For each office document that has an accessible version, does this version provide the same information?
A PDF posted online with an accessible Word version next to it serves no purpose if the Word version is a reduced version, an earlier version, or just a summary. Criterion 13.4 sets a simple rule: the accessible version must contain exactly the same information as the original. Not less, not differently structured, not truncated.
In practice, if your source document contains a data table, graphics with numerical values, footnotes, or appendices, the accessible version must present all these elements. A 40-page PDF accompanied by a 3-paragraph HTML version does not meet the criterion. Equivalence concerns informational content, not page layout.
The test consists of opening both documents side by side and verifying that each piece of information present in the original is found in the accessible version. This is not an automatable test. It is a human review, point by point.
This criterion only applies when an accessible version already exists. If no alternative is offered, it is criterion 13.3 that applies, not 13.4.
Un test to ensure that an accessible version of the content is available
Informational equivalence between original document and accessible version
For each office document offered for download with an accessible alternative version:
- Identify each pair of files (original document + accessible version) on the page.
- Open both documents in parallel.
- Verify that each informative element of the original document is present in the accessible version: texts, numerical data, tables, graphics, notes, appendices, captions.
- If a single pair presents missing or different information in the accessible version, the test fails.
Examples
❌ Non-compliant : Incomplete accessible version — data table missing
<!-- Original document: rapport_financier_2025.pdf (32 pages with tables) -->
<!-- Accessible version: rapport_financier_2025_accessible.docx -->
<!-- Content of .docx: introduction + conclusions only, without the 8 data tables -->
<a href="rapport_financier_2025.pdf">Financial report 2025 (PDF, 2.4 MB)</a>
<a href="rapport_financier_2025_accessible.docx">Accessible version (DOCX)</a>The accessible version contains only the introduction and conclusions. The 8 financial data tables present in the PDF are absent from the DOCX. A screen reader user receives incomplete information — the precise data the document is intended to communicate is missing. Criterion 13.4 fails.
✅ Compliant : Complete accessible version — same content, adapted format
<!-- Original document: rapport_financier_2025.pdf (32 pages) -->
<!-- Accessible version: rapport_financier_2025_accessible.docx -->
<!-- The .docx contains: all texts, all tables with tagged headers,
text descriptions of graphics, footnotes, appendices -->
<a href="rapport_financier_2025.pdf">Financial report 2025 (PDF, 2.4 MB)</a>
<a href="rapport_financier_2025_accessible.docx">Accessible version (DOCX, 890 KB)
— same content, format compatible with screen readers</a>The DOCX version contains all information from the PDF: texts, tables with properly structured headers, graphics accompanied by their text descriptions and values, footnotes, appendices. The layout differs but no data is missing. Criterion 13.4 is satisfied.
Tips and pitfalls
⚠️ Confusing 'simplified version' with 'accessible version'
This is the most common audit error. Teams produce a document summary thinking they are doing the right thing. A summary, however well written, is not an accessible version — it is a different document. The accessible version must convey the same information, not an editorial selection of it.
⚠️ Accessible version not maintained after source document update
The PDF document is updated every quarter. The accessible DOCX version, meanwhile, dates back 18 months. Result: the criterion was compliant at creation, it is no longer. Integrate the update of accessible versions into the source document publication process — not as a separate task.
⚠️ Graphics and infographics in the source document
A pie chart in the original PDF carries precise numerical information. In the accessible version, this information must appear in text form — table or list of values. A simple 'see chart above' is not enough. Informational equivalence requires transcribing the data, not just mentioning the visual's existence.
💡 Criterion 13.4 and criterion 13.3 do not overlap
Criterion 13.3 asks whether an accessible version is offered. Criterion 13.4 asks whether that version is equivalent. If no accessible version exists, only 13.3 fails — 13.4 is out of scope (noted 'not applicable'). Avoid counting both criteria as failing for the same document without an alternative version.
⚠️ Page layout may differ — only content matters
The accessible version does not need to reproduce the visual formatting of the original document. A two-column presentation can become linear, colors can disappear, page numbering can change. What cannot change: the data, the headings, the values, the informative text. The criterion concerns informational equivalence, not graphic fidelity.
Frequently asked questions
How do you manually audit criterion 13.4 in the absence of an automated tool?
No, there is no tool. The method is manual: open both documents side by side and go through the source document section by section. For each informative block (paragraph, table, graphic, note), verify its presence in the accessible version. On a long document, focus on non-text elements — tables, graphics, captions — which are most often absent or incomplete in alternative versions.
What qualifies an HTML page as an equivalent accessible version of a PDF?
Yes. The format of the accessible version is not constrained — it can be a DOCX, ODT, HTML page, or structured TXT. What matters is that the alternative version is accessible (compliant with applicable criteria) and contains the same information as the source document.
How do you handle decorative images from the source document in the accessible RGAA version?
No. Purely decorative images do not carry information. Their absence in the accessible version is not a failure of criterion 13.4. However, an informative image — a graphic, diagram, or photo illustrating data — must be replaced by its text equivalent in the accessible version.
Which documents are covered by criterion 13.4: internal or public only?
RGAA applies to content published on the websites and applications of affected organizations. As soon as an office document is made available for download on a website subject to RGAA — whether it is a public report or an administrative form — criterion 13.4 applies if an accessible alternative version is offered.
How does an accessible executive summary differ from a complete version compliant with RGAA criterion 13.4?
No. An executive summary is a separate document that does not contain the same information as the full report. To meet criterion 13.4, the accessible version must be a complete version of the source document. If only the summary exists in accessible version, criterion 13.3 (presence of an accessible version) may also fail depending on interpretation.