To date, no DAX company has published an accessible PDF version of its annual report

Kirchhoff Consult, one of the leading communications and strategy consultancies for financial communications and sustainability, has examined the PDF documents of the 2024 annual reports and 2025 half-year reports of all DAX40 companies: Not a single PDF passed the PAC test[1] for the PDF/UA standard and received a test report.

This is due to various shortcomings, such as missing tags, alternative texts for images, metadata, or structural elements. Comparatively good PDFs with few deductions come from the DHL Group, Siemens Energy and SAP. All three companies have already taken many aspects of accessibility into account in their PDFs.

However, a comparison of the PDFs of the 2024 annual reports and 2025 half-year reports also showed that, overall, more accessibility criteriahad already been fulfilled by the half-year. For example, 10 of the 40 companies had set tags in the PDFs of their 2025 half-year reports.

An additional review and comparison of DAX and MDAX reports for 2024[2] also revealed that the annual report PDFs of DAX companies meet significantly more accessibility criteria than those of MDAX companies. 

‘Making the PDF of an annual report accessible is a challenge – but if you consider accessibility from the outset, you make it easier for yourself and create real added value,’ says Tanja Stoll, Senior Project Manager at Kirchhoff Consult. ‘Accessibility in annual reports is not a requirement – but it is already a sign of respect and social responsibility.’

Greater participation and improved usability 

With the Accessibility Enhancement Act (BFSG), which came into force at the end of June 2025, the issue of accessibility in reporting has come into sharper focus. The criteria for accessible PDFs primarily include technical aspects such as alternative texts, reading order, and tags. However, design aspects such as contrast, typography, and structure also play a decisive role. In addition to an overarching visual information architecture, it is important to prepare the PDF document technically in such a way that screen readers can process it.

"Accessibility does not mean sacrificing good design. On the contrary: it is the highest form of functional design. Typography, colour, and contrast are not secondary considerations, but have a decisive influence on accessibility. Those who anchor accessibility in their branding create a brand that is designed for everyone," explains Kerstin Walther-Fellinghauer, Executive Creative Director at Kirchhoff Consult.

[1] PAC is a PDF accessibility checker used worldwide.

[2] Based on Adobe data.