Content co-author: Mike Scott, Chief Information Accessibility Officer, State of Illinois

Throughout this year, we’re revisiting some of our past articles with a focus on refreshing key insights and adding updates to help you prepare for the first major deadline for the ADA Title II Update coming up on April 24, 2026. This deadline applies for governments serving a total population of 50,000 or more.

This month’s spotlight revisits the “Oh Snap! Startling discoveries when you reflow your PDF” article first published in July 2023. PDFs continue to be a hot topic as government agencies discover just how many PDFs exist on their websites that require accessibility remediation. Reflowing a PDF often reveals accessibility issues that aren’t obvious at first glance. 

In this update, we’ll share what’s changed since the original article and offer actionable tips to ensure your documents meet compliance requirements—not just for April, but for long-term accessibility success.

A quick background on ADA Title II

The US Department of Justice (DOJ) added digital accessibility requirements to the Americans with Disabilities Act (ADA) for Minnesota’s state and local government entities. While the final rule spans more than 320 pages, the DOJ also released a clear, practical fact sheet that everyone should read. View the quick summary below: 

• Web Content Accessibility Guidelines (WCAG) 2.1 serves as the technical standard. 
• The rule applies to web content and mobile apps that a state or local government provides or makes available, regardless of whether it is created by the government or a third party.  
• Web content includes electronic documents, videos, and other embedded or downloadable content.  
• This rule does not include non-web software.  
• The rule includes several exceptions, such as:  
  •  Archived web content.  
  •  Pre-existing conventional electronic documents.  
  •  Content posted by a third party that’s not part of a contract or licensing arrangement.  
  • Individualized, password-protected (or otherwise secured) electronic documents.  
  • Pre-existing social media posts.  
• There’s a phase-in period:  
  • April 2026 for entities with populations of 50,000 or more.  
  • April 2027 for entities with populations under 50,000. 

So, PDFs

Like many government organizations, your website likely has a large number of PDFs. If those are scanned or untagged PDFs, then they are not accessible. Even tagged PDFs can present issues if the tags are not accurate or if the document lacks headings and other key navigation components. Add in that PDFs must resize content to meet Resize Text and Reflow standards, and the challenge becomes clear. These requirements ensure documents remain usable across devices and assistive technologies.

Unfortunately not much has changed in regard to the issues we outlined in our original July 2023 article. As we noted, improvement depends on the vendor – Adobe – to improve support for reflow within the Acrobat platform.

However, with the ADA Title II deadline approaching, it’s more important than ever to keep accessibility requirements in mind as you review your documents.

So how do you get started? You can tackle this systematically. The Title II rule does offer some flexibility. It requires the PDF to be accessible if:

• It is “currently used to apply for, gain access to, or participate in services, programs, or activities.”
• It is posted after the appropriate deadline (April 24, 2026, or April 26, 2027).

If a PDF does not meet either of those criteria, it can go to the back of the line. Important Note: If a person wants to read the document and can’t, then you are required to provide an alternative, which may mean making it accessible. Including contact information on your PDF or website can allow users to request these alternatives.

General process

You can break down the process into five steps:

1. Inventory – get the complete list of PDFs on the website
2. Identify – find the owners 
3. Prioritize – active, archive, other 
4. Plan – retire, replace, remediate 
5. Prepare – guides & training

PDF inventory

How you inventory the PDFs on your website depends on the tools you have. Your content management system (CMS) may be able to generate a list, or you may already use a scanning tool.

Next, decide how you will assess accessibility. Will you assume all PDFs are inaccessible, or do you have a tool that identifies which PDFs are tagged and which are not? Check with your web team—they may already use these tools.

You can also ask the document owner to confirm whether a PDF is accessible. That step leads naturally to the next phase of the process.

Identify PDF content owners

Once you have a list of inaccessible or potentially problematic PDFs, next step is to identify who—or at least what department—owns the document. 

