How to Make an Annual Report PDF Accessible: A WCAG 2.2 and PDF/UA Guide for Indian Listed Companies

An accessible annual report is one that a person using a screen reader can read from start to finish, in the right order, without missing a table or a chart. For a PDF, that means a tagged file built to the PDF/UA standard and checked against WCAG, the W3C's web accessibility guidelines. Most Indian annual reports aren't built that way. They look right on screen and in print, but underneath, the text is an untagged stream that jumps between columns, the charts are pictures with no description, and the financial tables are just lines of numbers.

Why it matters for an Indian listed company

The legal position in 2026

No SEBI, MCA or stock exchange rule prescribes an accessible format for the annual report. LODR, the Companies Act, 2013 and the exchange filing systems accept a PDF and say nothing about tags or screen readers.

The Rights of Persons with Disabilities Act, 2016 (the RPwD Act) defines a private establishment to include a company. Section 46 requires service providers, government or private, to provide services in line with the accessibility rules made under Section 40. Section 89 sets fines of up to ₹10,000 for a first contravention and ₹50,000 to ₹5 lakh after that, and Section 90 extends liability to the officers in charge of a company.

The rules themselves have moved several times:

IS 17802 (Part 1): 2021 is the Bureau of Indian Standards' adoption of the European standard EN 301 549. Its clause 10 on non-web documents applies the WCAG 2.1 success criteria to documents, and names PDFs among its examples. So an annual report PDF on a company's website already falls within the standard that Rule 15 points to.

The 2026 draft goes further. As published for comment on 20 July 2026, it would require establishments with a turnover of ₹500 crore or more to comply within one year of final publication, and smaller ones within 18 months. It would also require an Accessibility Conformance Report, a published statement of how far each product or document conforms, signed at director level. It's still a draft, and the final text may change.

SEBI has already acted on its own patch. Its circular of 31 July 2025 requires regulated entities to make their digital platforms accessible, and says investor documents in PDF must follow accessible standards such as tagged PDF. It covers intermediaries and market infrastructure institutions (the exchanges, depositories and clearing corporations), not listed companies. But the exchanges that host company filings are inside it, and it shows where the regulator's thinking is.

In practice: treat WCAG 2.1 AA as the floor, because that's what IS 17802 and GIGW 3.0 use, and build to WCAG 2.2 AA and PDF/UA so the report won't need rework when the rules settle.

Readers who can't use the PDF today

Census 2011 counted 2.68 crore persons with disabilities in India, about 2.21% of the population, across only eight disability types. The 2016 Act recognises 21. Among them are shareholders, employees, analysts and journalists who read with a screen reader, magnification or text-to-speech.

PDFs are a known problem for them. In WebAIM's screen reader user survey, 75.1% of respondents said PDF documents were very likely or somewhat likely to cause them significant accessibility problems. An annual report that can't be read this way also shuts out older shareholders who rely on reflow or zoom on a phone.

Machines read your report the same way

A screen reader and a search engine have the same problem with an untagged PDF. Both have to guess at the reading order of a three-column page, and both lose the link between a figure and its label in a table. Tagging gives the text a logical order and a structure: this is a heading, this is a table, this row is the header. The PDF Association's Well-Tagged PDF specification has a separate conformance level for reuse for that reason, alongside the one for accessibility. A well-tagged report is easier for AI assistants, data providers and search engines to extract and quote correctly, which is the same argument we made for the digital annual report.

The standards, briefly

The PDF Association describes PDF/UA as a way of making PDFs that conform to WCAG, and notes that PDF/UA doesn't cover colour or contrast. So a file can pass a PDF/UA check and still fail WCAG on contrast. You need both.

W3C also publishes a set of PDF techniques for WCAG, numbered PDF1 to PDF23, which explain how each success criterion is met in a PDF: alt text, artifacts, table tags, the document title and language.

Plan it into the InDesign workflow

Accessibility is cheapest when the layout file is built for it from the first spread. Almost everything a remediator fixes in Acrobat traces back to a decision made, or not made, in InDesign. Put it in the brief, and in the agency's scope, before design starts.

Styles mapped to tags

Section heading

H1

Subheading

H2

Body copy

P

Meaningful chart

Figure + text alternative

Data table

Table → TR → TH / TD

Map paragraph styles to semantic tags. A large font alone does not make a heading.

Illustrative examples · The Footnotes · Explanatory text remains selectable and readable by assistive technology.

Every piece of text should carry a paragraph style, and every style should map to a PDF tag. In InDesign, the Export Tagging section of Paragraph Style Options sets the tag (H1 to H6, P and so on). Edit All Export Tags, in the Paragraph Styles panel menu, shows every mapping in one list, which is the quickest way to audit a template.

