2026 ADA Deadline Compliance for State Agencies

The "just add a widget" approach to accessibility reveals its limitations most clearly when agencies confront their existing content libraries. Most state agencies are sitting on hundreds or thousands of PDFs that won't pass accessibility tests—and accessibility-related tools like SiteImprove or Userway aren’t equipped to fix them.

PDFs create significant barriers that require manual remediation

• The reading order often doesn't match the visual layout, making screen reader navigation confusing or impossible
• Without properly tagged headings, users can't navigate efficiently
• Many PDFs require a mouse to navigate and rarely adapt to smaller screens

Remediation requires tagging content with proper semantic markup, rearranging reading order, and ensuring color contrast standards. For some PDFs, this equates to a complete redo. With hundreds or thousands of documents, this quickly becomes a massive amount of work to complete before the April deadline.

There is one crucial exemption to highlight, however. 

Pre-existing PDFs maintained only for reference, and no longer updated, don't require compliance under DOJ guidance. However, any new or regularly updated documents must be made accessible, forcing organizations to either remediate PDFs or transition to HTML-based webpages. 

Web pages inherently support accessibility better—screen readers navigate semantic structure naturally, content adapts responsively, and updates are easier to manage through a CMS. For content you maintain and update, online content is the recommended path forward.

But whether you're remediating PDFs or transitioning to HTML, you're facing the same underlying problem. Automated accessibility testing tools only identify a fraction of your website's issues. 

The bulk of accessibility issues require manual testing and user testing with people who have disabilities. Automated tools miss critical problems, like whether keyboard-only users can navigate effectively, if voice-over systems make sense of your content, or whether your site meets the spirit of accessibility rather than just the letter of the law.

This is why content strategy becomes essential. You can't manually remediate your way out of a broken content creation system. You need systematic processes for how content is created, reviewed, and maintained to ensure accessibility is baked into everything you publish. Without documented workflows and clear accountability, accessibility becomes an afterthought rather than a requirement, and issues slip through even with the best intentions.

Passing an audit in April 2026 is one milestone. Maintaining compliance afterward is the real challenge. You need ongoing testing, auditing, and correction processes that function after the deadline passes and a consultant engagement ends.

DOJ requirements apply to all web content: websites, mobile apps, videos, and PDFs. A robust governance framework establishes repeatable processes for accessible content creation that work whether you're publishing a news update, creating a service page, or updating existing materials.

Start by documenting how content moves from creation to publication. Ask critical questions that prevent accessibility issues from reaching your citizens.

• Who creates accessible content?
• What standards must be met at each stage?
• What checkpoints exist before content goes live? 

Implement testing that combines three layers: automated tools catch basic technical issues quickly, manual testing with assistive technologies verifies that automated scans missed nothing critical, and user testing with people who have disabilities reveals whether your site works in practice, not just in theory.

One of the most powerful (and most overlooked) governance practices is enforcing plain language standards. 

The Plain Writing Act aligns perfectly with WCAG's cognitive accessibility requirements. Clear, straightforward writing helps citizens find information faster and makes content accessible to people with learning disabilities, non-native English speakers, and people with varying literacy levels. Plain language isn't just good practice—it's an accessibility requirement that supports your April compliance deadline and ongoing obligations.

If you're building a content governance framework from scratch—or rebuilding after years of accessibility debt—choosing the right web partner is critical to meeting the April deadline. Most RFPs we see don’t ask the questions that would reveal whether a vendor can actually deliver accessible solutions on this timeline.

Don't accept "we make sites accessible" as an answer. Ask web agencies to detail their holistic process from strategy through testing and launch. How do they incorporate accessibility into their workflow? What happens when automated testing reveals hundreds of issues three weeks before launch? Accessibility can't be tacked on at the end—and vendors who approach it that way will leave you scrambling in perpetuity.

Ask about qualifications. What accessibility training or certifications does their team hold? Do they outsource this work, creating dependencies that slow everything down? You also need assurances that the web agency has worked with government clients before and understands both DOJ requirements and the procurement constraints you're operating under. Ask for references to these clients and follow up on them.

Web partners should provide documentation showing how deliverables meet WCAG 2.1 Level AA standards, their testing methodology and monitoring tools, their approach to PDF remediation, staff training plans for your team, and post-launch support options.

Another tip: you can use those automated testing tools to check vendor websites and portfolio work before you issue the RFP. Sites that fail basic automated tests are a red flag indicating that the agency may be out of their depth. If they haven't made their own work accessible, they're unlikely to make your agency’s site any better.