In April 2024, the U.S. Department of Justice (DOJ) finalized a landmark rule under Title II of the Americans with Disabilities Act (ADA) that directly mandates state and local governments to make all public-facing digital content—including PDF documents—accessible to individuals with disabilities. This updated rule holds public entities responsible for ensuring electronic documents meet specific accessibility standards.
This article explains the scope of the rule, the specific requirements it enforces, the exceptions it allows, and the timeline governments must follow to comply.
Video Guide
The Scope of the New ADA Rule
The DOJ’s updated ADA Title II rule classifies PDFs and other electronic documents (like Word, Excel, and PowerPoint files) as “web content.” It requires public entities to ensure any documents they post on their websites or mobile apps comply with the Web Content Accessibility Guidelines (WCAG) 2.1 AA. This rule aims to eliminate digital barriers that often prevent people with disabilities from accessing government information or services online.
Please use my Decision Tree to help you decide if your documents need to be made accessible.
What the Rule Requires
WCAG 2.1 AA Standards
Public entities must ensure all PDF documents meet the following accessibility criteria:
- Tag all content to provide readable structure, including headings, lists, and tables, so screen readers can interpret it.
- Provide text alternatives (alt text) for all images and visuals.
- Maintain sufficient color contrast between text and backgrounds for users with visual impairments.
- Allow users to navigate documents using a keyboard alone.
Covered Documents
These accessibility standards apply to any documents governments post publicly, such as reports, forms, brochures, plans, newsletters, and data summaries. After the compliance date, public entities must ensure all new or updated content meets these requirements.
Exceptions to the Rule
The DOJ provides a few narrowly defined exceptions:
Archived PDFs
Public entities do not need to make PDFs accessible if the content:
- Was created before April 2026
- Exists only for reference or historical purposes
- Appears in a clearly labeled, segregated archive section
- Has not been modified since being archived
For example, a city can leave a 1998 budget report archived online without remediation if it meets all these conditions.
Legacy PDFs
Documents that existed before the compliance deadline qualify as exempt unless the entity still actively uses or updates them. For example, a flyer for a past event from 2018 remains exempt, but a business license application form from 2020 that is still in use must meet accessibility standards.
Individualized PDFs in Secure Accounts
Documents qualify for exemption if they:
- Are about an individual’s property, account, or identity
- Are delivered through secure, password-protected platforms
For instance, a utility bill accessible only through a resident’s personal login does not need to comply with WCAG standards.
Third-Party Content
Documents posted by unrelated third parties or old social media posts do not need to meet accessibility requirements. These exceptions typically do not involve internal PDF responsibilities.
Responsibilities Despite Exemptions
Even when a document qualifies for an exemption, public entities still have a legal duty to provide effective communication. If someone with a disability requests access to an exempt document, the government must provide it in an accessible format, such as HTML or an accessible Word file.
Compliance Timeline
For Large Public Entities (Population 50,000+)
They must comply by April 2026. After that date, they must ensure all newly posted or actively used documents are accessible.
For Smaller Entities
They will follow a different compliance timeline that the DOJ will announce separately.
From the effective date onward, governments must ensure every new document complies with accessibility standards and retrofit actively used legacy content or replace it with accessible alternatives.
Practical Implications
Governments must take several steps to meet these requirements:
- Audit existing PDFs on their websites
- Establish standard processes for creating accessible documents
- Train staff to apply accessibility principles
- Convert or replace frequently used legacy documents
- Develop internal policies to manage archived and exempt documents properly
By finalizing the 2024 ADA Title II rule, the DOJ pushes public entities to deliver equitable access to digital content. The rule makes PDF accessibility a core obligation, not an optional feature. Governments must now build inclusive digital infrastructure that accommodates all users, including those who rely on assistive technology. Meeting these standards demonstrates a commitment to legal compliance, social equity, and digital inclusion.
Here is my Decision Tree to help you decide if your documents must be made accessible.
Let me be your champion for inclusion. I offer tailored solutions (and self-paced courses!) to ensure your documents meet and exceed compliance expectations. For more detailed insights, tutorials, and in-depth discussions on accessibility and related topics, don’t forget to check out my YouTube channel: The Accessibility Guy on YouTube. Subscribe for regular updates!
