Short answer: if you're a public sector body, yes — the law names office documents explicitly, and it requires more than a mention. If you're a private company newly in scope under the EAA, the obligation is real but doesn't go by the same name. Either way, a statement that only talks about the website and stays silent on the documents is skipping the part of the site that, in our own measurements, breaks the most.
What the law actually says
The Web Accessibility Directive (EU) 2016/2102 requires public sector bodies to publish a statement, and Article 7(1) is specific about what "publish a statement" means. Member States must ensure bodies "provide and regularly update a detailed, comprehensive and clear accessibility statement," and the statement has to include three things: an explanation of which parts of the content aren't accessible and why, "a description of, and a link to, a feedback mechanism enabling any person to notify the public sector body concerned of any failure," and a link to the enforcement procedure to use if the response is unsatisfactory. That's not a suggestion for good practice — it's the text of the article.
Recital 26 of the same directive defines what's covered: "Office file formats should be understood as documents that are not intended primarily for use on the web and that are included in web pages, such as Adobe Portable Document Format (PDF), Microsoft Office documents or their (open source) equivalents." PDFs aren't a grey area here. They're named.
There's a carve-out, and it's worth knowing precisely because it's not "PDFs are exempt." Article 1(4)(a) excludes "office file formats published before 23 September 2018, unless such content is needed for active administrative processes relating to the tasks performed by the public sector body concerned." A council minutes PDF from 2015 that nobody references any more is out of scope. The same PDF, if it's still the document someone needs to submit a form or claim a benefit, is not — regardless of its age. That "unless" clause is where a lot of statements quietly get this wrong, in both directions: treating every old document as covered, or every document as exempt.
The private-sector layer arrived more recently
The European Accessibility Act (EU) 2019/882 has applied since 28 June 2025 — Article 31(2) sets that date for when Member States' transposing measures take effect. It's the first EU-wide accessibility law reaching into the private sector, covering (Article 2(2)) electronic communications, banking services, e-books, and e-commerce, among others. Article 2(4)(b) carries a matching exclusion for "office file formats published before 28 June 2025" — but note what it doesn't say: unlike the public-sector directive, the EAA's text doesn't attach an "unless still in active use" exception to that date. Read the exact clause before assuming the two cut-offs work the same way.
One more distinction that trips people up: the EAA never uses the phrase "accessibility statement." Search the whole directive and it isn't there. What it requires instead (Article 13(2)) is that service providers "prepare the necessary information in accordance with Annex V and shall explain how the services meet the applicable accessibility requirements," made available to the public. Annex V says that information normally lives in the general terms and conditions. So if you're a private company newly in scope, you likely need something functionally similar to a statement — but you won't find a template called "accessibility statement" waiting for you in the law that covers you. We've laid out what's actually in scope and what isn't on our EAA compliance page.
What we found when we went looking
The wide picture, from our earlier crawl of Hungarian public-sector PDFs: 1,682 municipal websites, 8,469 PDFs, checked against four cheap signals — scanned image, missing structure tree, no title, no declared language. Sixty-four percent of the files had at least one of those problems. Only 39 of the 1,215 sites that publish any PDF at all came back clean. Documents are, by a wide margin, the part of these sites most likely to fail — which is exactly the part a website-only statement leaves out.
So we checked the statements themselves, on 8 September 2026. We sampled 45 of the same municipal sites, looked for a link containing "akadálymentes" (accessible) on the homepage, and — where we couldn't find one — tried the conventional URL paths Hungarian public bodies use for this page. One request per second, a real user agent identifying the research.
We found a plausible statement page on eight of the 45 sites. Reading them by hand cut that down further: on five, what we'd found wasn't actually a statement — a stale link that resolved back to the homepage, a page from an old "accessible reading mode" toggle, or an unrelated announcement that happened to share a URL pattern. On two more, the page existed, was titled correctly, and said nothing: "Content upload in progress. For more information, please contact the municipality." That's the whole text.
