ABSTRACT The excess radio background seen at ${\simeq}0.1\rm{-}10\, {\rm GHz}$ has stimulated much scientific debate in the past years. Recently, it was pointed out that the soft photon emission from accreting primordial black holes may be able to explain this signal. We show that the expected ultraviolet photon emission from these accreting black holes would ionize the universe completely at z > 6 and thus wash out the 21-cm absorption signature at z ≃ 20 as well as be in tension with existing cosmic microwave background anisotropy and average spectral distortion limits. We discuss possible augmentations of the model; however, it seems that an explanation of radio excess by accreting primordial black holes is not well-justified.