ADA Title II · WCAG 2.1 AA

Accessible PDFs for state and local government

Under the ADA Title II web rule, the PDFs a state, city, county or special district posts must meet WCAG 2.1 Level AA: by April 26, 2027 if you serve 50,000 people or more, and by April 26, 2028 if you are smaller or a special district. You don’t have to fix every old file. Here is where to start, and how Proof does the work and proves it.

The short answer

The Department of Justice’s Title II rule makes WCAG 2.1 Level AA the standard for web content a state or local government provides, directly or through a vendor, and it names PDFs as covered. Everything you post on or after your compliance date must meet it, and so must older PDFs people still use to apply for, gain access to or take part in a service. 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

Title II applies April 26, 2027. A year later for smaller governments.

Your Title II date depends on your total population. A department that also receives HHS funding, such as a health department, answers to the HHS Section 504 rule as well, and for a smaller government that date can come almost a year sooner.

ADA Title II · 50,000+ people

States, cities and counties with a total population of 50,000 or more

ADA Title II · smaller

Governments under 50,000 people, and every special district government

HHS Section 504 · 15+ staff

A department that receives HHS funding, where the recipient has 15 or more employees

HHS Section 504 · fewer

HHS recipients with fewer than 15 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

  • Applications and permit or license forms people still download
  • Eligibility rules, fee schedules and current instructions
  • Current meeting agendas and materials
  • Election information
  • Anything posted after your compliance date, including old files you update
  • PDFs a vendor posts for you, such as on an agenda or permitting platform

Sort before you fix

  • Reports kept unchanged, for reference only, in an area clearly identified as archived
  • Flyers and notices for events that are over
  • A resident’s own secured documents, such as a tax statement in an account portal
  • 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.

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

Do PDFs our vendors post count?

Yes. The rule covers web content you provide directly or through contractual, licensing or other arrangements, so files a vendor or contractor posts for you, such as on an agenda platform, are covered.

Is every special district and school district on the 2028 date?

Every special district government is, whatever its size: DOJ’s examples include a mosquito abatement district and a water and sewer board. A school district is not a special district. It uses the population of its city or county, or, for an independent school district, the Census Bureau’s estimate for the district, so a large district can be on the 2027 date. K-12 school districts

Our health department takes HHS funds. Which date comes first?

HHS has said a recipient that is also a public entity must comply with both rules. For a county of 80,000 the dates are about two weeks apart. For a county under 50,000, the Section 504 date for a health department with 15 or more employees comes almost a year before Title II’s. The work is the same, so one plan serves both. Confirm with counsel which rules apply. Health organizations

Does Title II require PDF/UA?

No. The rule requires WCAG 2.1 AA. PDF/UA is the ISO file-format standard most checkers test, and Proof’s validator layer is built on it.

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: Higher education · 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.