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NewFormat AB

PDF standards make the world work




NewFormat makes PDF information permanently
accessible, searchable, readable and reusable
for the future and for as many people as possible.

We leave no file behind.

We create accessible PDF in compliance with the ISO Standard PDF/UA.


Our solutions are based on
recognized ISO Standards based on PDF technology
and tested, reliable, and highly accessible software solutions from
the PDF Association vendor community.




Accessibility - Icon

Accessible PDF


A fully PDF/UA compliant PDF can be just as
accessible as a WCAG compliant website



PDF/UA - Icon

Accessible PDF


    The ISO Standard PDF/UA for "Universally Accessible PDF Documents"
    is THE prerequisite in making PDF document digitally accessible.

    In case you are not already familiar with PDF/UA and why it matters,
    then welcome to learn the basics:






Warning - Icon

Inaccessible PDF Documents
May Constitute Discrimination


    It is now more than 6 years since
    the Swedish Act on Accessibility to Digital Public Services
    (also known as "DOS-lagen" / "DOS Act") was passed
    by the Swedish Parliament (2018).

    It is therefore high time to evaluate and publicly report
    on how well the public authorities and businesses concerned
    are copying with the requirements of the Act.

    Digital public services can consist of a digital government service
    that is provided for private individuals/citizens to take advantage of;
    example: websites and apps of concerned public actors,
    as well as digital documents published by such service.


    We/NewFormat AB have therefore chosen to audit and report
    below on how well PDF documents published on public websites'
    are designed and published as digitally accessible PDF documents.


    Other reviewers have chosen to publish "top lists"
    of how well Swedish government websites and apps
    are provided as digitally accessible.

    However, it appears that these top lists only show
    the accessibility status of the websites' HTML-based content
    and completely omit the websites' document-based content.

    Which does not give a completely accurate picture
    as it gives the websites' principals the impression that
    everything is fine and dandy and that their websites
    fully support the accessibility requirements
    according to the DOS Act.


    Our audit is probably the most comprehensive review
    conducted in Sweden on how well Sweden's concerned
    public authorities/actors care about complying with
    current accessibility laws for digital documents.

    Since 2018, we have continuously reviewed public PDF documents
    with regard to how well the documents meet the requirements to be
    designed and published as digitally accessible PDF documents.

    We have downloaded and reviewed completely normal and ordinary
    operational documents, a total of about 3000 PDF documents,
    from the websites of about 250 Swedish authorities, including:

    • Riksdag
      (The Swedish Parliament, the highest national body,
      a political assembly of elected members)

    • Government / Government Offices / Prime Minister's Office

    • Courts

    • Administrative Authorities

    • Regional and Local/Municipal Authorities

    As a minor part of the review,
    it also includes PDF documents published by
    entities within the European Union (EU),
    the Swedish private industry, Swedish political parties,
    as well as by organizations that work for full participation and equality
    in society for individuals with disabilities and/or special needs
    (precisely the human individuals that the DOS Act aims to protect).




Warning - Icon

    First a look back:
    The DOS Act aims to counteract discrimination

    Access to digital public information is a fundamental right for everyone.

    Barriers that prevent interaction with, or access to a digital services
    by people with disabilities can be considered discrimination.

    The EU Web Accessibility Directive (2016) ensures that all users,
    regardless of functional ability, have equal access to
    information and functionality on the web; implemented as
    "The Swedish Act 2019 on Access to Digital Public Services"
    also know as "DOS-lagen / the DOS Act".


    The DOS Act contains provisions on accessibility requirements
    for digital services provided by a public actor.
    A public actor refers to a state or municipal authority
    or a decision-making assembly in a municipality or region.

    Digital service can be a digital government service
    that is provided for private individuals to take advantage of;
    example: websites and apps of concerned public actors,
    as well as digital documents published via such service.


    The Swedish Agency for Digital Government (DIGG)
    is the government-appointed supervisory authority for
    compliance with the DOS Act by Swedish public authorities.

    On its website, www.digg.se, DIGG has specifically clarified that
    "Documents published on public sector websites and
    other digital services shall be accessible.
    These include, for example, forms in PDF format,
    Word documents or similar".

    This also includes digital services that automatically create
    digital documents that are in turn distributed/sent by email
    directly to a private individual's email inbox;
    for example: PDF-based invoices from public authorities.


    Websites hosting inaccessible documents can be a
    a significant liability risk even if the website owner
    has fixed the websites's HTML content.

    Ensuring that digital documents are accessible for everyone
    is not just a good idea:
    it is in fact completely in accordance with current law.


    The DOS Act aims to counteract discrimination.
    Public authorities have a special responsibility
    to comply with the law.

    Authorities are obliged to acquire the necessary knowledge.

    This is not something that Swedish authorities
    can choose to do or not do.

    The option to just opt out of publishing
    digitally accessible documents does not exist!


    An authority that provides inaccessible digital information
    thus withholds information intended for all citizens
    from reaching out precisely to all citizens;
    which in itself may constitute a form of discrimination.

    It can also be a form of defiance of the law.

    Should it be like that?!

    It doesn't have to be like that!





Warning - Icon

Every year Swedish authorities publish millions
inaccessible PDF documents on their public websites

Common business documents
that unfortunately are not digitally accessible for everyone!

It probably violates
the Swedish Act on Accessibility to Digital Public Services


    The Swedish public sector alone publishes
    every year millions of PDF documents.

    Digital PDF documents occupy a large proportion of
    the amount of information on the authorities' websites
    for public digital service.

    Unfortunately, even today, too many of these documents are
    designed and published as digitally inaccessible PDF documents.
    Thus, they are completely unusable for the intended user group!


    According to the requirements of
    the Swedish Act on Accessibility to Digital Public Services,
    all published content on public websites must be published
    in such a form that it is digitally accessible to everyone.
    This applies to both HTML-based content, documents and
    presentation slides.

    The following dates apply to complying with the requirements:

    • New websites: September 23, 2019

    • Existing websites: September 23, 2020,

    • Mobile applications: June 23, 2021

    Above legal requirements have now been
    in force for almost 6 years.
    Despite this fact,
    they are not being complied with
    by concerned Swedish authorities.


    To be considered digitally accessible, websites, documents and apps
    need to be based on the principle of universal design and on
    internationally recognized accessibility standards.
    This ensures that as many people as possible can use, access,
    understand and act on digital information on their own,
    i.e. without the help of outsiders.

    For a PDF to be considered digitally accessible
    it shall at least be compliant with:


    Authorities, and other entities that cooperate with the public sector,
    and who do not yet publish their digital PDF documents as accessible PDF
    shall immediately start the necessary accessibility work.

    How far a business has come in its accessibility work
    is easy to find out with this simple rule of thumb:

    • If the business' s perhaps most important document,
      the own annual report(!) is designed, distributed and
      published as digitally inaccessible PDF, it is a clear indication
      that all of the business's other PDF documents are also
      published as inaccessible PDF.


    • As a first immediate action, we recommend that at least
      the own annual report is immediately created, distributed and
      published in the form of digitally accessible PDF.

    • (Note:
      When mandatory laws affect an authority in the public sector,
      the authority's management is the primary recipient.
      Based on its overall responsibility for the entire operation,
      it shall ensure that new laws are implemented and all operations
      that are affected are managed through the change.

      When a government agency's management does not understand that
      they have received a new set of regulations, in this case the DOS Act,
      that ultimately applies to them and what changes they need to make
      in their operations with new overall policies and guidelines,
      the government agency's management is to blame.


      All information in an authority's annual report
      shall have been quality assured at several levels,
      from head of department to director general.
      Before it is submitted,
      it is signed by the entire board of the authority,
      who on honor and conscience “certifies that
      the annual report provides a fair picture of
      the authority's results".

