Making a single PDF accessible is a manageable task. Nine thousand is a strategic problem. That was precisely the figure at the top of the list when an insurer showed us its document archive some time ago – and it is by no means an outlier. When it comes to accessibility for old PDF collections, the real challenge is not the technical expertise, but the sheer volume. Public authorities with extensive archives and corporations with years’ worth of annual reports are faced with thousands of documents, all of which are subject to the same legal obligation. In this guide, I’ll show you the triage approach you can use to systematically sort through this mountain of documents – and which documents can be converted in batches and which absolutely require manual processing.
Why legacy files are the real problem with PDFs
In practice, the accessibility of PDF documents rarely fails because of individual new files – these can be created correctly from the outset. It fails because of the existing stock: thousands of documents that have accumulated over time, which were created over the years without any regard for accessibility and are now all subject to the BFSG or BITV. This vast volume cannot be ignored, nor can it be remediated manually within a reasonable timeframe. The only viable approach is structured prioritisation: identifying which documents are relevant at all, which are legally urgent, and which can be converted in batches.
The typical mistake: trying to sort everything out in one go
The most common mistake I see with large collections is the attempt to work through the entire pile in one go – chronologically, from top to bottom, without any preliminary sorting. This invariably results in a great deal of effort being poured into documents that nobody ever looks at again, whilst actively used forms remain unprocessed for months on end. If you have thousands of PDFs, you need to start with triage, not just hard work. I use the following logic to break the collection down into manageable groups.
The triage approach for large PDF collections
Triage means that, before any document is processed, each one is sorted according to the same four questions. Only then does the actual work begin – in the right places.
Step 1: Sort out what can be discarded
The first – and often most effective – question is: Is this document even needed any more? Outdated notices, expired forms, documents relating to discontinued services – much of this does not need to be digitised, but should instead be removed from the publicly accessible area or archived. Anything that is no longer made available to the public is not subject to the obligation. In practice, this step alone often reduces the volume of documents by thirty to fifty per cent.
Practical tip: Access Read checks whether your PDFs meet the machine-verifiable requirements of PDF/UA free of charge and without the need to register, with up to five files per check. Access Doc then formats any issues identified by the check to make them accessible.
Step 2: Sort by legal priority
What remains is sorted by urgency. At the top of the list are documents involved in active business and administrative processes: forms, applications, notices and frequently downloaded information sheets. These are the documents that users actually struggle with and which are the first to give rise to complaints. I have set out which services are actually covered by the requirements in ‘Accessibility as a Website Requirement 2026: Who is affected and who isn’t’ – this logic applies to documents just as much as it does to websites.
Step 3: Source document or PDF repair?
For every prioritised document, the next question is about the source. Does the original Word or InDesign document still exist? If so, it is often more efficient to recreate the document from the source in an accessible format, rather than repairing the finished PDF retrospectively. If only the PDF is available, PDF remediation comes into play. I describe how this works in detail in ‘Making PDFs accessible: a step-by-step guide to legally compliant documents’.
Step 4: Classify by complexity
Finally, files are sorted by technical complexity – and this is the crucial factor that distinguishes batch conversion from manual processing. A simple text-only PDF follows different rules to a 200-page annual report containing infographics. This classification determines which processing method is the most cost-effective.
What can be converted in batches and what cannot
This table is at the heart of the triage process. It shows which document type requires which processing route.
| Document type | Effort | Recommended procedure |
|---|---|---|
| Text-only PDF (letter, simple notification) | Low | Conversion via Access Doc with spot checks |
| Standard layout with simple tables/lists | Manageable | Conversion plus targeted follow-up checks of the tables |
| Interactive forms | Medium | Converted base, field logic and labelling done by hand |
| Annual Report, brochure with infographics | High | Manual remediation or recreation from the source |
| Complex, nested tables | High | Manual tagging of cell mappings |
| Scanned document without usable OCR | Pre-processing required | First OCR, then conversion or recreation |
The special case of the annual report
Annual reports are the pinnacle of document accessibility – and the reason why I warn against any ‘one-click’ promises. A typical annual report combines multi-column layouts, complex data visualisations, nested financial tables and elements positioned freely within the design. It is precisely these characteristics that overwhelm any off-the-shelf conversion tool. An infographic showing revenue trends requires a textual description of the trend depicted, not a generic caption. A balance sheet table with subtotals and multiple headers must be marked up manually to ensure its logical structure is preserved. Added to this is the high level of visibility: annual reports are aimed at investors and the general public, so an error-ridden document stands out particularly clearly in this context. For documents of this calibre, there is no alternative to manual work or recreating the document from the source file.
The special case of the authorities’ existing stock
Public authorities face the opposite problem: it is not the complexity of individual documents, but their sheer volume. Thousands of forms, statutes, minutes and notices, accumulated over decades, all falling under the BITV 2.0. This is where triage is particularly valuable, because a large proportion of the archive can be dealt with through systematic sorting and batch conversion – whilst resources remain available for the truly complex cases. It is crucial to identify early on which proportion of the archive falls into which category, rather than starting to process it blindly.
Where to start with large collections
The good news is that you don’t have to carry out this triage manually. That’s exactly what our PDF-Audit Access Read is for. It validates your documents in accordance with the Matterhorn Protocol and handles the classification: simple documents are flagged for conversion via Access Doc, whilst complex cases such as annual reports are identified as consultation cases requiring manual intervention. Instead of an insurmountable mountain of work, you’ll receive a sorted list with clear recommendations for action for each document – the basis for realistically planning your workload and budget.
This turns “we have thousands of PDFs and don’t know where to start” into a concrete, prioritised plan. And you invest your resources where they make the biggest difference, both legally and for your users – rather than in an archive of documents that nobody ever accesses anymore.
Lots of PDFs and not much time? In 30 minutes, we’ll show you how to make your documents accessible, from a single form to your entire collection.
