Every year, thousands of digital documents circulate in Luxembourg – reports, forms, brochures, presentations – without their authors ever asking whether a blind, visually impaired, or motor-disabled person will be able to read them. Yet producing an accessible document is often no longer optional: it has been a legal obligation for the public sector since 2019, and for many private businesses since 28 June 2025.
In this article, I explain what an accessible digital document actually is, why it matters strategically for your organisation in Luxembourg, and which standards apply to your PDF, Word and PowerPoint files.
What is an accessible document, and why does it matter in Luxembourg?
Definition: much more than “readable”
An accessible document is a digital file, like PDF, Word, PowerPoint or otherwise, that any person can read, understand and use, including with assistive technology. In practice, this covers:
- screen readers (JAWS, NVDA, VoiceOver) used by blind or visually impaired people;
- magnification software for people with low vision;
- keyboard-only navigation, without a mouse, for people with motor impairments;
- braille displays, which render text in tactile form.
For a document to be truly accessible, it must be structurally tagged (headings, paragraphs, lists), include text alternatives for every informative image, present a logical reading order, and ensure sufficient colour contrast.
A document that looks fine on screen can therefore be completely unreadable for a screen reader user if its internal structure is empty or incoherent.
The Luxembourg legal framework: two laws to know
Luxembourg has put in place a solid legal framework for digital accessibility.
The law of 28 May 2019 requires all Luxembourg public bodies to make their websites and mobile applications accessible. It also covers documents published on those sites. The supervisory body is the Government Information and Press Service (SIP).
The law of 8 March 2023, transposing the European Accessibility Act (EAA, Directive 2019/882), introduces obligations for a wide range of products and services offered by organisations in Luxembourg. It came into force on 28 June 2025 and applies to all companies with more than 10 employees or exceeding €2 million in annual turnover or balance sheet total. Penalties can reach €500,000, or double in the event of a repeat offence.
Luxembourg standards: RAWeb, RAPDF, RAAM
To support the implementation of these obligations, Luxembourg has developed three technical frameworks:
- RAWeb: 136 criteria for websites, based on the European standard EN 301 549 and WCAG 2.1/2.2;
- RAPDF 1.1: 46 criteria specific to PDF documents, aligned with section 10 “non-web documents” of EN 301 549 and with the ISO PDF/UA-2 standard;
- RAAM: 108 criteria for mobile applications.
These frameworks are freely available on the accessibilite.public.lu portal and form the basis of any conformance evaluation in Luxembourg.
The concrete benefits of accessible documents for your organisation
Reaching 100% of your audience
A 2017 study by Access42 on screen reader usage1 in French-speaking countries revealed a striking reality: three quarters of blind or visually impaired people report having problems with PDF documents, occasional or recurring problems. 64% say they can only read them sometimes, depending on the quality of the file. 2% never open PDFs, finding them too inaccessible.
These figures illustrate a common paradox: PDF is widely used to distribute official information like invoices, reports andforms. Yet it is the format hardest to make accessible.
Taking care of the accessibility of your documents simply means ensuring that your entire audience can access your message. This also applies to older people, mobile users, and anyone consulting your files in difficult conditions.
Reducing errors and support requests
In healthcare, social services, public administration or finance, an incomprehensible or inaccessible document is costly. A form filled in incorrectly, a summons ignored, a medical notice misunderstood: these situations generate avoidable human and administrative costs.
A well-structured document reduces back-and-forth, requests for clarification and the risk of error. That is a measurable time saving for your teams and for your clients or beneficiaries.
Meeting a legal obligation and avoiding sanctions
Since 28 June 2025, Luxembourg companies covered by the accessibility law must make their digital services accessible. This obligation is not theoretical: the Office for the Supervision of Accessibility of Products and Services (OSAPS) is responsible for enforcement and may impose administrative and criminal penalties.
Failing to act exposes your organisation to a real legal risk. Investing in document accessibility now means securing your compliance at the lowest cost.
Strengthening your image and social responsibility
An organisation that communicates clearly and accessibly projects an image of trust and ethical commitment. In Luxembourg, where the economic fabric includes many non-profits, public institutions and SMEs in direct contact with vulnerable populations, this commitment has tangible value.
