Why scanned and untagged PDF agendas fail accessibility

Last reviewed 23 October 2026. General information for councils in England, not legal advice.

A scanned agenda looks fine on a clerk’s screen. It does not work for everyone who needs to read it. This guide explains why scanned or untagged PDFs fail, what the 2018 regulations say, and the options that fit a three-clear-days deadline.

In short

  • A scanned PDF is a picture. Screen readers hear nothing useful, and people cannot search or enlarge the text cleanly.
  • A PDF exported without accessibility tags has text but no real headings or lists.
  • The 2018 accessibility regulations cover documents on council websites. Office files published before 23 September 2018 are exempt unless they are needed for active administrative processes. Agendas and minutes for current meetings generally are.
  • Practical options: tag the PDF in Word, publish HTML alongside it, or use ClerkPages to turn the Word file or text-based PDF into an accessible web page.
  • This is not a compliance guarantee. Your council remains responsible for its website and its papers.

Why scanned and untagged PDFs fail

Scanning a printed agenda or a signed set of minutes produces an image of the page. There is no text underneath unless you run optical character recognition (OCR). A screen reader user hears nothing useful. Someone who needs larger text cannot enlarge the words without the image becoming blurry. Nobody can search for a planning application number.

GOV.UK’s Publishing accessible documents guidance says not to scan non-digital documents and convert them to PDF, because “users will not be able to search the content and it won’t be read by a screen reader”. If you only have a paper copy, it says to run OCR first. Even then, recognised text from a scan rarely has proper headings and lists.

A PDF exported from Word can look the same and still be different: the text is selectable. That is necessary, but it is not enough. Accessibility tags tell assistive technology what is a heading, a list or a table header, and in what order to read the page. Without them, a screen reader may read the file as one long stream.

The same GOV.UK guidance says HTML is “the most accessible format for publishing documents” and should be your first choice. PDF and PDF/A “cannot be made fully accessible to all users of assistive technology”. If you keep a PDF, publish an accessible version with it.

Signed minutes still matter. The Local Government Act 1972, Schedule 12, paragraph 41 is about the formal record, not about publishing a picture of the signature. Keep the signed paper. Publish the same text from the original Word file. Our guide to accessible minutes covers that in more detail.

What the 2018 regulations say about PDFs

The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (SI 2018/952) apply to websites of public sector bodies. GOV.UK guidance says that includes “central government and local government organisations”. Parish and town councils are local government. Small councils are not on the list of bodies that are exempt or partly exempt.

You must make websites “perceivable, operable, understandable and robust” and publish an accessibility statement. GOV.UK says a website meets the legal requirements if it meets WCAG 2.2 AA and has that statement.

PDFs sit inside that duty because they are content on the website. Regulation 4(3)(d) defines “office file formats” as documents “not intended primarily for use on the web”, “such as Adobe Portable Document Format, Microsoft Office documents or their open-source equivalents”.

The 23 September 2018 exemption

Regulation 4(2)(a) says the regulations do not apply to:

“office file formats published before 23rd September 2018, unless such content is needed for active administrative processes relating to the tasks performed by the public sector body”

GOV.UK puts the same idea in plainer words. You do not need to fix “PDFs or other documents published before 23 September 2018 — unless users need them to use a service, for example a form that lets you request school meal preferences”. You still need to explain the exemption in your accessibility statement.

Two tests, then: was the file published before 23 September 2018, and is it still needed for an active administrative process or to use a service? If the answer to the second question is yes, the date does not help you.

What that means for current agendas and minutes

Agendas and minutes for meetings you are about to hold, or have just held, are not old archive files. Residents use them to know what the council will discuss, to decide whether to attend, and to see what was resolved. That is ordinary council business, not unused archive content.

The Transparency Code for Smaller Authorities (turnover of £25,000 or less) says councils should publish agendas and papers at least three clear days before the meeting, and draft minutes within one month. Those documents are part of how the council works now. Our guide to what parish councils must publish online sets out the rest of that list.

Older minutes from before September 2018 are a different case. GOV.UK says they generally do not need fixing unless people need them to use a service. Say so in your accessibility statement, and offer another format on request. If an older paper is still needed for an active process — a live complaint, a current planning matter — treat that file as in scope. This guide cannot tell you how a court or the Equality and Human Rights Commission would decide a specific case.

Practical options for clerks

You do not have to replace your whole website. The 2025 Practitioners’ Guide (paragraph 5.123) notes that an authority “does not have to buy a new website to comply with accessibility law if it places a disproportionate burden on the authority”, but it must still publish and review an accessibility statement. For the papers, these approaches are realistic.

Start from a structured Word file

If you are writing a new agenda or set of minutes, use real heading styles and Word’s numbering from the start. Our free agenda and minutes templates are set up that way.

Tag the PDF you export from Word

Write the agenda or minutes with real heading styles, list styles and table headers. Run Word’s Accessibility Checker. Save as PDF with “Document structure tags for accessibility” ticked — Microsoft’s guide to creating accessible PDFs shows where. Open the PDF and check you can select and search the text. Describe the link on your website: “Agenda, Full Council, 12 March 2026 (PDF, 280KB)”. This is the minimum if you must keep a PDF. GOV.UK still prefers HTML.

Publish HTML alongside the PDF

Paste the same text into a page on your website and re-apply the headings and lists. The Wiltshire Association of Local Councils suggests pasting as plain text first, so Word’s hidden formatting does not come with it. Keep the PDF if members want a print-style copy.

Turn the Word file or text-based PDF into a web page

If HTML publishing on your current site is slow, a conversion tool can take the file you already have and publish it as a web page with proper headings, lists and tables. That is what ClerkPages is built to do. It cannot convert a scan or image-only PDF — you need the original Word file, or a text-based PDF.

Using ClerkPages

ClerkPages turns the Word agendas and minutes you already write — and text-based PDFs — into accessible HTML pages. Each document gets a permanent address you can link from your existing council website. £79 a year per council, excluding VAT.

The conversion handles headings, lists and tables well. Complex layouts may not convert perfectly. It will not catch every issue in your wording, and it is not legal advice. Check the page before you share the link. Your council remains responsible for its website and its papers.

Subscribe — £79 a year See an example

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