If you run a state or local government website, April 26, 2027 is the date to plan around. Under the Department of Justice’s rule for Title II of the Americans with Disabilities Act, as updated by an interim final rule on April 20, 2026, public entities serving 50,000 people or more must make their web content and mobile apps conform to WCAG 2.1 AA by then. Smaller entities and special district governments have until April 26, 2028.
Most agencies have a plan for their web pages. Fewer have one for their documents, and that is usually where the work is.
Which documents are in scope
Electronic documents are web content under the rule. If your agency posts it and people use it, assume it counts: PDFs first, but also Word files, spreadsheets and slide decks.
- Forms people fill out, print or download to apply for a service, a permit or a benefit.
- Notices, guidance and instructions that explain how a program works.
- Meeting agendas, minutes and public notices.
- Reports, plans and budgets published for the public.
The rule has exceptions, including archived content that meets specific conditions and some documents posted before the compliance date. They are narrower than they sound: an old document that people still use to apply for or take part in a service is not exempt. Read them with your counsel before you decide a pile of files doesn’t count.
What WCAG 2.1 AA means for a PDF
A PDF can look perfect and still be unusable with a screen reader. Conformance is about the structure underneath the page. In practice, an accessible PDF has:
- Tags: every heading, paragraph, list and table is marked as what it is.
- A logical reading order, so content is read in the order a sighted reader would follow, not the order it was drawn.
- Alternative text for images that carry meaning, and decorative images marked so they are skipped.
- Tables with header cells, so each value is read with its row and column.
- Form fields with labels, a sensible tab order and instructions a screen reader announces.
- The document language set, changes of language marked, and a meaningful title.
- Real text rather than a scanned picture of text, with enough contrast and nothing conveyed by color alone.
Why the backlog is bigger than you think
Agencies have published documents for decades, from many offices, with no single owner. Most were exported from word processors without structure, and many are scans. They live on several sites, and linked copies drift apart. Few agencies keep a list of what they publish, so the first honest number usually comes from an inventory, and it is rarely small.
Fixing a long, complex PDF by hand can take hours. Multiply that by thousands of files and a fixed date, and the plan has to be about choices, not effort alone.
A plan you can finish
1. Inventory
Crawl every site and file share you publish from. Record each document’s location, type, page count, last update and owning office, and whether any page links to it. Duplicates and dead files show up here, and removing them is a legitimate step.
2. Prioritize by use
Start with the documents people need to get a service: forms, applications, eligibility guidance and anything linked from high-traffic pages. Then decide, file by file, whether to fix it, replace it with an accessible web page, archive it under the rule’s conditions or retire it. A form that works better as a web form should become one.
3. Remediate: automation plus judgment
Much of the work is mechanical: tagging, setting the language and title, repairing structure a tool can infer. Automation should do that at volume. Other decisions need a person who understands the content: what an image means in context, how a complex table should read, the right order for a multi-column layout.
That split is how our practice works. In May 2026 we remediated 600+ PDFs to WCAG 2.1 AA for the New Mexico Department of Health, in one month.
We use Ockem Proof, the platform we built for document remediation. It checks documents against WCAG 2.1 AA, fixes mechanical issues automatically and leaves judgment calls to people. Measured across 10,631 findings in a government document set, it fixed 63–74% of WCAG 2.1 AA defects automatically. The rest needed a person.
4. Verify and certify
Check every document twice: with an automated checker, and, for the ones that matter most, with a person using assistive technology. A document is done when every check is resolved, not most of them. Keep the record of what was checked, by whom and when, so you can answer a complaint with evidence.
5. Keep new documents compliant
A remediated backlog refills within months if nothing upstream changes. Give authors accessible templates, teach them to use real headings and styles in the tools they already use, add an accessibility check to your publishing workflow, and write the requirement into contracts with the vendors who produce documents for you.
If you also receive HHS funding
Health departments and other recipients of HHS funding have a parallel obligation under HHS’s Section 504 rule, which also points to WCAG 2.1 AA. Its first compliance date fell in May 2026. If both rules apply to you, the earlier date has already passed, so run one program that meets both.
Where to start this month
Pick one site. Inventory its documents, sort them by use and remediate the top of the list. That one exercise will tell you more about your real backlog than any estimate.
This article is general information, not legal advice. Confirm your obligations and dates with your counsel.
Topics
- Accessibility
About the author
Base22
Digital experience studio