      Because the annual report is also published on
      the authority's website and on the website of
      the responsible ministry,
      it shall also according to Swedish law,
      "Act on accessibility to digital public services",
      be published in a format so that it is accessible to all.
      If not, the director general of the authority and
      the board shall be held responsible.)





Common errors in digitally inaccessible PDF documents

Warning - Icon

PDF/UA Foundation, PAC PDF/UA-1 kontroll, Fel, Denna fil är uppfyller inte PDF/UA-1 , Ej tillgänglig PDF - Banner

PDF/UA Foundation, PAC WCAG 2.1 AA kontroll, Denna fil är uppfyller inte WCAG 2.1 AA, Ej tillgänglig PDF - Banner

Compliance with the ISO standard PDF/UA
is a prerequisite for digital PDF documents
to be digitally accessible for everyone


    When a PDF document meets the ISO Standard PDF/UA for
    universally accessible PDF, it is a clear confirmation that
    the PDF document meets high standards for digital accessibility.

    PDF/UA defines the technical requirements that
    must be considered in order for PDF documents
    to be accessible to everyone in the society;
    with or without functional variation.

    The PDF/UA standard specifies HOW concerned PDF content
    (such as semantic content, text content, images,
    form fields, comments, bookmarks, and metadata)
    shall be used in PDF/UA compliant documents.

    Properly tagged ("well-tagged") PDFs are essential and
    a prerequisite for accessibility so that screen reader devices
    for visually impaired people or reading software for
    users with learning disabilities can provide
    rich access to a PDF’s content.

    PDF tags are also an effective method to improve
    Search Engine Optimization (SEO).

    Even automated extraction of information/text content from
    PDF documents is easier to execute with well-tagged PDF:


    A digitally accessible PDF document must be correctly tagged with
    specific structural tags to enable users with technical assistance needs
    to be able to navigate the document and access its content,
    without having to request assistance from outsiders.

    If these tags are missing, or if they are not correctly set according to
    the ISO standard PDF/UA, the technical aid will not work and
    the PDF document will remain a digitally inaccessible PDF document
    - thus a completely unusable PDF document for all users.


    Common tagging errors in digitally inaccessible PDF document:

    • The PDF document is completely untagged

    • Objects are missing tags

    • Incorrect main language specified, or not specified

    • Text objects in a language other than
      the main language not correctly tagged

    • Document lacks a title

    • First introductory heading is not tagged as "H1"

    • Skipped heading levels
      (e.g.: H1 is followed by H4, instead of H1, H2, H3, H4)

    • Incorrect tag specified as a structure element

    • Document content is neither tagged as
      real information content nor as decorative content

    • Incorrect reading order and navigation (due to incorrect tagging)
    • Incorrect use of structure elements for mathematical formulas

    • Heading cells in tables lack associated subcells

    • Irregular tables
    • Images, figures and graphic elements lack alternative text

    • Boundary frame / Bounding box for a figure element is missing

    • Comments / Annotations lack alternative description

    • Links without descriptive text

    • Used character sets ("fonts") omitted / not embedded

    • Specified characters cannot be mapped to Unicode characters

    • PDF/UA identity flag missing or incorrectly specified



PDF/UA - Icon

Accessible PDF
Easy to validate PDF documents for PDF/UA compliance


    PDF documents can be easily tested/verified against how well they
    comply with the ISO standard 14289, PDF/UA, for accessible PDF.

    A reliable compliance test for the ISO Standard PDF/UA
    always requires at least two stages of validation:

    1. a programmatic syntactic test, which can be performed by a piece of software, and

    2. an interactive semantic test, manually carried out by a human.

    Syntactic compliance of PDF documents with PDF/UA,
    can be checked with several reliable testing tools.
    We always recommend the use of more than one testing tool,
    for example:


    In case your PDF document does not pass the PDF/UA validation:

    • Do not publish the document on public facing websites.
      Do not accept the document, return it to responsible instance
      for remediation - Re-do it, do it right!


    Interesting?




Warning - Icon

    Disappointing Audit Results
    Swedish public authorities don't care about complying with the DOS Act

    The results of the review are unfortunately very disappointing.
    It is not possible to use the term "top lists" here as
    the public websites of the actors/authorities concerned are de facto
    completely flooded with digitally inaccessible PDF documents.

    Regardless of the level examined, EU level or Swedish level,
    the most important public services quite unabashedly publish
    large amounts of inaccessible PDF documents on their websites.

    Among them, these stand out:
    the European Parliament,
    the European Council and the Commission, AccessibleEU,
    the Swedish Parliament, the Prime Minister's Office, ministries,
    administrative authorities, and Swedish regional and municipal authorities.

    Just as if the EU Web Accessibility Directive and
    the Swedish Digital Public Service Accessibility Act
    do not apply to them.

    The gap between the EU Web Accessibility Directive / Swedish DOS Act
    and reality is therefore enormous!

    Our opinion is that the actors concerned are
    clearly not complying with the DOS Act.


    It is particularly noteworthy that
    The Swedish Agency for Digital Government (DIGG),
    despite its special mission as the chartered supervisory authority
    for compliance with the DOS Act by Swedish public authorities,
    publishes large amounts of digitally inaccessible PDF documents on its website!

    Our audit indicates that the Swedish Agency for Digital Government,
    does not adequately perform its supervisory mission over the DOS Act!


    Worthy of surprise:
    The following important PDF publications,
    which constitute the very foundation within the EU and Sweden
    for digital accessibility for all, are produced and published
    as digitally inaccessible PDF documents:

    and corresponding Swedish Acts:


    It is reasonable that these central documents, which focus precisely on
    "accessibility for all individuals to digital information,
    public services, products and services", should have been designed and
    published as digitally accessible PDF documents according to the
    globally accepted ISO Standard PDF/UA for universally accessible PDF;
    PDF/UA has been an ISO Standard since 2012.

    It is astonishing that neither at the highest EU level nor at the highest
    Swedish level understand the meaning of adopted accessibility directives/laws
    nor the expectations of the outside world that these comprehensive instances
    themselves act and set an example when it comes to providing
    digital documents that should be accessible to everyone!




Pagragraf-tecken - Ikon

Who is responsible for the fact that
the concerned public authorities and businesses do not comply with
the Swedish act on accessibility to digital public services,
and demands for immediate actions

Extremely doubtful whether
the Swedish Agency for Digital Government (DIGG)
is carrying out its oversight mission over the DOS Act satisfactorily!


    Digitization means inclusion and accessibility.

    It has been more than 6 years since
    the Swedish Act on Accessibility to Digital Public Services
    was adopted by the Swedish Parliament (2018).


    Based on the large amount of public government documents
    that we have reviewed, we can confidently state:

    • The review clearly shows that concerned
      Swedish public authorities completely ignore
      the Swedish act on accessibility to digital public services
      for digital documents.


    • The Swedish Agency for Digital Government (DIGG),
      supervisory authority for compliance with the DOS Act
      by Swedish public authorities,
      lacks the ability to adequately perform its supervisory task;
      also confirmed in DIGG's annual report 2023,
      and in the Analysis Report of DIGG, 2023, by Statskontoret
      (The Swedish Agency for Public Management).


    • It's time for accountability:
      Authorities affected must comply with
      the requirements of the DOS Act.


    6 years is a long time.

    Our authorities have had plenty of time to adapt their operations
    and implement the necessary relevant quality assurance measures
    that ensure that the authorities' digital communication meets
    the applicable legal requirements for public websites and other channels,
    i.e. that the services/websites and the information published there
    shall be provided as digitally accessible.

    Why are authorities and businesses covered by the DOS Act
    allowed, year after year, to provide digitally inaccessible
    websites, government documents and apps?

    • Why does no one care?

    • Who is responsible?

    • Where is the accountability?

    • Who should be held accountable?


    Hardly a question of lack of resources.

    The public sector has large resources
    available for its accessibility work.

