PDF Decision Tree for ADA Title II (Updated 2026)
Under the United States Department of Justice’s Final Rule under ADA Title II, state and local governments must ensure their digital content, especially PDFs and other documents, meets accessibility standards.
To help you prepare, The Accessibility Guy has built a practical decision tree that walks you through whether a PDF should be remediated, archived, or deleted.
Video Guide
Before you use the tree, there are two things you need to know: the current deadlines, and the two separate exceptions the rule provides for documents.
Know Your Deadline First
| Entity size | Compliance deadline |
|---|---|
| Population of 50,000 or more | April 26, 2027 |
| Population under 50,000, or any special district government | April 26, 2028 |
The Two Document Exceptions You Need to Understand
1. Pre-existing conventional electronic documents
- It is a word processing, presentation, PDF, or spreadsheet file, AND
- It was available on your website or mobile app BEFORE your compliance date.
2. Archived web content
- Created before your compliance date (or reproduces physical media, paper, audiotape, film, CD-ROM, created before that date), AND
- Kept only for reference, research, or recordkeeping, AND
- Kept in a special, clearly labeled area for archived content, AND
- Not changed since it was archived.
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 to apply for, access, or participate in a service??
-
- Yes →
Must be made accessible (WCAG 2.1 AA) Live content never qualifies for an exemption.
-
- No → Then proceed to Step 3
3. Was the PDF available on your website before your compliance date?
-
- Yes → It likely qualifies under the preexisting conventional electronic documents exception → Go to Step 4 to confirm it hasn’t been changed.
-
- No → Must be made accessible. Anything posted on or after your compliance date must meet WCAG 2.1 AA from the start.
4. Has it been edited or updated on or after your compliance date?
-
- Yes → Must be made accessible. Editing a document re-triggers the requirement.
-
- No → It remains exempt as a preexisting document → Go to Step 5 if you also want to move it into a formal archive.
5. Do you want to formally archive it? (Optional, for long-term retention)
To qualify for the stricter archived web content exception, confirm all four are true: created before your compliance date, kept only for reference/research/
All four true → 
Can remain archived, Exempt
Any one missing → 
Must be made accessible
Outcomes:
Delete → Any PDF that isn’t needed and isn’t legally required to retain.
Archive / Exempt → A preexisting, unchanged, non-live document, ideally moved to a clearly labeled archive area.
Remediate → Any PDF that is live content, was posted on or after your compliance date, or has been edited since—accessibility is required.
One Important Reminder
An exemption is not a permanent free pass. Even for content that qualifies as exempt, an accommodation request overrides the exemption. The moment a person with a disability requests an accessible version of a document, you are obligated to provide it in an accessible format. So keep a clearly posted process for handling those requests.
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!
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