Guide
Which PDFs does ADA Title II require you to fix?
A plain guide for city and county web teams: what the rule covers, what is exempt, and when it applies.
Last reviewed October 20, 2026. General information for public agencies, not legal advice. Rules change, so check the sources below and ask your lawyer or civil rights office what applies to you.
The short answer
Under the Department of Justice's 2024 rule, web content published by state and local governments, including PDF, Word, Excel and PowerPoint files, has to meet WCAG 2.1 Level AA once your compliance date arrives. In April 2026 the DOJ issued an interim final rule that moved the dates back one year. The standard did not change.
| Who you are | Compliance date |
|---|---|
| State or local government serving a population of 50,000 or more | April 26, 2027 |
| Smaller governments and all special district governments | April 26, 2028 |
Dates are reported consistently by law firms that published alerts on the interim final rule, but check the Federal Register or ada.gov before you plan around them. Our deadlines page is updated when anything changes.
What counts as a document
The rule covers what it calls conventional electronic documents: PDFs, word processing files such as Word, spreadsheets such as Excel, and presentations such as PowerPoint, when you publish them on your website or in an app. Agendas, minutes, permit applications, budgets, notices and forms are all in scope.
The exceptions, and the catch in each
The exceptions are narrow. One university accessibility office that has written about them says they will not exempt a large share of an institution's materials.
| Exception | What it covers | The catch |
|---|---|---|
| Archived web content | Content created before your compliance date, kept only for reference, research or recordkeeping, stored in a clearly identified archive area, and not changed since it was archived. | All four conditions have to be true. Moving new content into an “archive” folder does not make it exempt. |
| Preexisting conventional documents | PDFs, Word, Excel and PowerPoint files that were already on your site before your compliance date. | If someone asks for an accessible version, you still have to provide one. Sources also say a document that people still use to get a service is not safe to leave as it is. |
| Third-party content | Content posted by people outside your organization that you do not control. | Content you chose to host or that is tied to a contract is treated differently. Ask your lawyer. |
| Password-protected documents for one person | Files meant for one individual, such as a personal account document. | It applies to individual files, not to a document everyone with a login can open. |
| Preexisting social media posts | Posts made before your compliance date. | New posts are not exempt. |
New documents are different
Anything you create or post after your compliance date has to be accessible from the start. The preexisting-document exception does not cover it. That makes the process for new documents more important than the backlog: if agendas and notices are built accessibly from now on, the backlog stops growing.
How to work through a backlog
- Count what you have. List the PDFs on your site and note how many pages each one has. Cost and time depend on pages, not files.
- Start with what people use. Forms, applications, meeting materials and anything a resident needs to get a service come first. Check your site analytics to see what gets opened.
- Archive honestly. If a document meets all four archive conditions, move it to a clearly labeled archive and leave it unchanged. If it does not, fix it or take it down.
- Fix the source for new documents. Build agendas and notices in Word or your layout tool with real headings, lists and table headers, and export a tagged PDF. See our PDF checklist.
- Have a request process. Say on the page where to ask for an accessible version, and answer promptly.
What accessible means for a PDF
WCAG 2.1 AA is the standard the rule adopts. PDF/UA is a technical standard for the inside of a PDF file: tags, structure and reading order. Meeting PDF/UA is largely how you meet WCAG in a PDF, but the two are not the same thing, and an automatic checker only catches part of the problems. A person should look at the result. The checklist covers what to check by hand.
Where idioma.chat fits
pdf.idioma.chat fixes the structure of a PDF so a screen reader can follow it. It costs $0.50 per page, and your first 10 pages are free. We test our results against PDF/UA with an open checker called veraPDF, and some documents, such as complex diagrams or poor scans, still need a person to review them. We do not certify that a document or a website complies with the law. See what remediation costs for how to estimate a backlog.
Sources
- Duane Morris: DOJ extends ADA Title II digital accessibility deadlines by one year
- Jackson Lewis: DOJ extends public entities’ compliance deadline for website accessibility
- Siteimprove: ADA Title II document accessibility
- University of Wyoming: exceptions to Title II
- University of Wisconsin: exceptions to Title II