The usual mistakes are local overrides on headings, section titles set as ordinary paragraphs in a large size, and running heads and folios that end up tagged as body text. Headings should follow a logical hierarchy: one H1 per section, H2 for its parts, and no skipped levels.

Reading order through the Articles panel

1. Set the sequenceHeading → first column → second column → related sidebar.
2. Use ArticlesArrange frames and enable “Use for Tagging Order in Tagged PDF”.
3. Listen after exportCheck that the tag order preserves sentences and places the sidebar where it makes sense.

The illustration is a metaphor; the correct order depends on the meaning of the page.

Illustrative examples · The Footnotes · Explanatory text remains selectable and readable by assistive technology.

A screen reader reads in tag order, not in the order the eye travels. On a page with a pull quote, a sidebar and two columns, those can be very different. InDesign's Articles panel (Window > Articles) lets you drag frames into the order they should be read. Turn on "Use for Tagging Order in Tagged PDF" in the panel menu so the export follows it.

Thread body text into connected frames wherever you can. A story threaded across a whole section exports in order without extra work. Twenty unthreaded text frames on a spread need twenty decisions.

Alt text for charts, photos and icons

Illustrative alt text

“Revenue rose from ₹100 crore in FY25 to ₹120 crore in FY26, an increase of 20%.”

For a complex chart, add a nearby data table or long description. Verify the message and every number.

Example wording only; the sculptural chart does not encode these figures.

Illustrative examples · The Footnotes · Explanatory text remains selectable and readable by assistive technology.

Every meaningful image needs a text alternative (WCAG success criterion 1.1.1). In InDesign, Object > Object Export Options has an Alt Text tab, and the Tagged PDF tab lets you mark a purely decorative image as an artifact so the screen reader skips it.

Good alt text gives the point of the chart. "Bar chart" tells the reader nothing. A sentence with the start and end values and the period tells them what the designer wanted them to see. For a complex chart, put a short alt text on the image and give the full figures in a table nearby or in an appendix. Leadership photos need a name and role. Background textures, rules and section motifs should be artifacts.

Recent InDesign releases can generate alt text with AI. It's a starting point for photos. It won't know what a chart is supposed to show, so a person who knows the numbers has to write those.

Real tables, never pictures of tables

A table pasted in as an image, or built from tab-separated text, has no rows or columns for a screen reader to move through. Build every table as an InDesign table, and set its header rows with Table > Table Options > Headers and Footers or Table > Convert Rows > To Header. InDesign's July 2026 release added the option to include row headers, column headers and captions when exporting, which helps PDF table structure considerably.

Avoid merged cells where a simpler layout will do, and avoid splitting one logical table across separate text frames.

Title, language and metadata

Set the document title in File > File Info. It's what a screen reader announces and what browsers show in the tab (WCAG 2.4.2). Set the language too (WCAG 3.1.1). For an English report, set English in the paragraph styles and in the export dialog, and set Hindi or other languages on the specific passages that use them, through the Character panel.

Contrast, colour and fonts

WCAG 1.4.3 requires a contrast ratio of at least 4.5:1 for body text, and 3:1 for large text, which WCAG defines as at least 18 point, or 14 point bold. Chart lines, icons and the edges of input fields need 3:1 against what's next to them (1.4.11). Light grey captions on white, white text on brand-colour photos, and pale pastel chart series are the common failures. Colour also can't be the only way information is shown (1.4.1), so a red-amber-green ESG dashboard needs labels or symbols as well.

Use fonts that allow embedding, and don't convert live text to outlines. Text that has become a vector shape can't be read, searched or copied.

No text in images

WCAG 1.4.5 says that if text can be set as text, it should be. Cover lines, KPI numbers on an image, infographic labels and the CEO's signature quote are all routinely flattened into a placed image. Set them as live text over the image instead.

Links and bookmarks

Generate bookmarks from the table of contents, and make every contents entry, cross-reference ("see note 34") and web address a working link. Write link text that makes sense on its own (WCAG 2.4.4), so "read the BRSR on our website" rather than a bare "click here".

A report that's built accessible costs a checking pass. A report that's made accessible afterwards costs a second production.

Export the tagged PDF from InDesign

In the export dialog, the settings that matter are:

• Create Tagged PDF: on. Without it, there's nothing to fix.
• Bookmarks and Hyperlinks: on.
• Display Title: set to Document Title (in the Advanced tab of the Interactive PDF export), so the reader sees the report's name rather than a file name.
• Language: set to the main language of the report.
• Use Structure for Tab Order: on, for the interactive export, where Adobe notes it's available only for tagged PDFs.

Export the accessible version from the final, approved InDesign file. Every correction made after remediation has to be made twice, or the PDF has to be remediated again.

