ADA Title II PDF requirements: deadlines, exceptions and a plan

Who must comply

The rule applies to state and local government entities under Title II of the ADA: cities, counties, towns, school districts, public colleges and universities, public libraries, transit authorities, courts, utilities and other special districts. The ADA’s definition of “State” also includes the Commonwealth of Puerto Rico, Guam, the U.S. Virgin Islands, American Samoa and the Northern Mariana Islands (42 U.S.C. § 12103).

It covers web content and mobile apps an entity provides directly or through contractors and vendors — so a PDF hosted on an agenda-management or permitting platform still counts (28 CFR 35.200).

Compliance dates

The original 2024 rule set dates in 2026 and 2027. An interim final rule published April 20, 2026 pushed both back one year (Federal Register):

“Total population” is the population of the jurisdiction the entity belongs to, based on Census data — a school district inside a large city may still be a special district. Check the ADA.gov fact sheet for how your entity is classified.

Which PDFs are covered (and the exceptions)

By default, every PDF, Word, Excel or PowerPoint file you make available online must meet WCAG 2.1 AA from your compliance date. The rule lists five exceptions (28 CFR 35.201):

1. Archived web content — created before the compliance date, kept only for reference, research or recordkeeping, not changed since archiving, and stored in a clearly labeled archive area.
2. Preexisting conventional electronic documents — documents available before your compliance date, unless they are currently used to apply for, gain access to, or participate in your services, programs or activities.
3. Content posted by third parties — unless they post on your behalf under a contract or arrangement.
4. Individualized, password-protected documents — about a specific person, their property or account (for example a utility bill behind a login).
5. Preexisting social media posts.

Exception 2 is narrower than it looks. Application forms, fee schedules, eligibility rules, maps and current policies are “currently used” — even if you posted them years ago. The DOJ explains the reasoning in Appendix D to Part 35. When in doubt, ask counsel; this page is not legal advice.

What WCAG 2.1 AA means for a PDF

WCAG is written for web content in general, but for a PDF it comes down to a handful of structural requirements (see our PDF accessibility checklist):

• Real text, not a scanned image (OCR first).
• Tags that expose headings, lists, tables and reading order to screen readers.
• Alternative text for meaningful images; decorative images marked as artifacts.
• Data tables with header cells; forms with labeled fields and a logical tab order.
• A document title and a primary language; sufficient color contrast.

Many teams also validate against PDF/UA, the ISO standard for accessible PDF. The rule itself references WCAG 2.1, not PDF/UA — we explain the difference in PDF/UA vs WCAG.

A 5-step plan for your backlog

1. Inventory

   Export every PDF from your CMS, agenda system and file shares. Include legacy subdomains. Record where each file is linked.

2. Triage

   Sort files into scanned, untagged, tagged-with-issues, metadata-only and passing. That split drives cost far more than page count alone. PDF Triage does this for whole folders in your browser.

3. Decide per document

   Archive (if it truly qualifies), remove, convert to an accessible web page, or remediate. Converting simple notices to HTML is often cheaper than remediating the PDF.

4. Remediate by priority

   Start with forms, applications and documents people need to access services. Use the cost calculator to budget.

5. Stop creating new debt

   Fix templates at the source (Word, InDesign, your agenda tool) so new PDFs are born accessible, and check every upload.

Frequently asked questions