We checked the PDFs on 45 German city websites against PDF/UA-1 and WCAG 2.2: 97 % of the documents had defects, with an average of 30 out of 100 points. Why this is not a failure of the web editors – and what TYPO3 cities can do now.
In September and October 2026 we checked the PDFs of 45 German cities: 2,722 documents, against PDF/UA-1 and WCAG 2.2. In every single city, PDFs were not accessible. 97 % of the documents had defects, scoring an average of 30 out of 100 points. This is no reproach to the web editors – it is a problem of volume, and one that can be automated.
How we checked
The basis is DokAudit Pre-Checks of the websites of 45 German cities. We checked 2,722 PDF documents, including statutes, forms and budget plans.
Test basis of the sample| Check | Tool / basis |
|---|
| Technical conformance | veraPDF, PDF/UA-1 profile |
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| Content checkpoints | Matterhorn Protocol |
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| Requirements for documents | WCAG 2.2 |
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| Overall rating | DokAudit score, 0 to 100 points |
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| Content management system of the website | automatic CMS detection (42 of 45 websites reachable) |
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The results
None of the 45 cities had consistently accessible PDFs. The problem is widespread and not an outlier of individual administrations.
Results of the sample| Indicator | Result |
|---|
| Cities with inaccessible PDFs | 45 of 45 |
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| Inaccessible PDFs | 2,640 of 2,722 (97 %) |
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| Average DokAudit score | 30 out of 100 points |
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| City websites on TYPO3 | 11 of 42 detected – roughly one in four |
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Only 82 of the 2,722 documents passed the check. An average of 30 points shows that the gaps are not cosmetic but fundamental.
It is not a question of will
In most administrations, awareness of accessibility is there. What is missing is time. A web editorial team often looks after hundreds of PDFs, and new ones keep arriving: from specialist departments, from the council information system, from external service providers.
Remediating every one of these documents by hand is not feasible at this volume. The numbers show the result: the website itself is often implemented well, but the PDFs behind it remain a barrier.
What this means legally
PDFs on the websites of public sector bodies are web content and must be accessible. The basis is Directive (EU) 2016/2102, implemented in Germany through the BGG (German Disability Equality Act) and the BITV 2.0 (Germany’s federal accessibility ordinance for IT) as well as the state laws (Länder) that apply to municipalities. The technical benchmark is EN 301 549; for PDFs, PDF/UA applies. The details are explained in BITV 2.0 for German municipalities.
One in four cities works with TYPO3
11 of the 42 city websites whose content management system we could detect run on TYPO3. For exactly these cities there is DokAudit for TYPO3. The extension checks every PDF directly in the TYPO3 file list and replaces it with the accessible version:
- checked and remediated against PDF/UA-1 and WCAG 2.2,
- at the same address, all links remain valid,
- the original is backed up.
The editorial team does not have to learn a new workflow. The documents stay where they are – just accessible.
Conclusion
Accessible PDFs in municipalities do not fail because of a lack of will, but because of volume. Where manual work is not enough, automation helps – and for TYPO3 cities it is now one extension away. Live demo and download: DokAudit for TYPO3.
Data basis: DokAudit Pre-Checks September/October 2026, 45 German cities, 2,722 PDFs; checked with veraPDF (PDF/UA-1) and Matterhorn checkpoints. CMS detection: 11 of 42 reachable city websites on TYPO3.
Sources:
As of: 10/2026. 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.
