A digital accessibility provider has warned that hiring teams using untagged PDFs for job adverts and contracts may be unwittingly breaking equality law.
As remote hiring becomes standard, many UK employers rely on digital documents – PDFs for job adverts, application forms, and contracts – to recruit and onboard staff. However, a significant portion of these documents are created in formats that are inaccessible to candidates and employees with visual or cognitive impairments.
The company say this oversight isn’t just a technical hiccup, but could constitute a failure to make “reasonable adjustments” under the Equality Act 2010, opening organisations to legal risk at a time when digital accessibility laws are tightening globally.
“Badly structured reports and PDFs are not simply a minor irritation, they actually slow down decisions, lead to errors, and increase frustration amongst the workforce,” Jeff Mills, CEO at GrackleDocs, explains. “In hybrid settings especially, clarity and accessibility are and should be considered productivity enablers, not just optional extras.”
In the context of recruitment, these document failures move beyond productivity to create significant legal and ethical risks.
Poorly formatted HR documents create two problems. They alienate potential candidates and create legal and financial risks for organisations. For candidates with disabilities, the experience is one of frustration and exclusion. What should be a simple process, reading a job description becomes an impossible task, forcing reliance on others or leading to abandoned applications. The UK Government Digital Service (GDS) explicitly advises against publishing crucial content in PDF format due to its frequent inaccessibility, stating that “PDFs are not designed to be as flexible or accessible as HTML.”
While accessibility is a major concern, PDFs are still widely used because they offer greater document integrity. PDFs ensure the layout and formatting remain fixed across all viewing devices, which is critical for legal and archival purposes, and they are significantly easier to create, manage, and share as a single, portable file than coding complex, multi-page HTML documents across teams.
To uncover the scale of the issue, GrackleDocs analysed 50 job descriptions in PDF format from jobs advertised online within the past year using accessibility software. The audit revealed that over 90% of PDF job descriptions failed basic accessibility tests, with an average score of just 49 out of 100. A closer look showed that 62% of documents scored 50 or below, representing significant barriers to access.
The most widespread problems were structural: every document was untagged, 42% used layout tables that disrupt screen reader navigation, and complex tables were the single most damaging element, appearing in nearly half of all documents reviewed. Sectors varied in performance, with charities averaging 58 out of 100, while private sector and local government documents averaged just 44 and 47 respectively.
Rob McKellar, Legal Services Director and General Counsel at Peninsula Group discusses how failing to provide job seekers with adequately formatted job descriptions could leave employers open to legal risk.
“There is no set list of what does and doesn’t constitute a ‘failure to make a reasonable adjustment ’ – this will always depend on the specifics of an individual’s disability and what is reasonable for the employer to implement,” he notes, “so a non-accessible job advert or other recruitment document could count. However, that being said, an individual would only be able to raise this specific claim if they requested and were denied the materials in an alternative format. But that doesn’t mean that employers shouldn’t aim to make their processes as accessible as possible. Not only to minimise the risk of other discrimination claims, but to also expand the field of potential applicants.”
McKellar concludes: “In practice, this means employers should carry out an assessment of what accessibility measures are reasonable to implement across their recruitment materials and then be prepared to make further adjustments on a case-by-case basis. For UK businesses that operate within the EU, they may also have additional obligations under the European Accessibility Act when it comes to their digital documentation.”