Fix what's left in Acrobat

Even a well-built file usually needs some work in Acrobat Pro. Adobe's own accessibility guidance puts the tools under All tools > Prepare for accessibility.

Reading order and the tag tree

Open the Accessibility tags panel and step through the tree against the pages. Look for headings tagged as paragraphs, columns read in the wrong order, footnotes landing in the middle of the text and pull quotes read twice. The Reading Order tool can retag regions and mark them as background. Adobe says the tool is intended for PDFs tagged in Acrobat and advises going back to the source file where you can. For an InDesign export, editing the tag tree directly is usually safer.

Resist running Automatically tag PDF on an InDesign export that's already tagged. It throws away the structure you built and replaces it with a guess.

Table headers

Check every table in the tag tree. Header cells should be TH, data cells TD, and complex tables need the relationship between headers and cells set explicitly. Acrobat's Table Editor, in the Reading Order tool, lets you inspect and fix cell properties.

Artifacts

Keep in the structure

Headings, paragraphs, meaningful figures, tables and necessary references.

Mark as artifacts

Purely decorative backgrounds, rules and repeated running furniture that adds no necessary information.

“Artifact” is a PDF structure setting. Do not mark meaningful information as decoration.

Illustrative examples · The Footnotes · Explanatory text remains selectable and readable by assistive technology.

Folios, running heads, crop marks, background shapes, decorative rules and repeated section graphics should be artifacts, outside the tag tree. A screen reader that announces "page 147, Annual Report 2025-26" at every page break is technically reading everything and practically unusable.

The Accessibility Checker

Run Check for accessibility. It reports each rule as passed, failed, skipped or needing a manual check. Adobe says the checker tests against PDF/UA and WCAG 2.0, not WCAG 2.2, and it can't judge whether the reading order is logical, so that rule always needs a person. It also fails any document of 21 pages or more that has no bookmarks.

Test it properly

1. Validate structureUse PAC and veraPDF for the applicable PDF/UA profile. Review failures and manual checks.
2. Navigate and listenUse NVDA or VoiceOver. Test headings, reading order, charts, a financial table and footnotes.
3. Review meaningCan a reader find the right figure? Is the alt text accurate? Does the sequence make sense?

Keep validation reports and a short manual test log. Automated results alone do not establish full accessibility.

Illustrative examples · The Footnotes · Explanatory text remains selectable and readable by assistive technology.

Use at least two automated checkers and one human.

PAC's technical tests are still based on WCAG 2.1 and its PDF/UA-2 support is limited, so it's strongest on PDF/UA-1 files, which is what most InDesign exports are. veraPDF says plainly that it performs only machine-verifiable checks. Neither tool can tell whether alt text is accurate or a reading order makes sense.

That's the job of the manual pass. Open the PDF in Adobe Reader with NVDA running, or with VoiceOver on a Mac, and listen to the sections that matter most: the chairman's letter, one KPI spread, the balance sheet, a note with footnotes, a BRSR table and the contents page. Navigate by heading, then by table. If you can't find the profit for the year by moving through the statement of profit and loss cell by cell, neither can a shareholder.

In practice: ask your agency to deliver the PAC report and a short screen-reader test log with the final PDF, the same way you'd ask for a printer's proof.

The hard parts of an annual report

Financial statements

Multi-column statements, with current year, previous year and note references, are the largest set of tables in the report. Each needs a header row with the year labels, a header column with the line items, and correct handling of subtotals and indented sub-items. Statements that continue across pages should repeat the header row and stay as one table in the tags where possible. A negative number shown only through colour, with no bracket or minus sign, is lost to a screen reader.

Notes with footnotes

The notes to accounts mix narrative, tables, policy text and footnotes. Footnote markers need to link to the footnote, and the footnote text needs to sit in the tag tree where it won't interrupt the sentence. PDF/UA has specific requirements for notes and references, and this is where automated tagging most often fails.

Infographics and KPI dashboards

The value-creation model, the business-model diagram and the KPI spread are often the most designed pages and the least accessible. Group each infographic as one figure with alt text that gives its message, and make sure every number on a KPI spread exists as live, tagged text in a logical order, so it isn't lost inside a graphic. If the dashboard uses colour coding for performance against target, add a text label.

BRSR tables

The Business Responsibility and Sustainability Report is close to a long form: principle-wise questions, then tables of energy, emissions, water, waste, employees and complaints, many with current and previous year side by side. Build them as real tables with headers, keep the question numbering as text, and don't set the format as a scanned image of a filled form. The BRSR is also filed separately in XBRL, which is the machine-readable version.

Long statutory sections

The board's report, corporate governance report, MD&A and annexures run to many pages of plain text and simple tables. They're the easiest to make accessible if they've been set with styles, and the most tedious if each page was formatted by hand. Bookmark every annexure, so a reader looking for the secretarial audit report doesn't have to page through 60 pages to find it. Our annual report contents checklist lists the sections that need to be there.

