Document accessibility for enterprise & legal

Inside a large organisation, many of the documents that carry accessibility risk are ones customers never see: job adverts and application packs, offer letters, employment contracts, staff handbooks, policies, disciplinary and grievance letters, benefits statements, and the legal and compliance material staff are asked to read and acknowledge. The legal frame for these is equality law in employment rather than a product accessibility law. Many of these files are generated from templates in HR or contract systems, so a single defect in a template repeats in every letter produced from it.

In the EU, Council Directive 2000/78/EC applies to public and private employers in relation to access to employment, vocational training, and employment and working conditions. Article 5 requires reasonable accommodation for people with disabilities: appropriate measures, where needed in a particular case, so that a disabled person can have access to employment, participate in it, advance in it or undergo training, unless the measures would impose a disproportionate burden on the employer. The Directive sets the framework, and national employment equality laws give it effect.

In Great Britain, section 39(5) of the Equality Act 2010 applies the duty to make reasonable adjustments to employers, and Schedule 8 sets out that it is owed to applicants and employees. Section 20(6) says that where the duty concerns the provision of information, the reasonable steps include making sure it is provided in an accessible format. The employment duty is tied to a particular applicant or employee, and Schedule 8 says it does not arise where the employer does not know, and could not reasonably be expected to know, about the disability. Even so, a handbook or policy set that is already accessible means a request can be met straight away rather than by converting documents under time pressure during a recruitment round or a disciplinary process.

Long agreements and policies fail on structure: headings that are only bold text, clause numbering that is only visual, cross references that are not links, and no navigable outline. Normfluss checks each PDF against PDF/UA-1 and the WCAG AA success criteria that apply to PDF, remediates it, and issues a signed evidence record stating which checks ran and what they found. Fixing a template once carries through to every letter or contract generated from it. Documents are processed in the EU. The record documents conformance within a stated scope; it is not a legal determination, which stays with the organisation and its advisors.