Writing an accessibility statement. Which files are unlikely to be WCAG 2.2 AA compliant?

When you are writing your accessibility statement, you are required to list the non-accessible content on your website. These are the files or content where there are accessibility issues but the council is either not able or is not required to fix them.

Scanned PDFs

One of the most common accessibility issues on parish council websites is the use of scanned documents. This often happens when a paper document is scanned and uploaded directly to the website as PDF file.

Although the document may look normal to someone reading it visually, a screen reader cannot usually interpret text that is embedded in an image. This means users with visual impairments may not be able to access the content at all.

Scanned PDFs often fail accessibility requirements because:

  • Text cannot be selected or searched
  • Screen readers cannot recognise the content
  • Reading order is unclear or missing
  • Text quality may be poor or blurry when enlarged

For example, AGAR documents, Councillor’s Register of Interests and very often published as scanned documents.

What you should do

AGAR documents are required to be published as scanned documents, which are not accessible. You need to be able to provide the information in an alternative format, if requested, and you should include information in your Accessibility statement about how visitors can request the information in an alternative format. Other documents such as Councillor’s register of interests could be provided as Word documents for Councillors to fill in. These documents could then be saved as PDF and published online. This would be more accessible that completing by hand and then scanned. If you need to publish them as scanned docents, you should be prepared to provide them in alternative formats, if requested.

Image-Based Notices and Posters

Some councils upload event notices, or public announcements as image files such as JPEGs or PNGs. While visually attractive, these files often fail accessibility standards if they contain important information as text within an image.

Problems include:

  • Text cannot be read by screen readers
  • Content cannot easily be resized
  • Images may become difficult to read when zoomed
  • Users cannot copy or search the text

What you should do

Where important information is published as an image, councils should provide an accessible text alternative. This is usually done by simply writing out the text in the image, below it, as part of the web page text.

Older Documents published before 2018

Some older documents on parish council websites may be exempt from accessibility regulations if they were published before September 2018. However, if residents still need the document for an active purpose, it should still be made accessible.

This may include:

  • Current policies
  • Governance documents
  • Application forms
  • Financial reports
  • Consultation materials