Conference 27–28 May 2019 📍 Berlin, Germany

PDF Days Europe 2019 — The Last Pre-COVID PDF Association Conference

PDF Days Europe 2019 took place in Berlin on 27–28 May 2019 — the final in-person edition before the pandemic. Sessions centred on the imminent release of PDF 2.0 tooling, the early development of PDF/UA-2, advances in digital signature infrastructure, and the growing adoption of PDF/A-3 for structured e-invoicing across Europe.

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Key takeaways

  • PDF Days Europe 2019 was the largest edition to that point, reflecting the growing intersection of PDF with accessibility mandates, digital government, and e-signature adoption.
  • PDF 2.0's first production implementations revealed practical questions around page-level metadata inheritance, encryption migration, and page-level file attachments.
  • The EU Web Accessibility Directive's September 2019 deadline created urgent, compliance-driven PDF/UA demand — Matterhorn Protocol validators were the enabling technology.
  • Remote signing services (TSP-hosted keys, mobile app authentication) were displacing hardware tokens for qualified signatures.
  • eIDAS cross-border signature validation remained inconsistent in practice due to incomplete Trusted List implementation in viewer tools.
PDF Days Europe 2019 was held in Berlin on 6 and 7 May 2019, organised by the PDF Association. The 2019 conference arrived at a moment of transition: PDF 2.0 (ISO 32000-2:2017) had been published two years prior, and the first production tool implementations were appearing. The EU Web Accessibility Directive had been in force since October 2016 with public body website compliance deadlines — September 2019 for new content — creating urgency around PDF/UA for government digital services. eIDAS qualified signatures had been available across EU member states since 2016, and enterprise adoption patterns were beginning to emerge. The 2019 event was notable for being the largest PDF Days Europe to that point in attendance, reflecting the growing breadth of communities that the PDF standards touched: accessibility specialists, digital government teams, legal technology practitioners, and the traditional PDF developer and prepress communities.

PDF 2.0 in practice: first implementations

PDF 2.0 (ISO 32000-2:2017) had been published in July 2017. By May 2019, the first production libraries with PDF 2.0 support were shipping: iText 7's PDF 2.0 features were available, PDFlib had PDF 2.0 output, and Adobe Acrobat had selective PDF 2.0 support. PDF Days Europe 2019 was the first conference where sessions could draw on real implementation experience rather than specification analysis. AES-256 encryption improvements — PDF 2.0 corrected a known vulnerability in PDF 1.7's AES-256 key derivation. Implementors reported that the correction was technically straightforward but required careful handling of the /EncryptMetadata and encryption dictionary versioning to avoid creating PDFs that older viewers would misidentify as PDF 1.7 encrypted files (which would use the weaker key derivation). Page-level metadata — PDF 2.0 introduced page-level XMP metadata streams. The use case — different pages of a document having different copyright, authorship, or licensing information — was well-understood from publishing workflows, but implementors were discovering that the inheritance rules between document-level and page-level metadata needed careful handling. If a page has its own metadata stream, does it fully replace the document-level metadata, or only override the properties it explicitly specifies? Associating file attachments with pages — PDF 2.0 formalised the page-level /AF (Associated Files) mechanism, which allows arbitrary files to be attached to a specific page rather than the document as a whole. This was particularly relevant for PDF/A-3 workflows embedding structured data: with page-level AF, an invoice PDF could embed its ZUGFeRD/Factur-X XML attachment at the document level while embedding image references at their respective pages. New structure elements — The additional tagged PDF structure elements in PDF 2.0 (/Aside, /FENote, /Sub, /Em, /Strong) were discussed. Tool support was minimal — authoring tools were not yet producing them, and validators were not yet checking for them. They were a future capability rather than a current practitioner concern.

PDF/UA and the EU Web Accessibility Directive deadline

The EU Web Accessibility Directive (2016/2102) required member state public sector bodies to make their websites and mobile applications accessible by September 2019 (for new content) and September 2020 (for existing content). PDFs published on public body websites were in scope. This created an urgent, compliance-driven demand for PDF/UA guidance and tooling that had not existed as strongly in previous years. Matterhorn Protocol adoption — The PDF Association's Matterhorn Protocol (a machine-testable interpretation of PDF/UA requirements) had been published in 2013. By 2019, validator tools (PAC 3, veraPDF) had implemented Matterhorn Protocol checkpoint testing, making automated PDF/UA validation practical for the first time. Government agencies were deploying these validators in document management system workflows to catch non-compliant PDFs before publication. Common failures in government PDFs — Analysis of UK Government, European Commission, and German federal agency PDFs revealed consistent failure patterns: missing document language declaration, missing document title in XMP metadata, untagged figures (images without alt text), incorrectly tagged tables (missing header scope attributes), and reading order that did not match visual order for multi-column layouts. PDF/UA for procurement — A key development discussed at PDF Days 2019 was the inclusion of PDF/UA requirements in public procurement contracts for document management software. Several EU member states had begun specifying PDF/UA in their tender requirements for content management systems, word processors, and PDF generation tools. This was a significant market signal: PDF/UA support was becoming a procurement filter rather than an optional feature.

