The ADA Title II deadline for PDFs.
State and local governments must make their web content, PDFs included, meet WCAG 2.1 Level AA by April 26, 2027 if they serve 50,000 people or more, and by April 26, 2028 if they serve fewer, or are a special district.
The dates
| Who | Deadline |
|---|---|
| State and local governments with a total population of 50,000 or more | April 26, 2027 |
| Those with a total population under 50,000 | April 26, 2028 |
| Special district governments, whatever their size | April 26, 2028 |
The Department of Justice published the rule in 2024 with deadlines of April 24, 2026 and April 26, 2027. On April 20, 2026 it moved both back by about a year. The standard itself did not change: it is still WCAG 2.1 Level AA. 1
Why PDFs are the hard part
The rule covers web content, and the documents on your website are web content. For most agencies they're also the biggest part of it: agendas, minutes, budgets, permit forms, reports and notices, posted every week, for years. A web page is fixed once in its template. Every PDF has to be dealt with one by one.
Most PDFs fail WCAG in the same ways: no headings, a reading order that jumps between columns, tables a screen reader reads as a stream of numbers, images with no description, and scans that contain no text at all.
Which PDFs are exempt
The rule has exceptions that matter for documents: 2
- Preexisting documents. PDFs, word processing files, presentations and spreadsheets posted before your compliance date are exempt, unless people currently use them to apply for, access or take part in your services, programs or activities. A permit application posted in 2019 and still in use is not exempt.
- Archived content. Exempt only if all four conditions hold: it was created before the compliance date, it is kept only for reference, research or recordkeeping, it sits in a special area for archived content, and it hasn't changed since it was archived.
- Individual documents. Password-protected documents about a specific person, property or account, such as a tax bill, are exempt.
- Third-party content. Content posted by the public is exempt. Documents your contractors post for you are not.
No exception covers next month's agenda. Everything you post after your compliance date must conform, so the documents you publish regularly are what an accessibility program has to keep up with.
What to do before the deadline
- Count your documents. Most agencies have far more PDFs than they think.
- Sort out what's in active use. Forms, applications, current budgets and meeting materials come first, because the exceptions don't cover them.
- Decide how new documents will be handled. Fixing today's backlog is pointless if next week's agenda goes up inaccessible.
- Keep a record. Document what you've made accessible and how you handle corrections.
Where Paridoc fits
Paridoc makes the documents on your site accessible without anyone opening them one by one: every PDF link opens an accessible HTML version, checked against WCAG 2.2 AA, which includes every WCAG 2.1 AA requirement. New documents are handled as you post them. Flag a problem in any document and our team fixes it, with every fix recorded. How it works.
HTML is also the format federal guidance prefers: Section508.gov says federal policy requires agencies to prioritize HTML and use PDFs only when necessary. Why HTML is more accessible than PDF.
The rule lets agencies offer a separate "conforming alternate version" only where a technical or legal limitation stops the original from being made accessible. How the rule applies to your documents is a question for your counsel. We're glad to walk them through exactly what Paridoc serves.
- Department of Justice, Extension of Compliance Dates, 91 Fed. Reg. 20902 (April 20, 2026).
- ADA.gov, Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps.
Questions
When is the ADA Title II web accessibility deadline?
April 26, 2027 for state and local governments serving 50,000 people or more. April 26, 2028 for those serving fewer than 50,000, and for all special districts. The Department of Justice moved both dates back a year in April 2026.
Does the ADA Title II rule cover PDFs?
Yes. The rule covers web content, and PDFs, Word documents, presentations and spreadsheets on your website are web content. Older documents can be exempt, but not if people use them to apply for or take part in your services.
What standard do PDFs have to meet?
WCAG 2.1 Level AA.
Do old PDFs have to be fixed?
Not always. PDFs posted before your compliance date are exempt unless people currently use them to apply for, access or take part in your services. Archived content that meets all four of the rule's conditions is exempt too. Everything you post after the deadline must conform.
Updated September 2026
Send us your website's address and we'll count your PDFs and send you a price: paridoc@efile.systems