Five years ago, the 21st Century Integrated Digital Experience Act (IDEA) was introduced as Public Law 115-336. This was a bipartisan act to encourage agencies to build a framework and requirements for a digital-first public experience.
Reflecting on the 21st Century IDEA
Although much has changed since the 21st Century IDEA was introduced, not enough progress has been made toward its goals. All executive branch agencies were required to:
- Modernize their websites
- Digitize services and forms
- Accelerate use of e-signatures
- Improve customer experience
- Standardize and transition to centralized shared services
How PDFs Fail 21st Century Design
PDFs have been popular in government agencies since they were first introduced in the 90s. They are well entrenched into how agencies think about digital. PDFs are the easiest way to have a digital copy of a paper document or brochure. However, there have always been accessibility challenges with PDFs, as the format was not built for accessibility from the start. It is just too easy to produce PDFs, and far too difficult to determine which have been tagged for accessibility. They are regularly a problem for low vision and mobile users, and often present barriers to screen-reader users.
Since smartphones were introduced, PDFs have become even more problematic. From Analytics.USA.gov data, Apple’s iOS is now the second most popular operating system, followed by Android. Together, mobile traffic makes up 52% of traffic to government sites. Building mobile-friendly sites was identified as a priority five years ago, yet it is still an afterthought for many projects.
Some will argue that PDFs can be made accessible. Unfortunately, even if they are tagged for accessibility, they do not rescale well for either low vision or for mobile users. Unlike HTML or EPUB, the images and text simply do not adjust to the screen size or magnification preferences.
PDFs are currently embedded in all government sites and amount to over half of known page visits. PDFs are also still being used to collect and organize user information. PDF forms are quite common on government sites, often requiring specific versions of Adobe Acrobat to open them and frequently requiring specific versions of Adobe Reader in order to fill them in. This is clearly not meeting the need for digital forms that provide a good customer experience.
There are some efforts to reduce the number of PDFs in government, but without a clear call to action, that isn’t going to happen. It is just too easy to produce PDFs, and they are just too difficult to evaluate for accessibility. The documents can be developed by a small team, without involving centralized services, and often do not follow government standards.
September’s OMB Memo
Many of the same points were emphasized in September’s Office of Management and Budget (OMB) Memo M-23-22, Delivering a Digital-First Public Experience. The Biden Administration wanted to build on previous guidance to provide additional reasons for agencies to ensure their digital communications met current expectations. Agency sites were required to follow the following principles:
- Accessible to people of diverse abilities
- Consistent visual design and agency brand identity
- Content that is authoritative and easy to understand
- Information and services that are discoverable and optimized for search
- Secure by design, secure by default
- User-centered and data-driven design
- Customized and dynamic user experiences
- Mobile-first design that scales across varying device sizes
How PDFs Failed in 2023
PDFs are a fragile format that simply makes it harder for agencies to meet these priorities, particularly accessibility. According to the Spring 2023 Section 508 Program Maturity Report, inaccessible PDFs accounted for 56% of the “top 10” downloaded files at the 24 agencies subject to the Chief Financial Officer (CFO) Act, including the Departments of Defense, Treasury, Commerce, and State.
There is also often a problem where the source files for the PDFs are lost, which makes it hard to fix accessibility issues or update the brand identity. PDFs are also often harder to translate to other languages, making them more difficult for non-English speakers to understand. Without the source files, it also is difficult to modify content if users provide feedback.
Well-structured PDFs can be searched, but it is much easier for search engines to work with semantic HTML. Content in many PDFs will be skipped because the text is presented as an image. PDFs do not offer customizable user experiences. Authors like them largely because they can be confident that the documents are displayed consistently in a desktop environment.
A Clear Alternative
The UK Government publishing guide offers a clear example in their direction to “use the HTML5 standard to publish government documents.” Yes, there are exceptions. The UK government does still use PDFs from time to time, but there is a clear explanation as to why this should be avoided.
Although it doesn’t explicitly say not to use PDFs in either the 21st Century IDEA or Delivering a Digital-First Public Experience, it is difficult to actually follow the principles and continue to use them for government communications. Government agencies must move past PDFs to not only meet these Section 508 compliance standards, but to fulfill the promise of government services being accessible to all.
Mike Gifford is a Senior Strategist at CivicActions and a thought leader on digital accessibility in the public sector. Previously, he was the Founder and President of OpenConcept Consulting Inc., a web development agency specializing in building open source solutions for the open web. OpenConcept was an impact driven company and Certified B Corporation. Like CivicActions, OpenConcept worked extensively with the Drupal CMS. Mike was also part of the Government of Canada’s Open Source Advisory Board. Mike spearheaded accessibility improvements in Drupal since 2008, and officially became a Drupal Core Accessibility Maintainer in 2012.
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