The most effective way to remediate an inaccessible PDF is to rebuild it from an accessible source document. Ideally, the document owner has the source document or can recreate it, if needed. 

How you contact document owners may depend on the authority you use to address these PDFs in the first place. Referencing that authority can help encourage cooperation. If your work spans multiple agencies or departments, partner with their webmasters or communications teams. They often own many of these documents and have established relationships with other document owners.

Prioritize

Once the documents have been assigned, work with the owners to help them classify the documents:

• Active (currently used to apply for, gain access to, or participate in services, programs, or activities)
• Archival
• Other (e.g., redundant or out-of-date)

There is no single required way to label a document as “archived.” The Title II rule simply requires that it be clear to the audience that the content is archived. For example, creating an archive page on your website or adding text “archive” to the link to the PDF. (Do not add “archive” or any other text to the document – otherwise that alters the document and it is no longer an archive. It must be remediated.)

Plan

Now that you’ve identified the documents, assigned them to the owners, and helped them prioritize, the next step is to set a plan to meet the accessibility requirements. There are 5 general steps:

1. Retire: Can you remove or unpublish the document from the site? 
2. Archive: Can you designate it as archival?
3. Replace: How about making it a web page (more on that below).
4. Recreate: Use a source document to rebuild a new accessible document.
5. Remediate: Fix in Adobe Acrobat Pro as a last resort.

Web page alternative

PDFs are a great way to create a static document that looks the same regardless of computer or browser. Which is why government agencies rely on them. However, in some cases, the information works just as well—or better—as a web page. Web pages are also more:

• Accessible: Once you create an accessible template, you can update the content and it’s automatically accessible. In addition, it reduces the number of steps people need to access the information. 
• Mobile-friendly: A responsive web page is easier to read on a mobile device. It would also make it more likely to meet the Reflow standard.
• Translatable: It’s much easier to automatically translate web pages than to translate (and update) multiple PDFs in different languages.

So, if you can migrate a PDF to a web page, you solve a lot of issues.

Remediation: Roll your own or outsource?

At the remediation stage, you’ll have to decide whether to handle the remediation work in-house or outsource and work with a vendor.

Outsourcing

When evaluating vendor capabilities, whether manual or automatic, we recommend using this Expectations for Accessible Documents (PDF) checklist.

Note: Some vendors claim they can scan hundreds or thousands of PDFs and remediate them all with AI or other automated tools. At this time, the Office of Accessibility does not have any personal experience with such tools. If you are considering a vendor that makes these claims, ask them to demonstrate their solution using several sample documents.

In-house

For in-house remediation, Adobe Acrobat Pro provides good built-in accessibility checkers and tools. 

For larger or more complex documents, Allyant’s CommonLook PDF tool offers a plug-in that enables a deeper dive and faster remediation.

Prepare

Now that you have a plan, you may have to train people how to identify accessible and inaccessible PDFs. If you’re remediating in-house, you’ll have to get licenses for Adobe Acrobat Pro and other tools. Here are some resources to get you started:

• Illinois Accessibility Guides
• Minnesota guidance on accessible electronic documents
• Free accessible Word training
• Massachusetts Creating Accessible Electronic Documents

Looking ahead

As you remediate existing documents, put processes in place to ensure all future documents are accessible from the start. Work with your training department and leadership to encourage everyone to learn how to make accessible documents. Promote workflows that funnel accessible source documents to specialists who can convert them to accessible PDFs or to the web team for web pages.

Summary

Whether you reach full compliance by the deadline or continue working to catch up, remember that digital accessibility is an ongoing journey. New documents, applications, and websites will always follow, so it helps to adopt an organizational policy that requires all content and web applications to be accessible. A clear policy drives the processes and procedures that help ensure any new content or websites you build or buy meet accessibility requirements. Revisit our Update to ADA’s Title II article and Preparation for the update to ADA’s Title II series for policy implementation.

Stay tuned for more updates and resources designed to make your accessibility journey smoother in 2026.