    According to the report of Statskontoret
    (The Swedish Agency for Public Management)
    "State Administration in Brief", 2024-06-14, on January 1, 2024,
    (unfortunately also report is published as an inaccessible PDF)
    only under the Swedish government there were:

    • 367 authorities/agencies

    • with a total of approximately 257000 annual workforce

    A not entirely insignificant resource to involve in the government's
    accessibility work (that also includes accessibility validation of
    all digital documents before they are shared or published).

    With these large resources behind them, it is surprising that
    the websites, apps and digital documents of the affected actors
    still do not comply with the DOS Act.


    Nor is it a lack of budget, prioritization of other tasks,
    lack of time, lack of competence,...

    The possibility for authorities to invoke "undue burdensome adaptation"
    as a reason to justify exceptions from making websites, documents and
    apps accessible is too tempting for many.

    However, it is a clear exception provision that
    can only/should be invoked with great restraint.
    Unreasonably burdensome adaptation cannot therefore be invoked year after year:

    • "Lack of priorities, lack of time or lack of competence
      are not grounds for unreasonably burdensome adaptation".


    Different treatment can constitute a form of discrimination.

    Authorities that are not yet able to meet the DOS Act's requirements
    to provide digitally accessible PDF documents are often trying to
    "cut corners" on the DOS Act by urging users on their website to:

    • "Click here to print the PDF document"

    • "Contact us for an accessible PDF"

    Which raises the following questions:

    • Why should users who need to use
      assistive technologies to read/access
      the information in the authority's PDF document:

      • first print the PDF document on paper?

      • be forced to queue (for an unspecified period of time)
        to wait for the authority to provide the desired document
        in the form of a digitally accessible PDF document?

      • how should the user then be able to act if the authority document
        relates to a matter where the user is asked to immediately respond
        or confirm an appointment?


    Accessibility statement.

    Actors and others covered by the DOS Act must also
    provide a mandatory accessibility statement.
    In this statement, the actor must explain which parts of
    the website's content and functions are not accessible
    and where improvements are still needed to meet
    he DOS Act's requirements for digital accessibility.

    However, these accessibility statements are all too often misused
    by covering up ("accessibility washing?") the inability of the authority to
    take adequate measures to comply with the DOS Act.

    It is given the appearance that they are actively working on
    the "challenge" and that the website will soon comply
    with the DOS Act's requirements.

    The problem with this is that they write this in their
    accessibility statements, not just once, but year after year,
    and without DIGG intervening.

    A clear credibility problem for the authorities concerned,
    and above all for the supervisory authority, DIGG,
    the ability to carry out its mission.



    Reporting an authority that does not comply with the DOS Act.

    According to the DOS Act, users have the opportunity to report a
    public actor/authority that they believe does not comply with
    the DOS Act's requirements.

    One reason may be that the reporter believes that the website
    violates the DOS Act; i.e. that the authority is probably committing a crime.
    The report can be made to the legally responsible person,
    i.e. to the Director General of the Authority, via the authority's Registrar.

    Since the Director General / Head of Authority is the only official within
    the authority who is legally responsible for the authority's operations,
    it is reasonable that a report of a suspected crime should be answered in a
    transparent manner by the responsible Director General / Head of Authority.

    Ideally as a public statement about why the head of authority has
    deliberately chosen not to comply with the DOS Act.

    For the sake of credibility, it is important that such a statement
    is not hidden away in a footnote in the authority's internal system,
    email, accessibility report, or annual report.

    The responsible government minister and the supervisory authority
    responsible for compliance with the DOS Act at the time
    shall also be informed in these cases.


    Our own experience of this type of notification is that
    the authorities do not appreciate having to explain
    why they do not comply with the DOS Act.

    Examples:

    • Some authorities do not even acknowledge receipt of our report,
      let alone register it with a searchable record number;
      apparently some authorities lack functioning
      record management systems?


    • Not infrequently,
      the authority uses all means at its disposal to prevent the report
      from reaching the Head of the Authority/Director General.
      Instead, the authority allows an employee from its
      communications department, or even its webmaster(!),
      to respond to a report of a suspected violation of the law.
    • This is remarkable since these organizational units are not in
      the legally position responsible for the authority's activities
      or potential violations of the law.



    • Authorities on digital accessibility in social media.
      Agency Heads/Director Generals today like to
      communicate in social media.
      Not least to highlight to the outside world all
      excellent accessibility initiatives and activities
      that their agency is implementing.
    • But this type of communication is often one-way only.
      It seems its only aim to present the agency as
      "a leading player in digital accessibility".
      Something that is made clear by the fact that
      director generals are not happy to publicly answer
      embarrassing questions in his/her feeds.

      For example: "Why does the agency still publish
      inaccessible annual reports on its website?"
      Then suddenly it becomes completely silent in
      the director general feed, no answers or explanations!



    • Obvious low-water marks are the authorities (regardless of level)
      that we have repeatedly, since 2019, reported as a result of publishing
      a large number of important operational documents as
      digitally inaccessible documents on their websites.
      (Thus, not organisations that "accidentally" happen to publish
      a few inaccessible documents, but organisations that actively
      and systematically publish and share hundreds,
      in some cases thousands, of inaccessible PDF documents).
    • If they respond at all, a typical response might look like this
      (Note! this is an authentic response from a national authority):

        "The authority is actively working to
        increase the accessibility of our website.
        We are aware that a few PDFs are not accessible today.
        We manage all PDFs on an ongoing basis and the goal
        is that all of them will be accessible in the near future."


      Translated into plain Swedish, this corresponds to:

        "The authority is aware that it is affected by the DOS Act
        and that this law is mandatory and must be complied with.
        The authority is aware that it does not have control
        over its document resources and lacks knowledge of
        the documents' accessibility status and who is responsible.
        The authority has, despite this, chosen not to prioritize the task
        of adapting the authority's documents to be accessible in order
        to meet the requirements of the DOS Act."

      Such a response may well be acceptable for the first few years,
      but when this particular authority has responded with
      exactly the same "cut-and-paste"/nonsense response,
      year after year after year since 2019,
      the Head of the Authority/Director General
      must be held accountable and blamed.
      As it is now, this type of authority continues to, year after year,
      publish even more inaccessible PDF documents,
      and completely without DIGG taking any actions.



    • When we in 2020 notified another very central authority
      about their published inaccessible PDF documents,
      they replied:
      • "Thank you for drawing attention and pointing out to
        the authority about the Act on Accessibility to the Public Sector.
        It is important, the issue of accessibility is fundamental
        for everyone to be able to participate in society.

        The Act (2018:1937) on Accessibility to Digital Public Services
        means that the authority needs to take responsibility for
        services and information to be accessible.
        The authority has worked for many years to ensure
        that our websites can be used by everyone.
        The documents published on the website should
        of course be accessible to everyone and
        the authority is working intensively on this."

      A pleasing, truly hopeful response from this authority.
      It clearly gave the impression that the authority takes
      the DOS Act very seriously.

      Every year since then we have checked
      what that authority promised to fix in 2020,
      but unfortunately nothing has changed on their
      website since then, not a single digitally accessible
      PDF document can we find there!
      All (thousands) of the authority's published PDF documents
      are still completely digitally inaccessible PDF documents.

      Thus, a non-binding promise,
      - and completely without DIGG taking actions.


    Lack of accountability.

    When Sweden's most important and central government agencies,
    set the tone by systematically failing to comply with the DOS Act,
    without penalties, other public authorities follow suit.

    They seem to reason like this:

    • "That's what everyone does".

    • "When no central authority cares,
      not even the supervisory authority DIGG,
      why should I, as the responsible head of authority/director general,
      care about complying with the DOS Act?"

    Nobody cares, not even the Swedish parliament,
    the government/government offices, ministries,
    or administrative authorities.
    And strangely enough, not even the administrative authorities
    appointed to exercise public review/supervision of accessibility for all.


