Document Accessibility Compliance Crosswalk

WCAG 2.2 → ADA · EAA (EN 301 549) · Section 508 · PDF/UA · Brazil · Colombia · Mexico

Ten WCAG success criteria, mapped clause-by-clause to seven accessibility regimes, with the source text quoted verbatim in its original language. Where a regime has no defensible citation for a criterion, this page says so and explains why, rather than filling the cell.

Most published crosswalks stop at WCAG and the US/EU frameworks, and they map web pages. This one covers non-web documents — the PDFs, reports, and decks an organization publishes — and it includes Brazil, Colombia, and Mexico, which we could not find mapped anywhere, in any language, and curated by hand from primary sources.

Last reviewed: July 2026 · Scope: 10 WCAG 2.2 success criteria × 7 frameworks · Primary sources: eCFR, Federal Register, EUR-Lex, ETSI, W3C, PDF Association (Matterhorn), ISO 14289-1 sample, Planalto/gov.br, MinTIC/Función Pública, Cámara de Diputados MX, FDA/eCFR, acquisition.gov

How to read the citation confidence

Two different things are called "confidence" in accessibility tooling, and conflating them is how crosswalks lose credibility. This page uses only the first.

A justified empty is a finding, not a gap in the research. "ADA does not set a per-criterion technical standard for private documents" is a more useful answer than a plausible-looking clause number that would not survive an auditor's question.

The matrix — 10 criteria × 7 frameworks

Only EAA and PDF/UA vary meaningfully by criterion. Section 508 and Colombia adopt WCAG wholesale, so their citation is uniform. ADA is empty across all ten. Mexico is empty for the private/document case. Brazil cites the WCAG success-criterion number carried by NBR 17225.

Reading the empties. ADA — Title III incorporates no technical standard; the 2024 WCAG 2.1 AA rule is Title II (28 CFR §35.200) and binds public entities only. Mexico — no binding NOM or NMX adopts WCAG; the only hook is a 2015 federal-administration ACUERDO. Both are expanded below.

Two renames worth knowing. EN 301 549 Clause 10 renames two criteria for non-web documents: 2.4.2 becomes "Document titled" (§10.2.4.2) and 3.1.1 becomes "Language of document" (§10.3.1.1). If you are citing the EAA for a PDF and you write "Page Titled," you are citing the web clause. For HTML output, the equivalent family is §9.x, not §10.x.

The version question: WCAG 2.0, 2.1, and 2.2 in the same table

The frameworks incorporate different WCAG versions, which normally makes a cross-framework table unsound. Here it does not, and the reason is worth stating explicitly:

All ten criteria originate in WCAG 2.0, and their number, title, and level are identical in 2.0, 2.1, and 2.2, with the normative text preserved verbatim. The only differences across versions are editorial ("Web page" → "web page" in 1.4.2 and 3.1.1). So the citation crosses version boundaries without divergence.

"Content that conforms to WCAG 2.2 also conforms to WCAG 2.0 and WCAG 2.1."

The exception to watch. EN 301 549 V4.x, which moves to WCAG 2.2, was still a draft as of 2026. Do not cite "WCAG 2.2" as the version incorporated by the EAA until V4.x is published in the Official Journal. Until then, V3.2.1 / WCAG 2.1 is the version carrying the presumption of conformity.

Verbatim evidence — US and EU frameworks

ADA — uniform, justified empty across all ten criteria

Context, not a per-criterion citation. 28 CFR §35.200(b) — "…shall ensure that the web content and mobile apps … comply with Level A and Level AA success criteria and conformance requirements specified in WCAG 2.1…" This is Title II: public entities only, adopted wholesale rather than criterion by criterion, with compliance dates of 26 April 2027 and 26 April 2028 (89 FR 31320; extension at 91 FR 20902).

For a document checker whose users are private organizations, there is no per-criterion ADA basis to cite. That is the finding.

Section 508 — uniform, E205.4 across all ten criteria

The non-web exception, and why it does not bite. E205.4 verbatim:

"Non-Web documents shall not be required to conform to the following four WCAG 2.0 Success Criteria: 2.4.1 Bypass Blocks, 2.4.5 Multiple Ways, 3.2.3 Consistent Navigation, and 3.2.4 Consistent Identification."

None of the ten criteria in this crosswalk are in that exception set, so all ten apply to non-web documents under 508. E205 (electronic content) is the correct chapter; 602.3 applies only when the document is support documentation for an ICT product.