Document accessibility is also a question of coherence: you cannot champion inclusion on one hand while distributing PDF files that are unreadable for a third of your audience on the other.
PDF, Word, PowerPoint: the most common mistakes
PDFs: a popular format, full of pitfalls
PDF is arguably the most widely used and most problematic format for accessibility. The figures speak for themselves: according to the SIP’s 2022–2024 audit report, inaccessible PDF documents are by far the leading reason cited by public sector bodies to justify a disproportionate burden, ahead of all other accessibility issues. The same report reveals that 57% of public bodies acknowledge that not all their PDF and Office documents comply with the accessibility standard, and that an accessible alternative will only be provided on request.2 Inaccessible PDFs are also the most common source of citizen complaints, whether involving forms, image-mode scanned documents, or untagged files.
These findings are consistent with an earlier SIP investigation: a 2023 analysis of the most-visited public websites found that the vast majority of PDFs published were inaccessible.3
Three types of problem recur systematically.
The untagged PDF is the most common case. PDF was originally designed as a print format. It was not until 2001 that a new version introduced the concept of tagging, which provides assistive technologies with structured information about page content. Without this structure, content is not rendered and navigation is impossible for screen reader users. Adobe Reader attempts automatic structuring, but the results are often unsatisfactory. All major office suites and desktop publishing software are capable of exporting tagged PDFs — the problem is that this option is rarely activated by default.
The image PDF is created by scanning a paper document: it contains no selectable text and no structure. For a screen reader, the document is empty. The only solution for the user is to resort to OCR (optical character recognition) software, involving extra steps, uncertain reliability and a considerable loss of time.
The protected PDF presents a third obstacle. Many automatically generated documents (bank statements, invoices) have the “Content Accessibility Enabled” property set to “not permitted”. The result: reading via speech synthesis or braille display is impossible, even without an opening password. This protection can be activated by mistake, and should be avoided as a general rule.
For a PDF to comply with the Luxembourg RAPDF 1.1 standard, it must be tagged (headings, lists, tables, image alternatives), have a document title, a coherent reading order, and correctly declare the language.
Word and LibreOffice: structure first
An accessible Word document starts with a correct heading structure: never simulate a heading by making text bold and large. Always use native heading styles (Heading 1, Heading 2, etc.). This structure is then exported into any PDF generated from the file.
Other critical points:
- Every informative image must have a relevant text alternative (not “image1.jpg” or “photo”).
- Data tables must have a correctly declared header row.
- Bullet lists must use native list styles, not manually typed hyphens.
- Hyperlinks must have a descriptive label (not “click here”).
The built-in accessibility checker in Word and PowerPoint is useful for detecting certain errors, but it is not sufficient. It can flag false positives, overlook real problems (such as a non-relevant text alternative), and does not check the coherence of the heading structure.
PowerPoint: the invisible enemy – reading order
In PowerPoint, the number-one enemy is reading order. This is not the visual order of elements on the slide, but the order in which they were inserted. If you add an introduction after the body text, it will be read last by the screen reader, even if it appears visually first.
On Windows, the Reading Order pane (Accessibility menu) lets you view and correct this order. On macOS, the display has historically been reversed: the first element read is the last in the list. Recent versions of PowerPoint appear to have fixed this behaviour. Check before finalising your document.
Another frequently overlooked point: elements placed in the slide master are not rendered by assistive technologies. Only redundant decorative elements belong there.
How Key4.lu supports you with accessible documents in Luxembourg
I offer organisations in Luxembourg training courses to make their digital documents accessible.
Training courses available on request:
- Digital accessibility for your organisation
- Communicating accessibly on social media
- Creating accessible PDF documents
My approach combines technical expertise with a pedagogical perspective. I work with the reference tools: PAC (PDF Accessibility Checker), the native Microsoft and LibreOffice checkers, and the Luxembourg frameworks RAPDF 1.1 and RAWeb. I avoid using Adobe Acrobat Pro in order to keep costs down for SMEs and non-profit organisations.