    Fear of involvement.
    There is a fear of involvement.
    The state does not dare to interfere too much,
    but hopes that all authorities will adhere to the laws,
    an attitude where they only appeal to the authorities
    to fulfill the requirements of the DOS Act.


    It is incomprehensible that more voices are not heard about this problem.

    Otherwise life just continues as usual....

    Of course it cannot continue like this!



    Time for accountability.

    "The stairs must be swept from the top"
    to gain an impact for the DOS act and the public's trust in
    the authorities and decision-makers concerned.

    Directly responsible for the fact that these abuses
    are still ongoing are, of course, the respective
    heads of government agencies, including members of
    the government board.

    In addition, public organizations and decision-makers
    shall be held accountable when Swedish law is not respected:

    • The Agency for Digital Government (DIGG, www.digg.se

    • DIGG, appointed regulatory authority
      for compliance with the DOS Act.

      DIGG manages all matters relating to digital accessibility
      and where other authorities and the public should report
      observations/notifications about inaccessible websites and services.

      DIGG shall coordinate and support the administration-wide
      digitalization with the aim of making public administration
      more efficient and effective.

      Public administration refers to municipalities,
      regions and state authorities,
      with the exception of elected assemblies
      such as the Government/Government Officea/Parliament,
      as well as the Security Service, the Fortification Agency,
      the Defence University and authorities belonging
      to the Ministry of Defence.

      Consequently, DIGG is not allowed to audit the accessibility of
      Sweden's most central public services/authorities,
      or issue fines to them!

      This demarcation is probably the explanation why DIGG
      has only issued fines to relatively small local/municipal actors
      (with limited own resources) while the parliament and
      the government/government offices, ministries and
      administrative authorities completely and shamelessly
      continue to publish inaccessible websites, services
      and inaccessible digital documents!


      DIGG does not live up to
      what it preaches and pretends to do.

      DIGG states on its website:

      • "When we work with the supervision of
        websites, documents and mobile apps,
        we follow our new supervision manual"

      But the fact is that DIGG's own website is completely flooded
      with digitally inaccessible PDF documents!

      DIGG has not even followed its own supervision manual
      to audit its own website (www.digg.se) for accessibility!


      It is further strange that DIGG, the designated expert authority,
      with access to its own accessibility expertise in its line organization,
      is unable to publish its own operational documents as
      digitally accessible PDF documents; clear examples are:

      • DIGG Annual Reports (2018 to 2023)

      • government assignment reports
        (including those relating to inclusion,
        accessibility and disability politics)

      • information material, guides/guidance, presentation slides

      • DIGG's own regulations (MDFFS 2019:2, MDFFS 2021:2)
        for the Swedish act on accessibility to digital public services, etc.

      So unfortunately, DIGG is not a role model when it comes to
      making digital government documents accessible.



      DIGG and inaccessible fines - What a surprise:

      In 2023, there were two notable cases where DIGG issued
      sharp fines to two smaller actors at the local municipal level,
      Ockelbo Municipality and Pajalabostäder AB,
      for accessibility deficiencies on these actors'
      websites and related accessibility statements.

      These orders were issued by DIGG in the form of PDF documents.
      One would like to believe that the supervisory authority DIGG then
      provided these documents as digitally accessible PDF documents.

      But alas no,
      the documents were/are completely untagged PDF documents,
      and thus digitally inaccessible PDF documents for the receiving party.

      Perhaps DIGG believed that this type of document would never
      ever appear on a public website or be requested from
      DIGG for external review?

      However, not likely, DIGG's decisions were issued by DIGG's
      own supervisory officer and accessibility expert and had been
      internally presented for DIGG's Authority Lawyer;
      all staff members who were/are well-versed in
      the requirements of the DOS Act.


      DIGG's role as supervising authority of the DOS Act?

      The question is whether DIGG has the right focus and
      resources and makes relevant priorities to satisfactorily
      carry out its supervisory mission?

      DIGG's total staff number approximately 170 individuals.
      The "central accessibility team" responsible for monitoring
      compliance with the DOS Act by all public authorities consists of
      4 individuals (of which one is a specialist and three are
      auditors/administrators; according to the recruitment
      advertisement published by DIGG, as of November 2024).


      The actual outcome of DIGG's supervisory activities and priorities,
      the number of in-depth review cases carried out and
      issued remarks and fines, are shown in DIGG's annual reports and
      DIGG's webpages on audited websites (years 2020-2023).

      The outcome also states that DIGG,
      despite its specific and clearly defined mission to exercise
      supervision and audit of "websites, apps AND digital documents",
      has deliberately chosen not to review and report on how well
      the digital documents of the concerned authorities
      meet the requirements of the DOS Act.


      However, we can report that too many PDF documents
      that are published on most of the government websites that
      DIGG claims to have audited (simplified and in-depth) are in fact
      produced and published as digitally inaccessible PDF documents
      - without any form of sanction being imposed on DIGG's part!


      DIGG has not exercised its control obligation according to law,
      which has had fatal consequences in the form of so many (most)
      of Swedish authorities' published PDF documents still being
      provided as digitally inaccessible.
      Clearly indicates that DIGG has not adequately carried out
      its supervisory mission to get Swedish authorities
      to comply with the DOS Act.


      Nor has DIGG been able to issue actions or fine orders against
      several large central administrative authorities/actors for which
      DIGG has a supervisory mandate.
      Authorities that clearly do not comply with the requirements
      of the DOS Act; see a selection of these authorities below.

      For example,
      it is generally accepted that administrative authorities
      are allowed to submit digitally inaccessible annual reports
      to the concerned ministries;
      without either responsible ministers or DIGG reacting.

      Inaccessible annual reports which are in turn republished on
      the respective ministries' websites. Total loophole!
      It most likely completely violates the intentions of the DOS Act!


      As an independent actor, we/NewFormat have identified over
      3000 inaccessible PDF documents.

      It is not really our task to examine the extent to which
      concerned Swedish authorities comply with the DOS Act.
      This type of accessibility review should normally be carried out
      entirely by a well-functioning supervisory authority over the DOS Act.

      If DIGG had wanted to, they could easily have taken
      the necessary measures to protect Swedish citizens
      from all these digitally inaccessible PDF documents.

      If one wants, one can, but it is obvious that DIGG does not want...
      DIGG seems to lack both the will and the ability to prioritize
      the task of working to ensure that concerned authorities and
      actors provide accessible documents according to
      the requirements of the DOS Act.

      We question whether DIGG is making
      the right priorities in its accessibility mission.

      It can also be questioned whether the current DIGG
      is the most appropriate authority to adequately supervise
      compliance with and impact of the DOS Act.



    • Justitiekanslern (JK), www.jk.se
      The Office of the Chancellor of Justice

    • The JK is tasked with examining whether those who exercise
      public functions comply with laws and other regulations
      and whether they also otherwise fulfil their obligations.

      However, the JK cannot examine the Government or ministers,
      nor the Riksdag's authorities or employees and contractors at
      the Riksdag's authorities.



    • Justitieombudsmannen (JO), www.jo.se
      Riksdagens ombudsmän / The Parliamentary Ombudsmen

    • JO reviews that the authorities work in accordance with
      the laws and regulations that govern their work
      - especially those laws that concern the rights and
      obligations of individuals in relation to the public sphere.

      JO's task is to exercise supervision, on behalf of the Riksdag,
      over the application of laws and other regulations in public activities.
      The supervision covers both courts and other authorities
      and the employed executives.


      One way to clarify whether DIGG is the most appropriate authority
      to supervise compliance with the DOS Act is to file a complaint
      with JO against DIGG; with the argument that it is extremely doubtful
      whether DIGG in its public activities follows and applies Swedish laws
      and other regulations correctly in its supervisory activities.

      Other authorities affected by the DOS Act can also be reported to JO.
      The question, however, is whether JO is equipped to manage
      250+ separate reports or whetherJO would rather welcome
      a class action concerning all 250+ authorities?