eIDAS adoption patterns and remote signing

Three years after eIDAS came into force, the 2019 conference could draw on real enterprise adoption data. The patterns that had emerged by 2019: Qualified signatures in the public sector — EU public administrations were the primary early adopters of qualified signatures. Tax authority filings, land registry submissions, and notarial documents were among the first use cases to require qualified signatures under national implementations of eIDAS. Remote signing services — The hardware token model (USB tokens, smart cards) was being displaced by remote signing services where the private key is stored in an HSM at a trust service provider. Users authenticate via a mobile app (typically SMS OTP or biometric) to authorise the signing operation without handling a hardware token. ETSI's standardisation of the remote signing protocol (TS 119 432) had enabled multiple TSPs to offer interoperable remote signing services. Seal signatures for organisations — eIDAS also defined electronic seals for legal entities (as opposed to natural persons). Organisation-level PDF seals were being adopted for automated, high-volume document workflows: generating and sealing client statements, invoices, and confirmations without individual human signature actions. Cross-border signature validation challenges — Despite eIDAS's goal of cross-border recognition, practical interoperability challenges persisted. The EU Trusted Lists of qualified trust service providers were the mechanism for cross-border validation — a qualified signature created with a certificate from a qualified TSP in one member state should be verifiable in another. Validator tools and PDF viewers were inconsistently implementing the Trusted List lookup, leading to "signature unknown" results when validating cross-border qualified signatures in some environments.

Frequently asked questions

What are the new structure elements in PDF 2.0 and what are they for?

PDF 2.0 (ISO 32000-2) added several new structure element types for tagged PDF that were not in PDF 1.7: /Aside — for content tangentially related to the main content (sidebars, pull quotes, call-out boxes). /FENote — for footnotes and endnotes. /Sub — for subscript text. /Em — for text with emphatic stress (analogous to HTML ). /Strong — for text with strong importance (analogous to HTML ). /Annot — for annotation content associated with an annotation object. /Form — for PDF form annotations. /Ruby, /RB, /RT, /RP, /RC, /RBC — for East Asian ruby annotations (phonetic guides over CJK characters). These elements provide richer semantic structure for accessible PDFs, enabling assistive technologies to convey document meaning more accurately. Widespread authoring tool support was still limited as of 2019–2020.

What is the EU Web Accessibility Directive and how does it apply to PDFs?

The EU Web Accessibility Directive (Directive 2016/2102) requires public sector bodies in EU member states to make their websites and mobile applications accessible to people with disabilities. PDFs published on public websites are covered when they are used to distribute public services or information. The deadline for new web content was 23 September 2019; for existing content, 23 September 2020; for mobile applications, 23 June 2021. The directive references EN 301 549 as the harmonised standard, which incorporates WCAG 2.1 for web content and PDF/UA-1 (ISO 14289-1) for PDFs. Non-conforming PDFs on public body websites can be reported to national enforcement bodies, which have powers to require correction. UK public bodies were subject to equivalent requirements under the Public Sector Bodies Accessibility Regulations 2018 until Brexit alignment ended.

What is an electronic seal under eIDAS and how is it different from an electronic signature?

Under the eIDAS Regulation, an electronic seal is the equivalent of an electronic signature for legal entities (companies, organisations) rather than natural persons (individuals). A seal is associated with a legal entity certificate rather than a personal certificate. Seals can be applied without individual human authorisation — they are typically used in automated workflows: generating and sealing batches of client statements, invoices, or official documents without requiring a person to explicitly authorise each signing operation. eIDAS defines three seal levels paralleling signature levels: electronic seal, advanced electronic seal, and qualified electronic seal. Qualified electronic seals have equivalent legal effect to authenticated documents (official stamps) across EU member states. In PDF terms, seals are implemented identically to signatures at the cryptographic level — the difference is in the certificate type and the legal framework that governs them.

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The PDF tools and standards discussed at this event are available free — no account needed.