Short answer: To remediate PDFs for ADA Title II, first sort them into the ones the web rule covers and the ones it exempts. Then fix each covered PDF so it meets WCAG 2.1 Level AA: real text, tags, headings, reading order, alt text, table and form markup, a title and a language.
Large state and local governments must meet the rule by April 26, 2027, and smaller ones and special districts by April 26, 2028.
Sources: 28 CFR 35.200; Federal Register, 91 FR 20902.
Which PDFs does the Title II web rule cover?
The rule calls PDFs "conventional electronic documents," together with word processor, presentation and spreadsheet files. They count as web content, so the WCAG 2.1 AA standard applies to them.
2 exceptions matter most for PDF libraries:
- Preexisting documents. PDFs posted before the entity's compliance date are exempt, unless people use them to apply for, gain access to, or take part in a service, program or activity.
- Archived web content. Content made before the compliance date, kept only for reference, research or recordkeeping, never changed after archiving, and stored in an area clearly marked as archived.
A third exception covers individualized PDFs about 1 person, their property or their account, when they are password-protected or otherwise secured. A utility bill behind a login is the typical case.
Sources: 28 CFR 35.104 and 35.201; ADA.gov fact sheet.
How do you triage a PDF library?
Sort the library before anyone opens Acrobat. Triage decides what gets fixed first and what can wait.
| PDF type | Covered by the rule? | Action |
|---|---|---|
| New PDF posted after the compliance date | Yes | Make it conform before it goes live |
| Preexisting application form, permit form or fee schedule people use to get a service | Yes, the preexisting exception does not apply | Fix first, or replace with an accessible web form |
| Preexisting report nobody needs to use a service | Exempt if posted before the compliance date | Fix on request; fix if it is updated |
| Old minutes or reports kept for reference | Exempt only if they meet all 4 parts of the archived content definition | Move to a clearly labeled archive area and stop editing them |
| Individual bill or record behind a login | Exempt as an individualized, secured document | Provide an accessible version on request |
| Current agenda, budget or notice | Yes | Fix now, or publish the content as HTML |
Even an exempt PDF may need an accessible version for a person who asks. The web rule sits on top of Title II's general duties.
Sources: 28 CFR 35.104 and 35.201; ADA.gov fact sheet.
Should you fix the PDF or replace it with HTML?
Ask whether the content needs to be a PDF at all. Section508.gov notes that federal policy requires agencies to prioritize HTML and use PDFs only when necessary.
That policy binds federal agencies, but the logic carries over. A meeting notice or a fee table is easier to keep accessible as a web page than as a file.
Keep the PDF when the layout has legal or practical weight, such as a signed ordinance or a form a person prints and mails.
When you keep it, fix the source file where you can. If the PDF came from a word processor, set real headings, list styles, table header rows and alt text there, then export with tags turned on. Repairing the source once is faster than repairing every new export by hand.
Source: Section508.gov, Create Accessible PDFs.
Step by step: remediating 1 PDF
This order fixes structure before detail, so later steps do not undo earlier ones. The W3C technique numbers point to the matching WCAG 2.1 PDF technique.
- Check for real text. If the PDF is a scan, run OCR so the words are text, then proofread the output (PDF7).
- Tag the document. WebAIM notes that an untagged PDF would not be considered accessible. Add tags if none exist.
- Set the title and language. Give the file a document title and a default language (PDF18, PDF16). Mark passages in another language (PDF19).
- Fix headings and lists. Tag headings by level and lists as lists, so screen reader users can scan the file (PDF9, PDF21).
- Fix the reading and tab order. Make sure the tag order matches the visual order, column by column (PDF3).
- Add alt text, or mark images as artifacts. Describe images that carry meaning; hide decorative ones (PDF1, PDF4).
- Mark up tables. Use table, row, header and data cell tags, and repair mistagged tables (PDF6, PDF20).
- Fix links. Make link text clear and tag links correctly (PDF11, PDF13).
- Fix forms. Give every field a label, a name, role and value, required status and error help (PDF10, PDF12, PDF5, PDF22).
- Add bookmarks to long files so people can jump between sections (PDF2).
- Test. Run an automated checker, then test by hand with a screen reader and keyboard. Section508.gov links free checklists and training for this.
Sources: W3C, All WCAG 2.1 Techniques (PDF techniques); WebAIM, PDF Accessibility; Section508.gov.
Failures to check first
These are the problems that stop a screen reader user cold. Each maps to a W3C technique, so a tester can cite the fix.
| Failure | What the user hits | Fix (W3C technique) |
|---|---|---|
| Scanned image with no text | A screen reader reads nothing | OCR, then proofread (PDF7) |
| No tags | No headings, lists or tables to move through | Tag the document, then check each tag |
| Wrong reading order | Columns read across, sentences jumbled | Reorder tags (PDF3) |
| Missing alt text | Charts and maps are skipped or read as "image" | Alt entry for meaningful images (PDF1) |
| Untagged table | Cells read as a stream of numbers | Table markup with headers (PDF6) |
| Unlabeled form fields | Fields announced as "edit text" with no name | Labels and name, role, value (PDF10, PDF12) |
| No document title | The file is announced by its file name | Title entry (PDF18) |
Source: W3C, All WCAG 2.1 Techniques.
What to hand off first
If you are a prime with a remediation backlog, hand off the PDFs people use to get a service: forms, permits, applications and current notices. They have no preexisting exemption and the highest impact.
Give the remediation team a clean inventory to start from. Useful columns:
- URL and file name
- Owning department and a contact
- Page count, and whether the file is a scan
- Whether it is a form or is used to get a service
- Date first posted and date last changed
- The exception you think applies, if any, for a reviewer to confirm
Next, hand off any recurring document a department posts every week or month. Fix the source template once, so each new file starts accessible.
Our accessibility remediation and software work covers this kind of document work under a prime, and our delivery model explains what we handle offshore. New to the market? Read what SLED means, or see the Konnex capability statement.
Source for the exceptions: 28 CFR 35.201.
Quick answers
Do old PDFs on a city website need to be fixed?
Not always. PDFs posted before the compliance date are exempt unless people use them to apply for or take part in a service, under 28 CFR 35.201(b).
Is a tagged PDF automatically accessible?
No. Tags are the base layer. Headings, reading order, alt text, tables and forms still need checking against WCAG 2.1 AA.
Can an automated checker confirm a PDF conforms?
No. Checkers find missing tags and titles, but a person still has to judge alt text and reading order. Section508.gov pairs its checklists with manual testing.
Sources: 28 CFR 35.201; Section508.gov.
Sources
- 28 CFR Part 35: Nondiscrimination on the Basis of Disability in State and Local Government Services, eCFR (sections 35.104, 35.200, 35.201)
- Extension of Compliance Dates for Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities, Federal Register, April 20, 2026
- Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments, ADA.gov
- All WCAG 2.1 Techniques, W3C Web Accessibility Initiative
- Create Accessible PDFs, Section508.gov
- PDF Accessibility: Defining PDF Accessibility, WebAIM
This is general information, not legal advice.
Have a PDF backlog on an agency contract? Contact Konnex to talk through scope.