      Interesting in this context is that the JO also
      does not care about the DOS Act;
      The JO also publishes a large number of inaccessible
      digital documents on its website, www.jo.se.



    • Riksdagens konstitutions­utskott (KU),
      The Parliament Constitutional Committee

    • KU is tasked with examining whether the government and
      ministers are following the rules for government work.
      KU is a committee in the Swedish Parliament with
      the task of preparing questions and raising proposals
      of constitutional and administrative law significance,
      as well as examining the performance of the ministers'
      duties and the handling of government affairs.

      Members of the Parliament have the right to report
      the ministers in the government to KU.
      KU then investigates whether the ministers
      who have been reported have committed an offence or not.



    • Riksrevisionen, www.riksrevisionen.se
      The Swedish National Audit Office.

    • Riksrevisionen checks that the government and
      government agencies are doing their job.
      The task is to examine what the state's money is used for,
      how it is reported and how efficiently it is used.

      Riksrevisionen examines whether the agencies comply
      with directives, rules and regulations, whether they achieve
      their objectives and whether government efforts are effective.

      If Riksrevisionen finds shortcomings,
      these are reported together with recommendations
      for improving operations.



    • Statskontoret, www.statskontoret.se
      The Swedish Agency for Public Management

    • Statskontoret works to promote an efficient and
      democratic state administration and acts as
      the government's investigative authority.

      Statskontoret conducts investigations and
      evaluations in all sectors by analyzing,
      evaluating and reporting as a basis for improving
      the efficiency and review of state operations,
      developing administrative policy and
      promoting a good administrative culture.

      (As an outside observer, one would like to believe that
      the concept of "a good administrative culture" includes
      that Swedish authorities comply with Swedish law,
      including the DOS Act.)


      In 2022 the Swedish Government/Ministry of Infrastructure
      commissioned Statskontoret (in the form of a PDF document)
      to carry out an Agency Analysis of
      The Agency for Digital Government (DIGG)

      The assignment included, among other things,
      "analyzing how DIGG fulfills its tasks in relation to instructions,
      appropriation letters, government assignments and resources,
      and how internal and external factors affect the agency's results".

      In its Analysis Report (2023), Statskontoret says:

      • "We assess that Digg is not fulfilling its task in
        supervising access to digital public services,...."
        (i.e., as a supervisory authority for the DOS Act).

      • "We base this on the fact that the authority
        carries out too few audits within the framework of
        its supervisory mission and does not meet
        the volume targets that the EU Commission has decided on".

      Worth noting:
      Despite the fact that both
      the Ministry of Infrastructure and Statskontoret
      have very good knowledge of the requirements of the DOS Act,
      both the assignment document and the analysis report
      were unfortunately carried out and published as
      digitally inaccessible PDF documents!



    • Lagrådet (Justitiedepartementet), www.lagradet.se
      The Council on Legislation (Ministry of Justice)

    • Lagrådet is a Swedish authority that reviews and issues
      opinions on legislative proposals at the request of
      the government or a parliamentary committee.

      Lagrådet shall normally be consulted on proposals
      for amendments to the constitutions that concern
      freedom of the press and freedom of expression
      in certain media and on proposals for laws that affect
      the freedoms and rights of individuals,
      their personal and financial circumstances or
      their obligations towards the public.

      Lagrådet has, among other things, published opinions
      (in the form of its own digitally inaccessible PDF documents)
      prior to the implementations of:

      • the EU's Web Accessibility Directive (2018-06-20) and

      • the Accessibility Directive (2022-10-05)

      as Swedish laws.



    • Åklagarmyndigheten (Statsåklagaren), www.aklagare.se
      The Swedish Prosecution Authority

    • Åklagarmyndigheten is a state administrative authority
      with the task of contributing to ensuring that individuals
      who commit crimes are held accountable for their actions
      and that this is done in an efficient and legally secure manner.


    Worth noting:

    All the above-mentioned entities
    DIGG, JK, JO, KU, Riksrevisionen, Statskontoret,
    Lagrådet and Åklagarmyndigheten still publish
    digitally inaccessible annual reports, official business reports,
    other reports, audit reports and statements
    on their respective websites!
    Which most likely violates the intentions of the DOS Act!

    We have found no indication that any of
    the above-mentioned authorities have been interested
    in carrying out any form of regulatory audit or action
    at the national state level or any opinion regarding
    how well the current web accessibility law, the DOS Act,
    is being complied with by state authorities.


    In summary

    Thus, DIGG, JK, JO, KU, Riksrevisionen, Statskontoret,
    Lagrådet and Åklagarmandigheten have clear
    credibility problems and seem to lack convincing
    ability to fully exercise assigned authority tasks.



    Conclusion

    As said, 6 years have passed since the DOS Act came into force in 2019.
    Despite this, it is not being complied with by the concerned
    Swedish authorities when it comes to published digital documents.

    How much longer will these authorities
    need to comply with the DOS Act?

    How many more inaccessible documents
    have to be reported to the concerned actors
    before they comply with the DOS Act?

    There should be no need to make special remarks to
    heads of authorities to comply with current Swedish law;
    after all, according to Regeringsformen
    (The Instrument of Government) they are appointed as
    heads of authorities by the government
    solely on the basis of merit and skill.

    Why doesn't DIGG demand real accountability
    to a greater extent from the heads of authorities concerned?


    Why doesn't anyone care? Where is the accountability?

    We cannot find that it is permissible for any other Swedish law
    to be neglected by concerned actors in a similar way.
    So why is this permitted for the DOS Act in particular?

    It is not offensive to demand accountability from
    the head of a public sector authority.
    There is a regulatory framework, the DOS Act,
    it's just a matter of daring and wanting to apply that law!


    Where is the political accountability?

    Our review shows that not even
    the Government / Government Offices / Ministries
    cares about complying with the requirements of the DOS Act.

    PDF documents that are currently provided by
    Swedish digital public services have one common characteristic:

    • They are not designed to meet the requirements of the DOS Act
      to be provided as digitally accessible PDF documents.

    An authority/and administrative culture has been created
    that focuses more on cutting corners around the DOS Act
    than on fulfilling its requirements to counteract discrimination.

    Continuing with the current order is not an option.
    Now there is a need for a strong steering of this government culture.
    It is time for a re-take where the authorities and executives concerned
    are required to face a clear accountability for fulfilling the DOS Act.


    The shortcomings are so severe and obvious that even all
    responsible Ministers / Heads of Ministries must step forward,
    act and take responsibility for fulfilling the DOS Act.

    However, the ultimate responsibility (currently) for
    demanding accountability and taking measures to stop
    the absurdity that is currently taking place is, Erik Slottner,
    Minister for Public Administration, Ministry of Finance,
    with responsibility for:

      "A well-functioning digitalization in public administration
      to improve services for citizens and increase
      the efficiency of our authorities".


    The Minister for Public Administration needs to take
    immediate action and answer these questions:

    • When the authorities and other actors concerned,
      regardless of level, have completely lost their core values ​
      and instead act in conflict with the values
      the Swedish state stands for according to
      the "Swedish Act on Accessibility to Digital Public Services",
      and it doesn't matter if you don't follow the rules,
      then for what purpose is the DOS Act?

    • What strict measures will you, as the responsible minister,
      take, and when, to ensure that authorities and actors affected
      by the DOS Act comply with the law's requirements?


    Demands for immediate actions:

    • The DOS Act must be tightened.
      Public authorities should not be allowed
      to cut corners around the DOS Act.
      Our review shows that the DOS Act in its current form is pointless;
      too many concerned authorities do not care to comply with it.
    • The Authorities' Budget Letters/Appropriation Letters,
      regulations and instructions must be clarified:
      "Swedish Act on Accessibility to Digital Public Services"
      must be fully complied with for the websites,
      documents and apps of the authorities concerned.

      Head pop Authorities who does not comply with the law,
      and thereby actively circumvents the law and his/her own
      responsibility, shall risk deterrent legal consequences.

