Paper and PDF forms to accessible online forms: a guide for councils

Why PDF forms fail users

A PDF form looks like the paper version, and that is its main problem. On a phone it has to be zoomed and scrolled, it often does not work well with screen readers, and many people end up printing it, filling it in by hand, scanning it and emailing it back. In 2018 the Government Digital Service explained why GOV.UK content should be published in HTML rather than PDF: PDFs are harder to find, use and maintain, do not adapt well to small screens and are less likely to be kept up to date.

The GOV.UK guidance on publishing accessible documents goes further: HTML should be the first choice, and PDF cannot be made fully accessible to every user of assistive technology. For a council the cost also shows up in the back office: incomplete forms, phone calls to explain them, and staff retyping answers into another system.

What the 2018 regulations require

The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 apply to public sector bodies, including local councils. According to the GOV.UK guidance, their websites and apps must meet WCAG 2.2 level AA, and each must have an accessibility statement.

This is a summary for orientation, not legal advice; take legal advice for your case. The points that matter most for forms:

• Old documents: PDFs and other documents published before 23 September 2018 are exempt, unless people need them to use a service. GOV.UK gives a school meal preferences form as an example of a document that is not exempt.
• New documents: PDFs published since then have to be accessible.
• Disproportionate burden: you can only claim it after a documented assessment that weighs the cost against the benefit to disabled users. Lack of time or knowledge does not count.
• Monitoring and enforcement: the Government Digital Service checks a sample of public sector websites and apps each year. The Equality and Human Rights Commission enforces in England, Scotland and Wales, the Equality Commission for Northern Ireland in Northern Ireland.
• Equality Act: the duty to make reasonable adjustments under the Equality Act 2010, or the Disability Discrimination Act 1995 in Northern Ireland, applies in addition.

The WCAG 2.2 criteria that matter most for forms

WCAG 2.2 became a W3C Recommendation in October 2023. Level AA means meeting all success criteria at levels A and AA. For forms, these criteria do most of the work:

Step by step: from PDF to online form

If you have many forms, do not start with the hardest one. Start with a form that is used often and causes a lot of follow-up work.

1. 1List your forms: where each one is published, how often it is used, who processes it and whether people need it to use a service.
2. 2Pick a first form: high use, frequent follow-up questions or retyping, and a clear owner in the service team.
3. 3Write a question protocol: for each question, why you need it, who must answer it and what happens with the answer, as the GOV.UK Service Manual describes. Remove what nobody uses; under the UK GDPR, personal data must be limited to what is necessary.
4. 4Order the questions: eligibility first, then one thing per page where it helps, with branching so people only see questions that apply to them.
5. 5Add checks and clear errors: required fields, formats, amounts and dates, with error messages that follow the GOV.UK validation pattern.
6. 6Plan uploads, review and confirmation: file checks, a check answers page, a confirmation and a copy for the applicant.
7. 7Decide where the data goes: into a case management system, a spreadsheet export or the right team's inbox, without retyping.
8. 8Keep another route: a phone number or assisted route for people who cannot use the online form, and say so on the form page.
9. 9Retire the PDF: remove old versions from your website, so nobody fills in last year's form.

Testing before launch

Automated checkers such as Axe or WAVE find missing labels and contrast problems quickly, but the GOV.UK Service Manual warns that you miss some issues with automated testing alone. Plan four kinds of test:

• Automated check of every page of the form and every error state.
• Keyboard test: complete the form without a mouse, including errors and uploads.
• Assistive technology: a screen reader, for example NVDA on Windows or VoiceOver on Apple devices, plus speech recognition and screen magnification.
• Research with disabled and older people: the Service Manual expects it for services that follow the Service Standard, and it finds problems no tool will.

Write the accessibility statement

Every public sector website needs an accessibility statement, published as an HTML page. According to GOV.UK, it must say whether the site is fully, partially or not compliant, what does not comply and why, how people can get alternatives to inaccessible content, how to report problems, and where to go if they are not happy with your response. GOV.UK calls it good practice to link to the statement from every page, for example in the footer. Review it after major changes and at least once a year. GOV.UK publishes a sample statement.

For forms, be specific: name the form, the problem and your plan to fix it, rather than a general sentence about ‘some PDFs’.

Build, buy or configure

There are three common routes. Council form platforms and case management systems often include a form builder; check how their forms perform against WCAG 2.2 AA before you buy, not after. GOV.UK Forms describes itself as free for central government; check whether it is open to your organisation. A custom online form makes sense where your rules, branching or back-office connections do not fit a platform.

Whichever route you choose, ask the supplier for the product's accessibility statement, an audit report against WCAG 2.2 AA and an example form you can test with a keyboard yourself.

Where Schwerpunkt can help

We are a small software company in Berlin. We build guided online application forms to WCAG 2.2 AA, with eligibility checks, validation, uploads, a review page, a PDF copy and a staff portal with CSV export, and we audit existing forms with a report and fixes. Our reference is an online application assistant for a German federal funding agency, built, accepted and handed over.

You can try an English demo with a fictional trust. We do not issue certificates. After a no-obligation intro call we quote a fixed price for each stage; contact us to arrange one.