Accessible PDFs, or Why You Should Stop Posting So Many of Them

Open almost any borough, township or authority website and click around for a minute. The agenda is a PDF. So are the minutes, the fee schedule, the trash calendar, the permit application, the newsletter and the budget. On a phone, each one opens as a tiny full page you have to pinch and drag to read. For someone using a screen reader, many of them read as a jumble, or as nothing at all.

The short answer: under the federal ADA Title II rule, documents a local government posts online after its compliance date have to meet WCAG 2.1 Level AA, and that includes PDFs. The cheapest way to comply is usually to post fewer PDFs. Put schedules, fee lists and announcements directly on web pages, use online forms instead of fillable PDFs where you can, and save PDFs for documents that genuinely need a fixed format, like official minutes and agendas. For those, make them accessible when you create them, and post the text on the page alongside the file. Older PDFs posted before the deadline may be covered by an exception, but not if people still use them to apply for or access a service.

Why PDFs are a problem in the first place

PDF was designed to make a document look the same when it's printed. The web was designed for the opposite: content that reflows to fit any screen and any assistive technology. That mismatch causes most of the trouble.

• They're hard to read on phones. A letter-sized page shrinks to fit a phone screen, so readers have to zoom and scroll side to side. Large files also take time and data to download.
• They're often inaccessible. A PDF that was scanned from paper is just a picture of text, and a screen reader can't read it at all. Even PDFs exported from Word or other software frequently lack the hidden structure, called tags, that tells a screen reader what's a heading, what's a table and what order to read things in.
• They're hard to find and use. Nielsen Norman Group, which has studied how people use websites for decades, concluded in 2020 that PDFs are still "unfit for human consumption" online. In its research, users skipped, abandoned or complained about PDFs, and content inside them was often missed.
• They go stale. A PDF is a separate file. When the fee changes, someone has to edit the original, export it again and replace the upload. Often nobody does.

We covered the bigger picture in website accessibility and the ADA in 2026. This post is about the documents.

What the Title II rule says about PDFs

The Justice Department's 2024 rule requires state and local governments' web content, including documents, to meet WCAG 2.1 Level AA. Under the current deadlines, governments serving 50,000 people or more must comply by April 26, 2027, and smaller governments and special districts by April 26, 2028.

The rule includes an exception for preexisting conventional electronic documents: word processing, presentation, PDF and spreadsheet files that were already on the website before the government's compliance date. But the exception has limits that catch a lot of real documents:

• Anything posted after the compliance date must be accessible. A PowerPoint posted for next month's council meeting doesn't qualify, even if it looks like an old document.
• Documents updated after the compliance date lose the exception. The Justice Department's example is a Word document posted in 2020 and later updated with new contact information.
• Documents people still use to get services don't qualify. The Justice Department's example is a 2020 PDF business license application that the public still uses. Permit forms, rental registrations and application packets fall in the same category.
• The ADA's other duties still apply. Even when a document is exempt, the government still has to provide effective communication, such as an accessible version on request.

Pennsylvania municipalities have an added reason to get this right. Since Act 65 of 2021 amended the state Sunshine Act, agencies with a website must post meeting agendas there at least 24 hours before the meeting. That means a steady stream of new agendas, every one of which falls under the Title II rule once your deadline arrives. (This is general information, not legal advice. Your solicitor can tell you how the rules apply to your municipality.)

Minutes and agendas are records, not just web content

Meeting minutes and agendas aren't like a fee schedule you can rewrite as a web page and forget. They're official public records. A municipality has to keep them for as long as its records retention schedule requires, which in Pennsylvania is set by the Municipal Records Manual published through the State Archives. Some records must be kept for years, and some permanently.

That means the answer for minutes and agendas usually isn't "replace the PDF." It's "keep the official PDF, make it accessible, and put the same text on the web page next to it." Residents get something they can read on a phone or with a screen reader, and the office keeps the official record intact.

Rule one: if it could be a web page, make it a web page

For everything else, the most effective accessibility fix for most PDFs is not to fix the PDF. It's to stop making one. Text, lists, simple tables and headings on an ordinary web page are accessible by default when the site is built well, work on every phone, show up in search, and can be updated in a minute.

When you do keep a PDF, Nielsen Norman Group recommends a "gateway" approach: a regular web page that summarizes the key points in text and offers the PDF as a download. Visitors get the answer without opening the file, and the PDF is there for anyone who needs to print it or needs the official copy.

Writing those pages in plain language helps too. We show before-and-after examples, including a borough permit page, in writing web pages in plain language.

Rule two: make the PDFs you keep accessible at the source

Fixing an inaccessible PDF after the fact is slow and expensive. Building accessibility into the original document is fast and nearly free. Most PDFs start life in Word or a similar program, so that's where the work belongs.

In Word, Google Docs or similar programs:

1. Use real headings. Apply the built-in Heading 1, Heading 2 and so on, instead of making text bold and bigger.
2. Use real lists and simple tables. Use the list buttons, and give every table a header row. Avoid merged and split cells.
3. Add alt text to images that carry information, and mark purely decorative images as decorative.
4. Write meaningful link text, like "2027 budget" instead of "click here."
5. Check contrast. Light gray text on white fails for many readers.
6. Set the document title and language in the file properties.
7. Run the built-in checker. Word's Check Accessibility tool catches many common problems before you export.

When you export: use "Save as PDF" or "Export to PDF" with the option to create tags turned on. Printing to PDF usually throws the tags away.

After you export: if you have Adobe Acrobat Pro, run its accessibility checker and review the reading order. For complex documents, the international standard for accessible PDFs is PDF/UA (ISO 14289).

Scanned documents: a scan is only an image. At minimum, run text recognition (OCR) and then tag the result, or post the text on the page alongside it. Signed originals can stay on file in the office; the website copy doesn't need to be the scan.

This isn't just for governments

Private businesses aren't covered by the Title II rule, but the same problems apply. A restaurant menu posted only as a PDF, a price list as a scanned image or an intake form that can't be filled out on a phone loses customers, and under Title III of the ADA, inaccessible websites draw lawsuits. A menu on a real web page is also easier for search engines and AI assistants to read, which we cover in how to show up in AI answers.

How we handle it

For municipal clients, we review the documents on the site, flag the PDFs that need to be remade, and recommend and implement alternatives, such as turning fee schedules and calendars into web pages or replacing fillable PDFs with online forms.

We also work with each municipality's staff to make sure they know how to create accessible PDFs themselves, so every new agenda, set of minutes and notice starts out accessible instead of needing to be fixed later.

For minutes and agendas, we use KosmicCivic, a WordPress plugin we built for municipal websites. When the office uploads the official PDF, it also pastes the text of the minutes or agenda into the same entry. The website keeps the PDF as the record and shows the text right on the page, so residents can read it on any device and the archive stays intact for as long as the municipality needs to keep it.

Sources

• U.S. Department of Justice, Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments
• Federal Register, Extension of Compliance Dates (DOJ interim final rule) (April 20, 2026)
• Nielsen Norman Group, PDF: Still Unfit for Human Consumption, 20 Years Later (2020)
• Pennsylvania Municipal League, New Public Meeting Requirements Under the Sunshine Law (2021)
• Pennsylvania State Archives, Local Government Retention and Disposition Schedules
• W3C, Web Content Accessibility Guidelines (WCAG) 2.1

This article is general information, not legal advice. The illustrations are AI-generated.