      At the national level, issues regarding the DOS Act
      shall also be part of the regular follow-up discussions
      held between the government office and authorities.



    • When an authority or other publicly funded entity
      provides a government office/department with
      a digitally inaccessible document,
      it shall not be accepted/received, but shall immediately
      be returned to the sending authority/body for action:
      Redo it, do it right!
      (Examples of such digitally inaccessible documents:
      annual reports of administrative authorities,
      consultation responses, reports,...)



    • Reform DIGG so that it becomes a well-functioning and
      efficient authority to "review digital public services provided
      by a public actor to see whether they meet the requirements of
      the Act on Accessibility to Digital Public Services" AND that
      demands accountability from heads of authorities who choose
      not to comply with the requirements of the DOS Act.
    • Alternatively,
      appoint another supervisory authority for the DOS Act (other than DIGG)
      with the will and prioritization ability to carry out serious supervisory work
      and to effectively exercise its supervisory mission over
      the Act on Accessibility to Digital Public Services.

      Regardless,
      set requirements for reasonable and appropriate competence and
      ensure that the appointed supervisory authority itself
      complies with the DOS Act and applies it fully to
      its own websites, apps AND documents.

      The appointed supervisory authority shall,
      to a much greater extent, use its entire arsenal of sharp tools.
      Fines must be issued quickly when warnings or orders for action
      are not respected within a reasonable period of time
      (6 years is then not a reasonable period of time!).




    Accessibility requirements will be extended,
    become more comprehensive and even stricter when
    the EU Accessibility Act (EAA) Directive enters into
    full force as Swedish law on June 28, 2025

    • On June 28, 2025, the EU Accessibility Act (EAA) Directive
      will enter into full force in Sweden as
      the Act on Accessibility of Certain Products and Services (2023:254).
    • The Act also applies to the private sector
      as a supplier of products and services.

      Products and services must be designed
      so that they are accessible to more people,
      for example older people and people with disabilities.

      The Act imposes accessibility requirements on a number of
      products and services aimed at consumers in the areas of:

      • electronic communication

      • banking and payment

      • e-commerce

      • e-books

      • audiovisual media (television)

      • passenger transport

      Products covered include computers, smartphones,
      payment card readers, ATMs and ticket vending machines,
      check-in machines and interactive information screens at,
      for example, airports and train stations.

      Services covered include e-mail, consumer banking,
      e-books and e-commerce services.


      Swedish business entities,
      industry, transport, banking, finance and insurance, etc.,
      must therefore take immediate action to adapt
      their operations to meet the requirements for
      digitally accessible information in their contact
      with customers/consumers.

      Quotations, order confirmations, invoices and similar
      commercial documents aimed at consumers
      must be provided as digitally accessible documents.


      As a matter of fact, the PDF standard is well prepared for
      this future and already has robust support for

PDF/A-3 / PDF/A-4 logo     + XML logo

      This type of e-invoice manages both
      structured and non-structured data,
      and consists of two components, a PDF/A-3 file and
      an embedded XML file (with identical invoice data)
      as attachment:

      • The PDF/A-3 file represents the visual part of
        the invoice and is therefore readable by humans.

      • The XML file contains structured invoice data that
        is processed automatically and by machines.

      They fully comply with the European e-Invoicing Standard EN 16931,
      "Created/issued, transmitted and received in a
      structured electronic format that can be processed
      automatically and electronically".

      The e-invoice recipient can choose between processing
      the invoice as an ordinary PDF or let computers
      process the embedded XML code.

      This type of PDF-based e-invoices (as above) have received
      international recognition and are approved as a valid
      e-invoicing format in, among others, Germany and France!

      In addition,
      when the PDF part is designed according to the ISO Standard PDF/UA,
      the e-invoices become de facto digitally accessible PDF-based e-invoices,
      fully in line with the requirements of the DOS Act and
      the Act on Accessibility of Certain Products and Services.

      (Note! However, in Sweden, DIGG, the "expert authority for e-invoicing",
      claims that PDF-based e-invoices do not comply with EN 16931.
      As evidenced above, this is a completely untrue claim by DIGG!)



    The Swedish Post and Telecom Authority (PTS)
    is the designated market surveillance authority for
    all products and services covered by this Act.

    PTS has also supervisory responsibility for certain of
    the services covered by the Act:

    • electronic communications services

    • banking services, and

    • e-commerce

    Also PTS has an important role in making the digital transition
    accessible and safe for everyone and works to ensure that
    the goal of the Swedish Disability Policy is achieved
    by supporting equality in living conditions and
    full participation in society for people with disabilities.

    Commendable, but despite that,
    PTS does not comply with the DOS Act;
    PTS publishes a lot of digitally inaccessible PDF documents
    on its website, www.pts.se.

    PTS is unable to publish its own operational documents as
    digitally accessible PDF documents; clear examples are:

    • PTS Annual Reports (2015 to 2023)

    • government assignment reports
      (including those relating to inclusion,
      accessibility and disability politics)

    • information material, guides/guidance, presentation slides

    • PTS's own regulations (PTSFS 2024:5, 2024:6, 2024:7)
      for the Swedish Act on the Accessibility of
      Certain Products and Services, etc

    So neither is PTS a role model when it comes to
    providing accessible government documents.



    Upcoming challenge for control/supervision authorities:

    Swedish public actors are currently far from fulfilling
    the requirements of the DOS Act,
    despite it having been in force for over 6 years.

    Many thousands more businesses will be covered and affected
    when the Swedish Act on Accessibility of Certain Products and Services
    is introduced on June 28, 2025:

    It would be extremely unfortunate if this extended
    target group were also allowed to fail to comply with
    the new Accessibility Act for more than 6 years
    without sanctions being imposed!

    Challenge:

    • Dear Supervisory Authorities,
      how long will affected actors
      be allowed to fail to comply with
      this Act without severe consequences?





Details

Unique audit of PDF documents
published on Swedish government public websites,
with regard to the documents' digital accessibility,
February 2025

The authorities concerned are probably violating both
the EU Web Accessibility Directive and
the Swedish Act on Accessibility to Digital Public Services


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    As well as overviews of authorities and activities with
    public funding that, year after year, actively and systematically
    create, share and publish digitally inaccessible PDF documents
    in large quantities, and the most common types of
    digitally inaccessible PDF documents.




Overviews of the authorities and actors concerned and
the most common types of digitally inaccessible PDF documents
that these entities provide via digital public services:


    The audit includes approximately 3000 central and important
    PDF documents from approximately 250 Swedish authorities.

    We have also reviewed PDF documents published by the EU,
    Swedish private industry, Swedish political parties,
    as well as by organizations that work for full participation and equality
    in society for individuals with disabilities and/or special needs
    (precisely the human individuals that the DOS Act aims to protect).
    - Inaccessible PDF documents

    Documents that neither meet the accessibility requirements for
    digital documents according to the EU's Web Accessibility Directive
    or the Swedish Act on Accessibility to Digital Public Services.

    Documents that are therefore not digitally accessible to everyone!


    Below is our overviews of a subset of affected
    authorities and publicly funded activities that,
    year after year, actively, consciously and systematically
    via their processes for public digital services,
    create, share and publish digitally inaccessible
    PDF documents in large quantities.

    Probably in complete violation of
    the EU Web Accessibility Directive and
    the requirements of the DOS Act.

    The overviews also list the most common types of
    digitally inaccessible PDF documents that we have audited.


    It is not possible to list all the inaccessible public PDF documents
    that we have audited on this website.