EAA — EN 301 549, clause by clause (Clause 10 = non-web documents)

Sources: ETSI EN 301 549 V3.2.1 (full) · Chapter 10 extract

Statutory anchor. Directive (EU) 2019/882, Article 4:

"Member States shall ensure … that economic operators only place on the market products and only provide services that comply with the accessibility requirements set out in Annex I."

The EAA has been in force since June 2025.

PDF/UA — ISO 14289-1, clause by clause

Sources: Matterhorn Protocol 1.1 · PDF Association — ISO 14289 (PDF/UA)

The empties here are structural, not an oversight. A static PDF has no audio to control, and PDF/UA explicitly places color and contrast outside its scope. A conformant PDF/UA file can still fail WCAG 1.4.3. Anyone treating "PDF/UA valid" as "WCAG AA conformant" is wrong by exactly these three criteria.

Verbatim evidence — Latin America

This is the part we could not find published anywhere, in any language. Each entry was curated by hand from primary sources, and the strength of each regime is stated plainly — including where it is weak.

Brazil — moderate, moving to strong

Recommended citation per criterion: ABNT NBR 17225:2025 (C.S. <n>, Nível A/AA) + LBI Art. 63. The structure is uniform — same standard, only the success-criterion number changes. No inventing a different instrument per criterion.

Why Brazil is stronger than it looks. LBI Art. 63 binds companies headquartered or commercially represented in Brazil — a broader reach than either ADA or Section 508, both of which are limited to public entities or federal procurement.

And where it is weaker than it looks. Until 2025, the only concrete technical standard (eMAG, WCAG 2.0) was mandatory for the federal government alone. NBR 17225:2025 finally supplies a current technical standard (WCAG 2.2) with per-criterion granularity — but as an ABNT standard it is voluntary by default. It becomes binding through contract or public procurement, or as the "melhores práticas … adotadas internacionalmente" that Art. 63 requires.

Colombia — strong

Recommended citation, uniform across all ten criteria: Resolución 1519/2020 (MinTIC), Anexo Técnico 1 (WCAG 2.1 AA) + backbone Ley 1618/2013, Art. 16.11.

Colombia is the cleanest of the three: a wholesale WCAG 2.1 AA adoption with a hard start date, resting on a statutory backbone. The citation does not change from criterion to criterion.

Mexico — weak, and this corrects a common assumption

Mexico is routinely grouped with Brazil and Colombia as a "strong" LatAm accessibility regime. For web and document accessibility in the private sector, it is not.

Recommended citation for the general/private/document case: justified empty. The only hook is the federal-administration case: the 2015 ACUERDO (WCAG 2.0 AA), with LGIPD Art. 32 as backdrop.

The honest read. Mexico has rights-level law (LGIPD) with no technical standard attached, plus an administrative ACUERDO limited to the federal public administration and tied to WCAG 2.0 AA. The verb in LGIPD Art. 32 is "promover" — promote — not require. For a document checker with private-sector users, the Mexico cell is left empty with a stated reason, and we would rather say that than manufacture a citation.

Rule-level mapping to PDF/UA

The crosswalk above works at the level of WCAG success criteria. Below is the finer grain: the individual checks in the ZiraDocs accessibility rulepack, each mapped to the ISO 14289-1 clause that backs it.

Two things this table makes visible. First, not every check maps to PDF/UA — three of them have no PDF/UA basis at all, and say so. Second, presence is not quality: several clauses require that alternative text exist, not that it be useful. A file with alt="image" on every figure passes PDF/UA §7.3 and helps no one.

On "advisory." Two of these checks report as suggestions, not failures, because WCAG does not support treating them as failures: WCAG imposes no maximum length on alternative text (1.1.1), and skipping a heading level is covered by technique G141, which is advisory. Reporting an advisory item as non-compliance inflates a finding count and costs you the auditor's trust the first time they check.

Sector applicability

Pharma, banking, and defense are frequently presented as accessibility "columns." They are not — none of the three is a per-criterion accessibility standard, and filling WCAG cells with their clauses would be inventing precision. What they actually do is determine which accessibility regime already in this crosswalk applies, and separately raise orthogonal obligations that are not accessibility at all.

