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Making public notices accessible

Planning notices, consultation documents, statutory notices and committee papers published as PDF: where they fail accessibility, the rules that apply, and the fixes.

Public notices exist so that people are told something in time to act on it: a planning application has been received, a consultation is open, a road will close, a committee will meet and decide. They are produced in a few recurring ways. A notice is filled in from a planning or case management system and saved as PDF, a consultation document is designed for print and then uploaded, and a committee pack joins an agenda, reports, appendices and scanned letters into one long file. The closing date is part of the substance: a person who cannot read a notice or a consultation document before the period ends has lost the chance to respond. The Web Accessibility Directive (EU) 2016/2102 defines public sector bodies to include the State and regional and local authorities, and applies to their websites and mobile applications. It excludes office files such as PDF published before 23 September 2018, unless needed for active administrative processes, and third party content that is neither funded nor developed by, nor under the control of, the body; notices, reports and consultation documents a body writes or pays for are developed or funded by it, so that exclusion does not reach them. In Ireland, S.I. No. 358/2020 gives effect to the Directive with the same exclusions in regulation 3 and requires an accessibility statement in regulation 7. In the UK, regulation 4 of the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 contains the same exclusions, and regulation 8 requires an accessibility statement that explains which content is not accessible and why. Whether a document submitted by an applicant and published on a planning register counts as third party content is a question for the body and its advisors. In Great Britain, section 29(7) of the Equality Act 2010 applies the duty to make reasonable adjustments to people exercising public functions as well as to service providers, and section 20(6) says the steps include making sure information is provided in an accessible format. 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, with documents processed in the EU. The record documents conformance within a stated scope; it does not decide whether a notice was validly given, and whether a body meets its legal duties is for the body and its advisors to decide.

Where public notices typically fail accessibility

  • Notices filled in from a planning or case management system are printed to PDF, which discards the tags, so the site address, the reference number and the closing date for comments sit in positioned boxes that are read out of order or not at all.
  • Site location plans, maps of a consultation area and diversion routes for a road closure are single images, and the address, boundary or roads affected are given only in the picture, so a reader who cannot see it cannot tell where the change is.
  • Committee packs join an agenda, several reports and their appendices into one long PDF with no bookmarks, and each report's headings are bold text, so there is no way to jump from agenda item 7 to the report it refers to.
  • Signed decision notices, letters of representation and older notices are uploaded as scans with no text layer, so the decision, its conditions and its date cannot be read by assistive technology.
  • Consultation documents designed for print use columns, pull quotes and boxed questions; without a set reading order the questions are read apart from the proposal they ask about, or skipped.
  • Financial tables in committee reports and schedules of affected properties, streets or trees have no header cells, so a figure or an entry is read without the row and column that give it meaning.
  • Options, zones or phases on a plan are distinguished only by colour, and a key made of coloured squares gives no text equivalent (WCAG 1.4.1).
  • The document title is a file name such as 'scan0042' and no language is set, and in bilingual notices, such as Welsh and English, the second language is not marked, so each passage is read with the wrong pronunciation (WCAG 2.4.2, 3.1.1 and 3.1.2).

Remediation checklist

  • Fix the notice template and the route from the case management system to PDF, so tags survive and the reading order starts with what is proposed, where, the reference and the closing date.
  • State in text what each map or plan shows: the address, the boundary described by the streets around it, or the roads closed and the diversion, either as alternative text or in the notice itself.
  • Give each committee pack a bookmark for every agenda item, real headings in every report, and a document title that names the meeting and its date.
  • OCR scanned decision notices and letters, check the recognised text against the page with particular care for dates, references and conditions, then tag it.
  • Set the reading order in consultation documents so that each question follows the proposal it asks about, and tag the questions so they can be found.
  • Tag financial tables and schedules with header cells, and state in text any meaning carried by colour on plans and charts.
  • Set the primary language, and mark each passage in another language so a bilingual notice is read correctly in both.
  • Check each notice against PDF/UA-1 and the WCAG AA success criteria that apply to PDF before the notice or consultation period starts, keep the signed record with it, and list anything not yet accessible in the accessibility statement.

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