My commitment as an expert
Over many years working in digital accessibility in Luxembourg, I have seen countless documents distributed in good faith that were completely inaccessible to part of their intended audience. Annual reports published as untagged PDFs, for instance.
These situations are not the result of ill will. They stem from a lack of method and training. That is precisely what I offer: concrete, transferable skills for your teams, so that accessibility becomes a production reflex rather than a corrective project.
FAQ – Your questions about accessible documents in Luxembourg
What exactly is an accessible document?
An accessible document is a digital file (PDF, Word, PowerPoint…) that any person can read, navigate and understand – including using a screen reader, a braille display, or keyboard navigation without a mouse. This requires correct semantic structure (headings, lists, tables), text alternatives for images, a logical reading order, and sufficient contrast. Accessibility is not only for people with disabilities: it improves the experience for everyone.
Are PDF documents necessarily covered by Luxembourg law?
Yes. For the public sector since 2019, and for private companies since June 2025. A PDF published on a website or transmitted as part of a service falls under accessibility obligations. In Luxembourg, the reference framework for PDFs is RAPDF 1.1, developed by the Government Information and Press Service. It contains 46 control criteria and is based on EN 301 549.
How much does it cost to remediate an inaccessible document?
The cost depends on the complexity of the document: a simple Word file takes a few hours; a multi-page PDF with tables and forms may require a full day or more. The key point: making a document accessible after the fact always costs more than creating it correctly in the first place. Training your teams in good practices is the most cost-effective investment in the long run.
My Word document looks great, but is it accessible?
Not necessarily. A document can be visually perfect and structurally empty for assistive technology. The most common errors: using bold text to simulate headings (without native heading styles), manually typing lists with hyphens, omitting text alternatives for images, or using colours without sufficient contrast. Word’s built-in checker helps, but does not catch everything.
What is the difference between PDF/UA and RAPDF?
PDF/UA (ISO 14289, now in version 2) is the international standard that defines the technical accessibility requirements for PDF files. RAPDF 1.1 is the operational Luxembourg framework that allows conformance with EN 301 549 (section 10) to be verified, and includes mappings to PDF/UA-2. RAPDF translates normative requirements into concrete, reproducible test criteria.
Can LibreOffice be used to create accessible documents?
Yes. LibreOffice Writer and Impress include an accessibility checker (Tools menu) and allow well-structured documents to be created. The principles are the same as with Microsoft Office: heading styles, image alternatives, native lists, language declaration. Exporting to PDF from LibreOffice can produce tagged files, provided the correct options are selected at export.
What tools should I use to check PDF accessibility?
The reference tool is PAC (PDF Accessibility Checker), which is free and analyses the file structure along with a screen reader preview. Adobe Acrobat Pro allows more advanced corrections (editing the tag tree, fixing table headers, adding alternatives). For contrast checks, the Colour Contrast Analyser from TPGi is recommended.
What does my organisation risk if its documents are not accessible?
For the public sector, the SIP may record non-conformance in its audit report, with a remediation requirement. For private companies subject to the law of 8 March 2023 (in force since June 2025), the OSAPS may prohibit the provision of the non-compliant service or product and impose criminal penalties of up to €500,000, or €1 million for a repeat offence. The fine is proportional to the severity of the breach.
Conclusion: act now, for every reader
Producing accessible documents in Luxembourg is not optional. It is a legal requirement, an act of inclusion, and a mark of professionalism. Whether you produce institutional PDFs, PowerPoint presentations or Word forms, the same principles apply: structure, alternatives, reading order, contrast.
Explore my digital accessibility training courses to build lasting expertise within your team.
- Study on screen reader usage in France and French-speaking countries, Access42, Fédération des Aveugles et Amblyopes de France, June 2017. access42.net ↩︎
- Contrôle de l’accessibilité des sites Internet et applications mobiles du secteur public au Luxembourg, période 2022–2024, Service information et presse (SIP), January 2025. accessibilite.public.lu ↩︎
- PDFs often inaccessible on most visited websites, SIP, April 2023. accessibilite.public.lu ↩︎