Taking stock with a website scan, setting priorities by downloads, currency and legal obligation, ongoing monitoring – and the question of what to replace, delete or archive.
Keeping your PDFs under control for good means: you know which PDFs are on the website, you work through them according to transparent priorities, new documents are checked before publication, the website is monitored automatically on a regular basis, and the accessibility statement reflects the current situation. A one-off clean-up is not enough, because new PDFs are added every week – from specialist departments, the council information system (Ratsinformationssystem, the system German councils use to publish meeting documents), the forms server and from service providers.
Step 1: Taking stock
PDFs are rarely stored in just one place. Typical locations are the media library of the content management system, the council information system, citizen service and forms portals, public notice pages, older project and campaign pages on their own subdomains – and links within other PDFs.
- Website scan: a crawler follows all links and records every linked PDF file together with the page on which it was found.
- Limits of the crawl: it only finds what is linked. Files that are still in the media library and can be reached via search engines are nevertheless public – compare the scan with the media library.
- Record for each file: address, page where it was found, number of pages, publication date, responsible office and check result. The creation date in the PDF metadata is only an indication; what matters is when the file was published.
Step 2: Prioritising
Nobody expects thousands of files to become accessible overnight. What is expected is a recognisable, well-founded approach. Proven criteria:
- Relevance to procedures: forms, applications, by-laws and fee schedules in force, notices for ongoing procedures – such as the public display of a local development plan (Bebauungsplan). They come first.
- Downloads: the most downloaded files according to web statistics or server logs reach the most people.
- Target group: information on care, participation, elections or emergencies is needed particularly often by people with disabilities.
- Publication date: files published before 23 September 2018 are exempt under EU Directive 2016/2102, as long as they are not needed for active administrative processes.
- Effort: a PDF that only lacks tags, title and language is done quickly; a poorly scanned expert report is not. Pick up quick wins early.
This results in three groups: A remediate immediately, B remediate according to a schedule, C delete, archive or name as an exception in the statement.
Step 3: Replace, delete or archive?
- Replace: the accessible version replaces the old file, ideally at the same address – links, bookmarks and search results remain valid. If the address changes, the old one needs a redirect.
- Delete: expired tenders, flyers for past events, outdated versions. Taking something off the website does not mean deleting it from the files – retention obligations concern record-keeping, not the website.
- Archive: the Directive also exempts content of websites that qualify as archives because they only contain content that is neither needed for active administrative processes nor updated or edited after 23 September 2019. A clearly labelled archive section that is no longer changed makes this traceable. You should check how the law of your German state (Land) implements this exemption.
- HTML instead of PDF: short pieces of information often do not belong in a PDF at all, but directly on the page – this is usually the most accessible solution.
Step 4: New PDFs right from the start
- Provide accessible document templates and train the editorial team (Word guide, training courses).
- Make checking before upload a fixed step in the editorial workflow.
- Where possible, connect the content management system so that uploaded PDFs are checked and remediated automatically (API and integration).
- Clarify responsibilities: who is responsible for a department’s files, and who approves them?
Step 5: Ongoing monitoring
Even with a good process, files slip through: a notice posted at short notice, a service provider replacing a brochure, an attachment in the council information system. Regular, automatic monitoring – often called ‘Continuous Accessibility’ – detects new, changed and removed PDFs and reports inaccessible files before a complaint does. The interval depends on how often you publish: daily for websites with ongoing public notices, weekly or monthly for quieter sites. The last step is the important one: the corrected version must actually replace the file on the website.
Step 6: Updating the accessibility statement
The accessibility statement names which content is not accessible, why, and by when this is to change. With ongoing monitoring, it can be filled with up-to-date figures – and it has to be reviewed regularly. Instructions and sample wording: The accessibility statement in 30 minutes.
Common mistakes
- The clean-up is a one-off project with no process for new files.
- The location is unknown – the repaired version never replaces the original.
- New addresses without redirects: links and search results lead nowhere.
- The entire legacy collection is declared an ‘archive’ across the board, even though it includes forms and by-laws.
- Mass deletions without considering relevance to procedures.
- The accessibility statement quotes figures from two years ago.
How DokAudit helps
The free website scan finds the PDFs on your website – or only the PDFs of specific pages from a list of URLs – and shows which ones are not accessible. You transfer selected files with their source URL into the document hub, assign them to projects and have them remediated in fully automatic mode or only checked at first. With Continuous Accessibility, DokAudit checks the website daily, weekly or monthly; on request, auto-remediation transfers new problematic PDFs straight into the Hub. You replace the files on the website by hand or via the connection through the REST API and webhooks. The test reports serve as evidence – and as the basis for the accessibility statement.
Sources:
As of: 09/2026. This article gives a general overview and is not legal advice. The legal and standards texts in force are authoritative; in individual cases, the law of the German states (Länder) may differ.