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PDF Remediation and Web Accessibility

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What State and Local Organizations Need to Know about ADA Compliance

Most state and local organizations are aware by now that new accessibility deadlines are coming. The real question is whether you’re ready for them.

In April 2024, the Department of Justice updated its regulations under the Americans with Disabilities Act (ADA), expanding what qualifies as “web content” and clarifying who must comply. These updates have major implications not just for websites, but for documents—especially PDFs.

Let’s break down what changed, how it affects your organization, and what practical steps you can take to get compliant.

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What Changed Under the Updated ADA Rules

The updated regulations expand accessibility requirements in two important ways:

  • First, all web content must meet accessibility guidelines. This now explicitly includes not just web pages, but also online applications, videos, and documents like PDFs.
  • Second, the rules apply broadly—to all state and local government organizations, as well as any organization that receives government funding, such as nonprofits providing public services.

For websites, accessibility requirements have been relatively well understood– typically measured against WCAG 2.1 standards. Documents, however, are another story.

Why PDFs Deserve Special Attention

PDFs are one of the most common ways organizations share information online—from reports and forms to regulations and applications. In fact, PDFs are second only to HTML as the most widely used online content format.

If your organization has been publishing content online for years, there’s a good chance you have:

  • A large number of PDFs
  • Limited visibility into where they all live
  • Little to no confidence that they’re accessible

That’s not unusual—and you’re not alone. PDF accessibility has historically been overlooked, even by well-intentioned organizations.

The good news is that this problem is manageable if you approach it step-by-step. 

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PDFs aren’t inherently bad.

But an overreliance on them creates real challenges. Compared to web pages, PDFs are often:

  • Inaccessible to screen readers and keyboard users
  • Not responsive on mobile devices
  • Difficult to update, track, and govern over time

For these reasons, we generally recommend moving away from PDFs on your website whenever possible. HTML pages are easier to maintain, more accessible by default, and better for users.

That said, some documents still need to exist as PDFs for legal, business, or user-experience reasons. The key is being intentional.

Step 1: Inventory Your PDFs

Before you can fix anything, you need to know what you have.

Start by creating a content inventory of all PDFs available on your website. For very small sites, this might be done manually. For most organizations, it’s best handled with a site crawler like Screaming Frog and exported into a spreadsheet.

Each row should represent a single document.

This step can feel tedious, but it’s foundational. You can’t make informed decisions about accessibility without a clear picture of your content.

Step 2: Evaluate What You Actually Need

Once you have an inventory, begin reviewing each document and add key details, such as:

  • When it was last updated
  • Who owns or edits it
  • How much traffic or how many downloads it receives
  • Whether the original source file still exists (Word, InDesign, etc.)

This is where many organizations realize that a significant portion of their PDFs are outdated, unused, or no longer necessary.

As you work through each document, next ask:

  • Is this still actively used?
  • Does it need to be available online?
  • Could this content be delivered as an HTML page instead?

From both an accessibility and maintenance standpoint, HTML is almost always preferable. Only keep PDFs when there’s a clear reason to do so.

Step 3: Test PDFs for Accessibility

After you’ve narrowed your list, you can begin evaluating the remaining PDFs for accessibility.

Start with automated accessibility checkers. Tools like Adobe Acrobat and other PDF accessibility scanners can help identify common issues, such as:

  • Missing document titles or language settings
  • Incorrect or missing tag structure
  • Untagged images
  • Color contrast problems
  • Table and list errors

Automated tools won’t catch everything, but they’re an essential first step.

Important Exceptions to Keep in Mind

The regulations do include important exceptions.

Documents published before the compliance deadline that are no longer being updated may be exempt from the new requirements. In other words, they can be “grandfathered in.”

This doesn’t mean accessibility doesn’t matter—but it does mean you can prioritize your efforts. Focus first on documents that are actively used, regularly updated, or critical to public access.

Step 4: Remediate PDFs That Need to Stay

Making PDFs accessible is often referred to as PDF remediation.

The goal is to ensure that documents have proper semantic structure and can be understood by assistive technologies. This typically includes:

  • A logical reading order
  • Proper heading structure (H1–H6)
  • Correct tagging for paragraphs, lists, and tables
  • Alt text for images, charts, and graphics
  • Document-level settings like title and language

Tags are the backbone of accessible PDFs. They provide the structure that screen readers rely on to interpret content meaningfully.

After automated testing, manual testing is essential. Navigate the document using only a keyboard and listen to it with a screen reader. If it doesn’t make sense audibly, it’s not accessible.

Step 5: Plan for Ongoing Compliance

Accessibility isn’t a one-time project.

Once you’ve remediated your existing documents, put systems in place to prevent backsliding:

  • Establish clear document governance and ownership
  • Require accessibility checks before publishing new PDFs
  • Continue replacing PDFs with web pages when possible
  • Archive documents that are no longer relevant

These steps help ensure accessibility becomes part of your process, not an afterthought.

Final Word

If you’re a government or government-funded organization, accessibility requirements now clearly extend to all web content—including PDFs.

This work isn’t easy, especially if you’re starting from scratch. But the sooner you begin, the more manageable it becomes.

If you need help evaluating your content, remediating documents, or building an accessibility-first approach to publishing, Electric Citizen can help.

About the Author

About the author

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Dan Moriarty is the co-founder, CEO and chief strategist with Electric Citizen.

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