The Rule
What the DOJ's final rule actually requires.
On April 24, 2024, the U.S. Department of Justice published a final rule updating Title II of the Americans with Disabilities Act. For the first time, the rule sets a specific technical standard for digital accessibility: WCAG 2.1 Level AA.
The rule applies to all "web content and mobile applications" of state and local government entities. That includes websites, web apps, mobile apps, and — critically — all digital documents published on those platforms, including PDFs.
This is not guidance or a recommendation. It is a binding regulation published in the Federal Register.
Deadlines
Two deadlines. No extensions.
14 days until the ADA Title II deadline
By April 24, 2026, entities serving 50,000+ residents must make all digital content WCAG 2.1 AA compliant — including every PDF.
The population threshold is based on the total population served by the entity — not the entity's staff count. Cities, counties, school districts, public colleges, and special districts all fall under the rule. The U.S. Census Bureau's 2022 Census of Governments counts 90,837 local government entities in the United States.
Scope
Which PDFs are covered?
The rule applies to all web content made available by a public entity. If a PDF is linked from your website, published on a portal, or distributed digitally to the public, it falls under the rule. Common examples include:
The rule includes limited exceptions for archived content, content posted by third parties, and preexisting conventional electronic documents — but only if providing accessible versions would be an undue burden. The exception is narrow and must be evaluated case by case.
Enforcement
What happens if you miss the deadline?
Title II is enforced by the Department of Justice. The DOJ can investigate complaints, initiate compliance reviews, and file lawsuits in federal court. Remedies in Title II enforcement actions can include:
- Injunctive relief — court orders requiring the entity to remediate its content
- Compensatory damages — monetary awards to affected individuals
- Consent decrees — binding agreements with specific remediation timelines, monitoring, and reporting requirements
Additionally, individuals can file private lawsuits under Title II. Accessibility-related litigation has risen sharply: in the first half of 2025, digital accessibility lawsuits in federal courts increased 37% year-over-year, with 2,014 cases filed January through June.
Technical Requirements
What WCAG 2.1 AA means for your PDFs.
WCAG 2.1 Level AA includes 50 success criteria organized under four principles: perceivable, operable, understandable, and robust. For PDF documents specifically, compliance means:
- Tagged structure — every element (headings, paragraphs, lists, tables, figures) must be semantically tagged in the PDF's structure tree
- Reading order — the tag order must match the logical reading sequence for screen readers
- Alt text — all meaningful images must have descriptive alternative text; decorative images must be marked as artifacts
- Table markup — data tables need proper header cells, row/column associations, and scope attributes
- Language — the document language must be declared, and passages in other languages must be marked
- Font embedding — all fonts must be embedded with correct Unicode mappings so text can be extracted by assistive technology
Conformance is validated against the PDF/UA standard (ISO 14289), which maps WCAG requirements to PDF-specific structure. We validate every document against both PDF/UA-1 and PDF/UA-2 using the open-source veraPDF validator.