Supporting text:

• 21 CFR §11.1(a): "The regulations in this part set forth the criteria under which the agency considers electronic records, electronic signatures … to be trustworthy, reliable, and generally equivalent to paper records…" — eCFR
• EAA Art. 2(2)(d): "consumer banking services;" — EUR-Lex
• DFARS 252.204-7012: "…shall be subject to the security requirements in NIST SP 800-171…" — acquisition.gov

Record integrity and cybersecurity are real obligations for these sectors. They are simply a different crosswalk.

Verification limits

Everything below is something we could not fully verify. It is published for the same reason the justified empties are: a crosswalk that only shows its strong cells is not a reference, it is a brochure.

• Brazil — NBR 17225:2025. The full normative text sits behind ABNT's paywall. We confirmed that it adopts WCAG 2.2 and cites each success criterion inline (format C.S. x.x.x, Nível …). We could not list the standard's internal item number per criterion. Cite the WCAG success criterion number, not the internal index.
• Mexico — 2015 ACUERDO. dof.gob.mx returned HTTP 403 from our environment; the verbatim text of its provisions was not retrieved. The WCAG 2.0 AA adoption comes from gob.mx's own declaration, not from the DOF text. We also could not confirm whether the ACUERDO remains in force or was superseded by later Estrategia Digital Nacional instruments (2018 / 2021). Treat its currency as unverified.
• EN 301 549 — Clause 9 verbatim. Obtained via an identical reproduction (Canada, IDT); the ETSI PDF truncated before the granular 9.x rows. The Clause 10 titles — including "Document titled" — were extracted verbatim from the Chapter 10 extract.
• §10.1.4.2 Audio control. Number and title confirmed. The "non-web document…" phrasing came back as a table restatement rather than verbatim source text; it should be re-verified against the complete ETSI PDF.
• PDF/UA — ISO suffixes (-1/-2/-3, 7.18.5). These come from the Matterhorn mapping. The clause titles (7.1, 7.2, 7.3, 7.4, 7.5, 7.6, 7.18) are verified verbatim against the ISO 14289-1:2014 sample; the suffixes are not — the full standard is paywalled.
• NTC 5854 (Colombia). Cited from a government consultation reproduction, not the paywalled ICONTEC original. Medium confidence.
• Annex I of the EU Directive. Section titles were not retrieved verbatim (EUR-Lex truncated). Art. 4 and Art. 2(2)(d) are verbatim.

If you can close any of these gaps — particularly the Mexico ACUERDO's current status or the NBR 17225 internal numbering — we would like to hear from you, and we will credit the correction.

Primary sources

United States and European Union

• eCFR 36 CFR Part 1194, Appendices A and C — ecfr.gov
• DOJ ADA Web Guidance (Mar 2022) — ada.gov
• 89 FR 31320 (Title II WCAG 2.1 AA rule) and 91 FR 20902 (extension); 28 CFR §35.200
• ETSI EN 301 549 V3.2.1 — full PDF · Chapter 10 extract · draft V4.1.0
• Directive (EU) 2019/882 (European Accessibility Act) — EUR-Lex
• Matterhorn Protocol 1.1 — PDF Association
• PDF Association, ISO 14289 (PDF/UA) — pdfa.org · ISO 14289-1:2014 sample
• W3C — WCAG 2.2, WCAG 2.0, PDF Techniques
• Section 508 laws and policies — section508.gov

Latin America

• Brazil — LBI, Lei 13.146/2015: Planalto
• Brazil — Decreto 5.296/2004: Planalto
• Brazil — eMAG: emag.governoeletronico.gov.br
• Brazil — ABNT NBR 17225:2025 (corroboration): CTA/IFRS
• Colombia — Resolución 1519/2020: Normograma MinTIC
• Colombia — Ley 1618/2013: Secretaría del Senado
• Colombia — NTC 5854:2011: ICONTEC
• Mexico — LGIPD: Cámara de Diputados
• Mexico — gob.mx accessibility declaration: gob.mx/accesibilidad
• Mexico — 2015 ACUERDO (DOF, not retrievable from our environment): dof.gob.mx

Sectors

• 21 CFR Part 11 — eCFR
• EAA, banking (Art. 2(2)(d)) — EUR-Lex
• DFARS 252.204-7012 — acquisition.gov

Corrections

This page is maintained, not published once. If a citation is wrong, a standard has moved, or a gap above can be closed, write to hello@ziradocs.com — corrections are applied with the review date updated, and contributors are credited.