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ADA Title II · HHS Section 504 · WCAG 2.1 AA

Accessible PDFs for colleges and universities

A public college or university answers to the ADA Title II web rule. An institution that receives HHS funding, public or private, answers to HHS’s Section 504 rule as well. Both require the PDFs you post to meet WCAG 2.1 Level AA. Here is which date is yours, where to start, and how Proof does the work and proves it.

The short answer

The Department of Justice lists public universities and community colleges among the state and local government entities Title II covers, and the rule names PDFs as covered web content. HHS’s Section 504 rule sets the same standard for any institution that receives HHS funding, directly or through another recipient, and under it the whole university is in scope, not only the funded program. Under both rules, older PDFs people still use to apply for or take part in something must meet WCAG 2.1 AA; properly archived files and older documents nobody uses can be exempt, though you will likely still need to provide them in an accessible form when someone asks.

Deadlines

Part of state government? April 26, 2027. HHS funding? May 11, 2027.

Your Title II date turns on the population the rule assigns you. An institution that is part of state government counts the state’s population. A community college district can count differently, depending on how your state organizes it, so confirm yours with counsel.

ADA Title II · 50,000+ people

Public institutions that count 50,000 people or more, including those that are part of state government

ADA Title II · smaller

Public institutions that count fewer than 50,000 people, and special district governments

HHS Section 504 · 15+ staff

Public or private institutions that receive HHS funding, with 15 or more employees

Dates as of October 2026, set by interim final rules in April and May 2026 that moved the dates and left the WCAG 2.1 AA standard and the exceptions unchanged. A lawsuit filed in May 2026 (NFB v. DOJ and HHS) asks a federal court to set aside both extensions; we update these dates when the court rules. Not legal advice.

What counts, and what’s exempt

Where to start

Fix what people use first. Sort the rest before you budget for it.

The rules ask whether anyone uses a document today to apply for, get or take part in something. If they do, it comes first. Older files nobody uses may be exempt.

Usually fix first

  • Admissions, enrollment and financial aid forms and instructions
  • Current catalogs, academic policies and student handbooks
  • Forms students use to request housing, accommodations or other services
  • Board meeting agendas and materials
  • Anything posted after your compliance date, including old files you update
  • PDFs a vendor posts for you

Sort before you fix

  • Old reports, newsletters and catalogs kept unchanged, for reference only, in an area clearly identified as archived
  • Flyers for events that are over
  • A student’s own secured documents, such as a bill behind a login
  • Files you can remove, once you have checked your records retention schedule

These are working decisions to confirm with counsel, and exempt documents must still be provided in an accessible form when someone asks. Archive, keep or fix turns the exceptions into a checklist, and finding every PDF shows how to build the list to sort.

How Ockem Proof fits

Software does the fixing. Your team makes the calls.

Ockem Proof runs 42 automated fixers and re-checks each one after it runs. What is left for a person comes to your reviewer as a short decision, such as confirming reading order, approving a color change or approving AI-drafted alt text: one at the median, two at the 90th percentile (production documents, August 2026). Every certified document gets a certificate and a public verification page stating what software verified, what your organization attested, and what is not claimed.

Start here

Count the PDFs on your site

Enter your domain. We count every linked PDF, score a free sample against WCAG 2.1 AA (12 by default, up to 100 for requests we qualify) and price the job, usually within 3 business days.

Free

Try one PDF

No account: a verified email, one document per email, up to 10 pages and 50 MB. Get the remediated file and see which checks still need a person.

(opens the Ockem Proof app)Pricing

Price the backlog

One document is a PDF of up to 50 pages: $59 on its own, and less in packs. Importing and the first check are free; you are charged when a document is certified.

For procurement. We accept purchase orders at any size and send a quote document and a W-9 (ask for a quote). Inference runs on hardware we operate; no customer document content goes to a third-party model. Your documents are never sold, never shared with other customers, and not used for model training unless your workspace turns that on. See Security and procurement.

Ockem Proof is not offered for documents that contain protected health information (PHI) or student education records protected by FERPA, and Ockem does not yet sign Business Associate Agreements. This does not apply to public documents that carry no such information, such as blank forms, notices and fact sheets. Health information and student records

Common questions

We’re a private institution. Do these rules apply?

Title II covers state and local government entities, so a private institution is outside it. If you receive HHS funding, the HHS Section 504 rule applies, and its definition of a program or activity takes in an entire private organization principally engaged in education, not only the funded program. If you take no HHS funding, neither rule’s dates apply to you; your other obligations are a question for counsel.

We receive federal funds, but not from HHS. Does the Section 504 date apply?

The WCAG 2.1 AA dates on this page come from HHS’s Section 504 rule, which covers recipients of HHS funding. Section 504 itself bars disability discrimination in any program that receives federal financial assistance, so ask counsel what it requires of you.

Does a medical school or academic medical center change anything?

It usually means HHS funding, which brings the Section 504 rule for the whole institution, not only the medical school. A state university medical center is also a public entity, and HHS has said such a recipient must comply with both rules, each with its own dates. Health organizations

Can we upload documents that contain student records?

No. Ockem Proof is not offered for documents that contain protected health information (PHI) or student education records protected by FERPA, and Ockem does not yet sign Business Associate Agreements. Please do not upload such documents to Proof, including through the free trial. This does not apply to public documents that carry no such information, such as blank forms, notices and fact sheets. Security and procurement

What does it cost?

One document is a PDF of up to 50 pages: $59 on its own, and less in packs. A longer file counts as one document per 50 pages, so a 120-page PDF is three. Importing and the first check are free, and you are charged only when a document is certified. We accept purchase orders at any size. See prices and packs

We don’t have staff for the judgment calls. Can Ockem make them?

Yes. With Assured, Ockem experts complete the judgment calls, such as alt text, reading order, contrast and table decisions, and those attestations are made by our expert, not your team. It is quoted per document. Ask for an Assured quote

Read next

Other sectors: State and local government · K-12 school districts · Health

Start with one PDF.

Free, no account: a verified email, one document per email, up to 10 pages and 50 MB. Get the remediated file and its verification record, and see which checks still need a person.

Longer document? Request an assessment.

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