    For all authorities concerned,
    we are happy to clarify and explain the reasons
    why the documents do not comply with
    the ISO standard PDF/UA and thus also do not
    comply with the W3C/WCAG 2.x recommendations,
    and possible remediation measures:





  • EU Level / European Union (EU)
    - Inaccessible PDF documents

  • EU Institutions and Businesses
    that actively and systematically
    provide inaccessible PDF documents:

    • European Parliament and Council

    • European Commission

    • European Court of Auditors (ECA)

    • AccessibleEU and AccessibleEU Sweden

    • ETSI (European Telecommunications Standards Institute)

    Types of audited digitally inaccessible PDF documents
    provided by EU institutions via digital public services:

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    • Directives and Regulations;
      including barrier-free access for all citizens
      to digital public services
      as well as to products and services

    • Guidelines

    • ICT Standards, Accessibility Standards,...

    • Brochures, Collaterals, Information Materials

    • Factsheets

    • Journals / Magazines

    • Audit Reports

    • Press Releases

    • Reports on:

      • Strategies

      • Cybersecurity

      • Competitiveness

      • Green transition

    • Seminar Confirmations

    • ...






  • Sweden - National level:
    National Authorities and Administrative Authorities
    - Inaccessible PDF Documents

    National Authorities and Administrative Authorities
    that actively and systematically provide
    inaccessible PDF documents:

    • Swedish Parliament / Sveriges Riksdag

    • Government / Government Offices / Prime Minister's Office / Ministries
      (Ministry for Foreign Affairs, Ministry of Finance,
      Ministry of Defence, Ministry of Infrastructure,
      Ministry of Justice (incl. The Council on Legislation),
      Ministry of Climate and Enterprise, Ministry of Culture,
      Ministry of Health and Social Affairs,
      Ministry of Education and Research,...)

    • Courts

    • The Agency for Digital Government (DIGG)

    • The Agency for Participation (MFD)

    • The Agency for Press, Radio and TV (MPRT)

    • The Civil Contingencies Agency (MSB)

    • The Agency for Accessible Media (MTM)

    • The Post and Telecom Authority (PTS)

    • The National Agency for
      Special Needs Education and Schools (SPSM)

    • The Public Employment Service (AF)

    • The Work Environment Authority

    • The Ombudsman for Children (BO)

    • The Board of Student Finance (CSN)

    • Digin.nu
      (Project supported by PTS, DIGG, MFD and MTM)

    • The Digitalisation Council
      (part of www.regeringen.se)

    • The Equality Ombudsman (DO)

    • The Courts of Sweden (Domstol)

    • The Economic Crime Authority (EBM)

    • The National Financial Management Authority (ESV)

    • eSam / eSamverka,
      Public Collaboration for Increased Digitalization

    • The Public Health Agency (FHM)

    • The National Defence Radio Establishment (FRA)

    • The Armed Forces

    • The Social Insurance Agency (FK)

    • The Authority for Privacy Protection (IMY)

    • The Office of the Chancellor of Justice (JK)

    • The Parliamentary Ombudsmen (JO)

    • The Gender Equality Agency

    • The Competition Authority (KKV)

    • The Consumer Agency (KO)

    • The Enforcement Authority (Kronofogden)

    • The Royal Library (KB)

    • The Mapping, Cadastral and Land Registration Authority

    • The Food Agency

    • The Agency for the Media

    • The Migration Agency

    • The National Agency for Higher Vocational Education (MYH)

    • The Environmental Protection Agency

    • The Pensions Agency

    • The Police Authority (Polisen)

    • The National Archives(RA)

    • The Riksbank

    • The National Audit Office (RR)

    • The International Development Cooperation Agency (Sida)

    • The Tax Agency (SKV)

    • The National Agency for Education

    • The National Board of Health and Welfare

    • The Arts Council

    • The National Government Employee Pensions Board (SPV)

    • The Statistics Sweden (SCB)

    • The Swedish Agency for Public Management

    • The Security Service (SÄPO)

    • The Transportation Administration (TRV)

    • The Transport Agency

    • The Council for Higher Education (UHR)

    • The Higher Education Authority (UKÄ)

    • The National Agency for Public Procurement (UHM)

    • The Payment Agency (UBM)

    • The Election Authority (VAL)

    • The Innovation Agency (Vinnova)

    • The Prosecution Authority

    • ...
       

    Types of audited digitally inaccessible PDF documents
    provided by Swedish National Authorities and Administrative Authorities:

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    • Statements of Government Policy

    • Annual Reviews

    • Annual Reports

    • Official Reports

    • Work Procedures

    • Appropriation Letters

    • Government Official Reports (SOU)

    • The Code of Statutes (SFS)

    • Budget Bills and Other Bills

    • Motions

    • Directives and Regulations

    • Instructions

    • Considerations

    • Referrals, Referral Responses, and Opinions

    • Supervisory Matters

    • Fines

    • Agreements

    • Factsheets

    • Audit Reports

    • Investigations

    • Business Plans

    • Invoices

    • Order Confirmations

    • Bank Statements

    • Brochures, Collaterals, Information Materials

    • Protocols,

    • Application Forms and Questionnaires

    • Declaration Documents, Declaration Forms and Guidelines

    • Presentation Slides

    • Information Graphics

    • Tutorials and Guides

    • Newsletters

    • Election Results Reports

    • Election Information Materials and Posters

    • ...

    Digitally inaccessible PDF documents whose principals and issuers
    are typically positive about digital accessibility and often express
    great empathy for all individuals with disabilities, but where they instead
    in practise in their daily work, provide digitally inaccessible PDF documents!

    Inaccessible PDF documents that are thus
    completely unusable for the intended target group!

    How have these public organizations reasoned
    when publishing documents whose design prevents
    the target group/individuals that the DOS Act protects
    from accessing the content of the PDF-documents?

    Sweden's heads of public authorities do not seem to accept
    that the DOS Act is a Swedish law that they must comply with;
    despite the fact that public authorities have a special
    responsibility to comply with the law.





  • Sweden - National level: Higher Education & Research Authorities
    - Inaccessible PDF Documents

    Higher Education & Research Authorities
    that actively and systematically
    provide inaccessible PDF documents:

    • Defence University (FHS)

    • University of Gothenburg (GU)

    • University of Skövde (HiS)

    • KTH Royal Institute of Technology (KTH)

    • Linköping University (LiU)

    • Luleå University of Technology (LTU)

    • Lund University (LU)

    • Mid Sweden University (MIUN)

    • Stockholm University (SU)

    • Umeå University (UmU)

    • Uppsala University (UU)

    • Örebro University (ORU)

    • ...


    Types of audited digitally inaccessible PDF documents
    provided by Swedish Higher Education and Research Authorities:

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    • Annual Reports

    • Sustainability Reports

    • Operating Results

    • Budget Plans

    • Planning Documents

    • Business Plans

    • Strategic Plans

    • Vision Documents

    • Research Reports

    • Evaluations

    • Protocols

    • Quality Policies

    • Educational Catalogs

    • Student Catalogs

    • Accessibility Reports

    • Audit Reports

    • Syllabuses on Digital Accessibility

    • Guidelines on Thesis Paper Design

    • Brochures, Collaterals, Information Materials

    • Journals / Magazines

    • ...




  • Sweden - Local / Regional Authorities
    - Inaccessible PDF Documents:

    Local / Regional Authorities
    that actively and systematically
    provide inaccessible PDF documents:

    • Alingsås Municipality,

    • Digidel,
      Public Collaboration on Good and Cost-Effective Digitalization
      between The Digidel, Region Västernorrland (RVN),
      Sambruk and Mid Sweden University (MIUN)

    • City of Gothenburg

    • Karlstad Municipality

    • Katrineholm Municipality

    • Kungsbacka Municipality

    • City of Malmö

    • Norrköping Municipality

    • Region Jönköping County (RJL)

    • Region Stockholm County (RS)

    • Region Stockholm County (RS), Regional Archive

    • Region Örebro County (RÖL)

    • Region Östergötland County (RÖ)

    • Region Östergötland County (RÖ), Östgötatrafiken

    • County Administrative Board of Skåne

    • County Administrative Board of Uppsala

    • City of Stockholm

    • Swedish Association of
      Local Authorities and Regions (SKR)

    • Vara Municipality

    • Värmdö Municipality

    • City of Västerås

    • Åstorps Municipality

    • ...


