Starting in April 2026, the United States Department of Justice’s Final Rule under ADA Title II will require public entities to ensure that their digital documents, especially PDFs, comply with accessibility standards. Agencies and organizations must assess and decide whether to make documents accessible, archive them, or delete them to prepare.
The Accessibility Guy has created a practical decision tree that guides you through that process. The decision tree breaks down the steps to determine if a PDF is currently needed, actively used, legally retained, or qualifies for archival exemption. By following this method, organizations can confidently align their digital document management with upcoming ADA compliance requirements.
When you’re ready to implement, consider using DocAccess. This powerful new tool delivers instant HTML conversion, intelligent alternate text, and document accessibility with minimal setup.
Video Guide
The ADA Title II update mandates that all digital content forming part of a public program, service, or activity meet WCAG 2.1 AA accessibility standards, unless specific exemptions apply. These changes aim to ensure that everyone, including individuals with disabilities, has equal access to essential information and services.
PDF Decision Tree for Title II ADA Requirements:
1. Is this PDF still needed for a program, service, or activity?
- ✅ Yes → Then proceed to Step 2
- ❌ No →
- Can it be deleted?
- ✅ Yes → 🗑️ Delete it
- ❌ No (e.g., legal retention required) → Proceed to Step 3
2. Is the content actively used by the public or staff?
- ✅ Yes → 🛠️ Must be made accessible (WCAG 2.1 AA)
- ❌ No → Then proceed to Step 3
3. Was it created before the compliance date (April 2026)?
- ✅ Yes → Then proceed to Step 4
- ❌ No → 🛠️ Must be made accessible
4. Is it stored in a designated archive and not updated?
- ✅ Yes → Then proceed to Step 5
- ❌ No → 🛠️ Must be made accessible
5. Is it only used for reference, research, or recordkeeping?
- ✅ Yes → Then proceed to Step 6
- ❌ No → 🛠️ Must be made accessible
6. Has it remained unchanged since being archived?
- ✅ Yes → 📦 Can remain archived – Exempt
- ❌ No → 🛠️ Must be made accessible
Outcomes:
- 🔴 Delete → Any PDF not needed and not required to retain.
- 🟡 Archive → Any PDF that meets all five exemption criteria.
- 🟢 Remediate → Any PDF in use, recently updated, or having missed criteria, accessibility is required.
I hope you found this ADA Title II PDF Decision Tree helpful! When you’re ready to implement, let’s chat about how DocAccess can help you:
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!
