Accessible documents policy

Accessible documents at HM Revenue and Customs (HMRC).

This policy explains how accessible the documents HM Revenue and Customs (HMRC) publishes on GOV.UK are.

It covers PDFs, spreadsheets, presentations and other types of document. It does not cover content published on GOV.UK as HTML: the main GOV.UK accessibility statement covers that.

Using our documents

HMRC publishes documents in a range of formats, including:

  • PDF
  • Microsoft Word
  • Microsoft Excel spreadsheets
  • CSV (Comma-Separated Values)
  • ODT (OpenDocument Text)

We want as many people as possible to be able to use these documents. For example, when we produce a document we make sure we:

  • provide an HTML option where possible
  • tag headings and other parts of the document properly, so screen readers can understand the page structure
  • make sure we include alt text alongside non-decorative images, so people who can’t see them understand why they’re there
  • avoid using tables, except when presenting data
  • write in plain English

How accessible our documents are

New documents we publish and documents you need to download or fill in to access one of the services we provide should be fully accessible.

However, we know that some of our older documents (published before 23 September 2018) are not accessible. For example, some of them:

  • are not marked up in a way that allows screen reader users to understand them
  • are not tagged up properly - for example, they do not contain proper headings
  • are not written in plain English
  • contain images without a textual description
  • include complex tables

This mostly applies to our:

  • corporate reports
  • research and analysis reports
  • statistics

These types of documents are exempt from the regulations, so we do not currently have any plans to make them accessible.

But if you need to access information in one of these document types, you can contact us and ask for an alternative format.

What to do if you can’t use one of our documents

If you need to access information in one of these document types, you can contact us and ask for an alternative format. It will help us if you tell us what assistive technology you use.

Reporting accessibility problems with one of our documents

We’re always looking to improve the accessibility of our documents. If you find any problems that aren’t listed on this page or you think we’re not meeting accessibility requirements, contact our digital publishing team.

Enforcement procedure

The Equality and Human Rights Commission (EHRC) is responsible for enforcing the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (the ‘accessibility regulations’). If you’re not happy with how we respond to your complaint, contact the Equality Advisory and Support Service (EASS), or the Equality Commission for Northern Ireland (ECNI) if you live in Northern Ireland.

Technical information about the accessibility of our documents

HMRC is committed to making our documents accessible, in accordance with the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.

The documents HMRC publishes are partially compliant with the Web Content Accessibility Guidelines version 2.1 AA standard, due to the non-compliances listed below.

Non-accessible content

The content listed below is non-accessible for the following reasons.

Non-compliance with the accessibility regulations

Success criterion 1.1.1: non-text content

Some of our documents have diagrams and/or tables. Some of these do not have a text alternative, so the information in them isn’t available to people using a screen reader. This doesn’t meet WCAG 2.1 success criterion 1.1.1 (non-text content).

We plan to add text alternatives for all diagrams and tables by September 2020. We will ensure they meet accessibility standards.

Success criterion 1.3.1: info and relationships

Some of our documents don’t identify headings, lists or data tables correctly. This means users using screen readers may not be able to follow the structure of a document, which in turn may affect their ability to access and understand the information. This doesn’t meet WCAG 2.1 success criterion 1.3.1 (info and relationships).

We plan to ensure all our documents have a correct structure, so that they are accessible to users using assistive technologies, by September 2020.

Success criterion 1.3.3: sensory characteristics

Some of our documents use sensory characteristics, such as colour, shape, or size, to convey information. This means users with visual access needs may not be able to understand the information. This doesn’t meet the WCAG 2.1 success criterion 1.3.3 (sensory characteristics).

We plan to ensure that our documents will not rely solely on sensory characteristics to convey information by September 2020.

Success criterion 1.4.5: images of text

Some of our documents and pages contain images of text to convey information, rather than plain text. This means users who either use a text-only browser or use assistive technology may not be able to understand the image of text. This doesn’t meet WCAG 2.1 success criterion 1.4.5 (images of text).

We plan to ensure that none of our documents and pages use images of text to convey information only by September 2020.

Some links in our documents do not contain context in the link text. This makes it hard for users using assistive technology to understand what the link is for, and where they would be directed to if they clicked on it. This doesn’t meet the WCAG 2.1 success criterion 2.4.4 (link purpose (in context)).

We plan to give all our links context so that their purpose can be determined from the link text by September 2020.

Success criterion 4.1.2: name, role, value

Some of our documents are not structured properly. This means they may not be accessible for users using screen readers or other assistive technology. This doesn’t meet WCAG 2.1 success criterion 4.1.2.

We plan to give our documents a proper structure so that users using screen readers or other assistive technology can access them, by September 2020.

Documents produced by third parties

Some of the documents we publish are produced by third parties, for example some research reports. We are not always able to make these fully compliant, for example adding alternative text to images or diagrams. This doesn’t meet WCAG 2.1 success criterion 1.1.1 (non-text content).

We are informing third party suppliers of our accessibility requirements, but sometimes we have to publish documents at short notice that are not accessible. Where possible, we will fix these as soon as we can.

Content that’s not within the scope of the accessibility regulations

Some of our older documents don’t meet accessibility standards. For example, they:

  • do not contain alternative text for diagrams and/or images – this does not meet WCAG 2.1 success criterion 1.1.1
  • use images of text, rather than plain text – this does not meet WCAG 2.1 success criterion 1.4.5
  • are not structured properly – this does not meet WCAG 2.1 success criterion 4.1.2

The accessibility regulations do not require us to fix PDFs or other documents published before 23 September 2018 if they’re not essential to providing our services. For example, we don’t plan to fix our annual reports and accounts.

Any new PDFs or Word documents we publish will meet accessibility standards.

How we tested our documents

We tested a sample of our documents in August and September 2019. The test was carried out by HMRC’s digital content team.

We tested:

  • PDF documents
  • Microsoft Excel documents

We decided to test these types of document as they are the main non-HTML formats published by HMRC.

What we’re doing to improve accessibility

HMRC is:

  • updating corporate Word and PDF templates to be accessible
  • publishing reports in HTML by default where possible, rather than PDF
  • providing CSV alternatives to Excel spreadsheets, and improving the way we structure these type of files
  • raising awareness and improving accessibility skills across the department
  • testing publications with assistive technology software users

We will continue to review and update this policy as our work progresses.

This page was prepared on 20 September 2019. It was last updated on 23 September 2019.