What "digital-ready" means beyond the PDF

An accessible PDF is the baseline. A report that's ready for digital use also needs:

• An HTML edition or microsite. Web pages reflow on a phone and are easier to make conform to WCAG than a PDF of any length. Our guide to the digital annual report covers what one costs.
• Bookmarks and deep links. Bookmarks for every section and annexure, and web addresses that take a reader straight to a page or section, so an analyst can share "the segment review" rather than "page 147".
• Searchable text. No scanned pages. The old Rule 15 already asked for OCR-based PDFs on websites. A scanned signature page or certificate should have its text available too.
• Metadata. Title, author (the company), subject, keywords and language set in the file, so the report is identified correctly by search engines and by the reader's software.
• A sensible file size. A 60 MB report fails on a mobile connection. Downsample images for the web version and consider offering the report by section as well as in full.
• Mobile reading. Single pages rather than spreads for the screen version, and type large enough to read without zooming.
• Machine-readable financials. Listed companies file their financial statements with the MCA in XBRL (eXtensible Business Reporting Language) under the 2015 XBRL Rules, submit results to the exchanges in XBRL, and have filed the BRSR in XBRL since July 2022. Link to those filings, or publish the key tables as downloadable spreadsheets, from the investor page.

Checklist for the annual report team

In the brief

• Target set: WCAG 2.2 AA and PDF/UA-1, written into the agency scope and timeline
• Accessible PDF and test reports listed as deliverables
• Owner named for alt text on charts (someone who knows the numbers)

In InDesign

• Every paragraph and character style mapped to a tag; heading levels in order
• Body text threaded; reading order set in the Articles panel
• Alt text on every meaningful image; decorative items marked as artifacts
• All tables built as tables, with header rows and columns
• Document title in File Info; language set in styles and for other-language passages
• Contrast at 4.5:1 for body text, 3:1 for large text and graphics; nothing shown by colour alone
• No live text converted to outlines or flattened into images
• Contents, cross-references and URLs linked; bookmarks generated

At export and in Acrobat

• Tagged PDF, bookmarks, hyperlinks, document title displayed, language set
• Tag tree checked against the pages; folios, running heads and decoration as artifacts
• Table headers checked; footnotes placed correctly in the tags
• Acrobat accessibility check run and manual items reviewed

Testing

• PAC 2026 and veraPDF pass with no PDF/UA failures
• Screen-reader pass with NVDA or VoiceOver on the key sections
• Final accessible PDF is the one uploaded to the website and the exchanges

Digital

• HTML edition or section pages, deep links and metadata
• Web-optimised file size; XBRL filings linked from the investor page

Effort and cost: a realistic view

The cost of an accessible annual report depends much more on when the work starts than on page count. If the InDesign templates are built with clean styles, threaded stories and real tables, and the team writes alt text while the charts are being designed, accessibility adds a checking and fixing pass at the end. The main extra cost is the time of whoever writes the alt text and runs the tests.

If accessibility is requested after the PDF is approved, someone has to rebuild the structure page by page in Acrobat. The financial statements and notes take the longest, because every table has to be checked cell by cell. Remediation vendors usually price that work per page, with complex table pages charged at a higher rate than text pages. And because remediation is done on the exported PDF, any late correction to the report means doing it again.

So when you brief an agency, ask for accessibility as part of the build. Ask what the quote assumes about tables and charts, whether alt text writing is included, and which test reports come with the final file. Our breakdown of what an annual report costs in India and the reporting calendar show where it fits in the budget and timeline.

What this means for IR teams, company secretaries and agencies

IR teams should set the target in the brief and make the accessible PDF the only version that's published. A separate "accessible version" uploaded weeks later tends to fall out of date the first time a page is corrected.

Company secretaries should watch the final text of the 2026 RPwD amendment. If it's notified close to the draft, a company with turnover of ₹500 crore or more will have a year to comply, and will need a conformance report signed at director level. The annual report, the website and the investor documents on it are obvious candidates for that report.

CFOs and finance teams own the hardest part. Financial statements prepared in Excel and placed into InDesign as images, or retyped as tab-separated text, can't be tagged properly. Agree a table format with the agency early, and write the alt text for financial charts yourselves.

Agencies need accessible templates, a style-to-tag map that survives the whole production, and the free test tools on at least one Windows machine. Building PDF/UA into the default workflow costs far less over a reporting season than remediating every client's file after approval.

Start with this year's template. Map the styles, set up the tables and turn on tagged export before the first draft comes in. Then run last year's report through PAC 2026 for twenty minutes and you'll see exactly where the work is.