ADA Title II and PDFs: what the web rule says about documents

The rule in one paragraph

In April 2024 the Department of Justice (DOJ) adopted a rule under Title II of the Americans with Disabilities Act. It applies to state and local government entities, and it makes WCAG 2.1 Level AA the technical standard for their web content and mobile apps. ADA.gov's fact sheet describes web content as "the information and experiences available on the web, like text, images, sound, videos, and documents." The fact sheet lists examples such as public schools and universities, courts, elections offices, public libraries and public transit agencies. A PDF posted on their websites is web content under the rule.

The dates

Public entity	Compliance date
Total population of 50,000 or more	26 April 2027
Total population under 50,000, and all special district governments	26 April 2028

These dates come from an interim final rule published on 20 April 2026 (91 FR 20902), which moved each original date (24 April 2026 and 26 April 2027) back by about a year. The interim rule says it "does not alter the substantive requirements adopted in the 2024 final rule": the standard is still WCAG 2.1 Level AA. Comments on it were accepted until 22 June 2026, so check ADA.gov for any later change. The full calendar for other laws is on our deadlines page.

The exceptions that matter for documents

The rule lists five exceptions. ADA.gov summarises them in plain language; the wording below follows the fact sheet.

Archived web content

Content is excepted only if it meets all four conditions:

• it was created before the date the government must comply;
• it is kept only for reference, research or recordkeeping;
• it is kept in a special area for archived content;
• it has not been changed since it was archived.

The fact sheet gives an example of what probably does not qualify: a PDF with a current map of a county park, based on data collected after the compliance date, even if it is posted in the "archive" section of the website. Being in an archive folder is not enough on its own.

Preexisting conventional electronic documents

Word processing, presentation, PDF and spreadsheet files that were available on the website or app before the compliance date usually do not need to meet WCAG 2.1 Level AA. The exception does not apply to documents that are currently being used to apply for, access or participate in the government's services, programs or activities.

The fact sheet's examples: the exception "would probably apply" to a PDF flyer for a 2018 Thanksgiving Day parade; it would not apply to a business license application posted as a PDF in 2020 that the public still uses to apply. That application would usually need to meet WCAG 2.1 Level AA.

Individualized, password-protected documents

Documents are excepted if all three conditions hold: they are word processing, presentation, PDF or spreadsheet files; they are about a specific person, property or account; and they are password-protected or otherwise secured. A PDF announcing a rate increase to all customers does not qualify.

The other two

Content posted by a third party who is not posting on the government's behalf (through a contract, licence or other arrangement), and social media posts made before the compliance date.

An exception is not the end of the matter

The fact sheet says that even where content does not have to meet WCAG, a government "would likely still need to provide the content to a person with a disability" who needs it, and "must still satisfy its other obligations under the ADA." So it helps to have a way to produce an accessible version when someone asks.

What this suggests for a document library

Read against the exceptions, a website's PDFs tend to fall into three groups:

1. Documents in current use, such as forms, applications, fee schedules, current policies, agendas and minutes for upcoming business. These are the ones the exceptions do not reach.
2. Older documents kept for reference, which may fit the archive exception if they are moved to a clearly marked archive area and left unchanged.
3. Documents nobody needs, which can simply be taken down.

Which group a particular document belongs to is a judgement for your organization and its counsel. Once the first group is known, the work is the same as for any accessible PDF: tags, reading order, a title and language, real text, alternative text and labelled form fields. The guides on checking a PDF, untagged files and remediating many PDFs cover that work.

Sources

• ADA.gov: Fact sheet on the new rule on the accessibility of web content and mobile apps
• Federal Register, 20 April 2026, 91 FR 20902: Extension of compliance dates (GovInfo text)
• The same interim final rule on FederalRegister.gov