    Types of audited digitally inaccessible PDF documents
    provided by Local / Regional Authorities:

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    • Annual Reports

    • Operating Results

    • Budget Plans

    • Action Plans

    • Business Plans

    • Audit Reports and Statements

    • Preservations and Thinning Plans

    • Sustainability Reports

    • Business Plans

    • Guidelines and Rules for AI Use

    • Guidelines for Long-Term Archiving of Digital Files

    • Presentation Slides

    • Supply Plans for Premises

    • Brochures, Collaterals, Information Materials

    • Sustainability Reports

    • Travel Terms Regional Traffic

    • Train and Bus tTmetables for Regional Traffic

    • Investigation Reports

    • Disability Policy Assignments

    • Statistical Yearbooks

    • Announcements

    • Safety Programs

    • Accessibility and Inclusion Programs

    • Disability User Surveys

    • Master Plans

    • Architectural Policies

    • Guides for Escorting

    • Vision and Opportunity Plans

    • Posters

    • Instructions for Executives

    • Checklists

    • Opinions

    • Journals / Magazines

    • ...




  • Sweden - Political Parties
    - Inaccessible PDF Documents:

    Political parties that actively and systematically
    provide inaccessible PDF documents.

    Our politicians are particularly fond of emphasizing
    that they care about citizens with special needs,
    precisely the target group that the DOS Act and
    other accessibility laws protect.

    In line with this belief,
    the parties have been involved in voting for
    the accessibility and other rights laws in
    the Swedish Parliament, such as:

    • Swedish Act on Accessibility to Digital Public Services (DOS Act, 2018)

    • Swedish Act on Accessibility of Certain Products and Services (2023)

    • Swedish Act on Support and Service for Persons with
      Certain Functional Impairments (LSS Act, 1993)

    So far so good.


    Certainly, political parties are not public authorities,
    but the parliamentary decisions above should reasonably
    have had a profound impact on how the parties themselves
    communicate with the outside world.

    However, our review shows that the parties' own central offices
    act as if they were completely uninformed about what
    their parties have voted for.

    A clear example of this:
    The parties published and shared a multitude of PDF documents
    on their websites ahead of the EU elections in 2018 and 2024,
    and the parliamentary elections in 2020 and 2024.

    Symptomatically, not a single election program, election manifesto,...
    was provided as a digitally accessible PDF document!

    Election information that was in practice useless for many voters!

    A legitimate question:
    What did the party strategists and communications officers think?
    Why didn't they give ALL voters equal opportunity to consume
    the content of the election material in order to be able to
    act on it independently - without having to ask outsiders for help?

    How could they have completely missed Sweden's accessibility laws?


    Types of audited digitally inaccessible PDF documents
    provided by Political Parties:

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    • Annual Reports

    • Budget Motions

    • Statutes

    • Agreements

    • Work Orders

    • Party Program

    • Idea Programs

    • Principle Programs

    • Accessibility Policies and Checklists

    • Future Agendas

    • Roadmaps

    • Reform Agendas

    • Promemorias

    • Action Plans and Programs

    • Documents on
      Annual Meetings, National Councils, National Meetings,
      Congress Meetings, General Meetings

    • Referrals and Referral Responses

    • Manifests

    • Reports

    • White Papers

    • Factsheets, Brochures, Collerals

    • Disability Programs

    • Election Platforms

    • Election Programs

    • Election Manifestos

    • Promotional Materials

    • Post-Election Analyses / Election Evaluations

    • Audit Reports

    • Presentation Slides

    • Information Graphics

    • Study Materials

    • Tutorials and Guides

    • Newsletters

    • ...




  • Sweden - Interest / User Associations / User Organizations
    that work for full participation and equality in society
    for individuals with disabilities and/or special needs
    (precisely the human individuals that the DOS Act aims to protect)
    - Inaccessible PDF documents

    Interest / User Associations / User Organizations
    that actively and systematically provide
    inaccessible PDF documents.

    The Swedish accessibility laws specifically protect
    the rights of people with functional variations;
    especially the right to accessible public digital information.

    A number of so-called "interest/user associations / user organizations"
    have been operating for many years with the good purpose of
    ensuring that our civil rights apply to all citizens,
    including those with functional variations
    (precisely the individuals that the DOS Act aims to protect).


    Often these organizations communicate with their members
    via websites and electronic mailings in the form of PDF documents.
    But strangely, these PDF documents are typically designed and
    distributed in the form of inaccessible PDF documents.

    The members of these organisations are thus prevented
    from consuming important member information.
    If the PDF documents are instead made available
    as accessible PDF documents, according to
    the ISO standard PDF/UA (adopted in 2012),
    the members are at least given the opportunity to
    reach and consume the PDF-based information
    using technical aids - without the help of outsiders.


    This question has to be asked?
    Why not take advantage of modern PDF technology to
    create and share important digitally accessible member information?


    Types of audited digitally inaccessible PDF documents
    provided by Interest / User Associations, User Organizations:

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    • Annual Reports

    • Activity Reports

    • Business Plans

    • Association Statutes

    • Reports on the UN Convention on
      the Rights of Persons with Disabilities

    • Idea Programs

    • Principle Programs

    • Referrals and Referral Responses

    • Accessibility Checklists

    • Guidelines for Universal Design

    • Letters on Inaccessible Ballots

    • Member Surveys

    • Member Magazines

    • Action Programs

    • Documents on
      Annual Meetings, National Councils, National Meetings,
      Congress Meetings, General Meetings

    • Manifests

    • Reports

    • Manuals

    • Factsheets, Brochures, Collaterals

    • Disability Programs

    • Electoral Platforms

    • Election Programs

    • Election Manifestos

    • Promotional Materials

    • Post-Election Analyses / Election Evaluations

    • Audit Reports

    • Presentation Slide

    • Informations Graphics

    • Study Materials

    • Tutorials and Guides

    • Newsletters

    • ...




  • Sweden -
    Trade and Industri, Transports, Banking, Finance and Insurance,...
    - Inaccessible PDF Documents

    Types of audited digitally inaccessible PDF documents provided by
    Trade and Industri, Transports, Banking, Finance and Insurance,...:

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    • Annual Reports

    • Activity Reports

    • Sustainability Reports

    • Climate Reports

    • Strategy Plans

    • Roadmaps

    • Investment Needs and Plans

    • Customer Magazines kundmagasin

    • Facsheets

    • Reports,

    • Trend Reports

    • Press Releases

    • Brochures, Collaterals and Folders

    • Prospectus, Public Offers,

    • Guides / Tutorials

    • Checklists

    • Technical Specifications

    • Course Catalogs, Teacher Guides and Lesson Materials

    • Referral Responses on Accessibility Directives and Acts

    • Offers

    • Order Confirmations

    • Invoices

    • Delivery Notes

    • Presentation Slides

    • Guides on Creating Accessible Services,
      Documents and Forms

    • Guides on Creating Accessible Web

    • Guides on Creating Accessible Video

    • e-books

    • Standards for Universal Design of
      Products, Goods and Services

    • AI Use in Business

    • ...


    In addition,
    on June 28, 2025, the new Swedish accessibility act will come into force:

    The Act will directly affect the private Swedish business sector
    as a supplier of products and services:

    • Swedish business entities,
      industry, transports, banking, finance and insurance, etc.,
      must therefore take immediate action to adapt
      their operations to meet the requirements for
      digitally accessible information in their contact
      with customers/consumers.





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Recommended Reading on PDF/UA
The ISO Standard for Accessible PDF Documents and Forms

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(For download of these guides, click on the pictures above)



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    out of native MS Office (Word and PowerPoint) and Adobe InDesign documents,
    and PDF documents generated by other tools.


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