation.

Our services page explains what an audit and repair involve, and you can read about the industries we work with.

Talk to us

If your website relies on PDFs, menus or forms, we can review them alongside your pages and recommend the simplest way to make each one accessible. Book a consultation and we will provide a fixed written quote after the audit.

Last reviewed October 2026. General information, not legal advice.