Funnel from a sample of 45 Hungarian municipal websites, checked on 8 September 2026. 45 sites were sampled. 8 had a plausible accessibility statement page. 5 of those turned out not to be statements at all, leaving 3. 2 of those 3 were empty placeholders, leaving 1 statement with real content — the same one that names PDF documents.
That left one. It named the specific gap — "some content generated by the content management system (for example, downloadable PDF documents) is not always fully accessible" — gave a contact address, promised a response within 15 working days, and linked to the national enforcement body. It's the only statement in the sample of 45 that mentioned a PDF by name, and it's a genuinely good example of Article 7(1) done properly. We're not naming the site — with 39 clean sites out of 1,215 in the wider crawl, this isn't a story about which town got it right or wrong, and we'd rather show you the shape of a good paragraph than point at one municipality's homework.
Why "we strive to be accessible" doesn't satisfy the law it's trying to satisfy
That sentence shows up constantly, and it isn't just weak — measured against Article 7(1)'s own words, it fails on its own terms. The article asks for "detailed, comprehensive and clear." A sentence with no specifics is none of those three. It doesn't explain which parts aren't accessible, so it doesn't meet requirement (a). It doesn't describe a way to ask for what's missing, so it doesn't meet (b). It doesn't link anywhere if the response is unsatisfactory, so it doesn't meet (c). Nothing about it satisfies the article — it's just a sentence occupying the space where a statement should be.
It also fails the person reading it. Someone who can't open a specific PDF doesn't learn whether that's a known issue, who to contact, or how long a fix takes. "We strive to be accessible" answers a question nobody asked and skips the one that mattered.
A paragraph you can adapt
This follows the three things Article 7(1) requires. Fill in the brackets for your organisation and your national enforcement body — the structure holds regardless of country or language, which is the point.
Documents
Documents published on this website before [date] have not all been checked against
PDF/UA-1 and may not work correctly with a screen reader or other assistive technology.
We are working through them in order of how often they are downloaded. Documents
published after [date] are checked before they go online.
If you need a document in an accessible format, or you've found one that doesn't work
with your assistive technology, contact us at [email / phone] and we will provide it,
or an accessible alternative, within [X working days].
If you're not satisfied with our response, you can raise it with [name of the national
enforcement body], via [link].
Two things make this different from the vague version. First, it's checkable: a visitor — or an auditor — can tell whether the date is accurate and whether the promised response time was kept. Second, it commits to something. "We strive" commits to nothing; "checked before they go online" is a claim someone could catch you failing, which is precisely why it belongs in the statement instead of the marketing copy next to it.
If you want to know what "checked against PDF/UA-1" should actually mean before you put it in writing, our PDF accessibility checker runs the same kind of structural check — tagging, title, language, alt text — against a file you drop in, without uploading it anywhere.
The honest limitation
Two, actually. First, our sample: we manually confirmed three genuine statement pages out of 45 sites, and one of those said anything specific about documents. That is nowhere near enough to claim a percentage for "how many statements mention PDFs" — we're not going to dress up an n of three as a national figure. What we can say, plainly, is what we saw: on this sample, finding a statement that addressed documents at all was hard, and most of what stood between "hard" and "found" was either silence, a broken link, or a placeholder saying the content wasn't there yet. A larger, structured survey might land somewhere else; ours doesn't reach that.
Second, the law itself: nobody yet knows exactly how strictly "active administrative processes" in Article 1(4)(a) will be read once it's tested. The EAA has only applied since 28 June 2025, and cross-border enforcement practice for either directive is still thin. If someone tells you with total confidence which of your five-year-old PDFs are in scope, they're further ahead of the regulators than the regulators are.
Where to start
Open your own accessibility statement and search it for the word "document" or "PDF." If it isn't there, that's the gap to close first — not because a checklist demands it, but because the files behind that silence are, by a wide margin, the least accessible part of most public-sector sites we've measured. Check whether the EAA reaches your organisation on our EAA compliance page, then run your most-downloaded document through the PDF accessibility checker before you write down what "checked" means.
