1. Pre-Compliance Assessment
Before you can fix your documents, you need to understand where you stand. This initial assessment phase establishes the scope of the work and helps you plan resources and timelines.
Organizational Readiness
- Determine your deadline. Entities serving 50,000+ residents must comply by April 24, 2026. Entities serving fewer than 50,000 must comply by April 26, 2027. Use Census data to confirm your population tier.
- Assign a compliance lead. Designate a person or team responsible for overseeing document accessibility. This should be someone with authority to allocate budget and coordinate across departments.
- Establish a budget. Estimate costs based on your document volume. AI-powered remediation typically costs $0.30-$0.85 per page. Manual remediation averages $5-$15 per page. Factor in validation, training, and ongoing maintenance costs.
- Identify all departments that publish documents. Documents come from across the organization — finance, public works, planning, parks, human resources, the clerk's office, and more. Each department is a potential source of non-compliant content.
- Review your website architecture. Understand where documents are hosted — your main CMS, separate portals, third-party platforms, board meeting systems, or archived sites. All publicly accessible documents must be compliant.
- Check existing contracts. If you use third-party vendors for document creation (agenda management, financial reporting, GIS mapping), review their accessibility capabilities. Vendor-generated documents are your responsibility.
2. Document Inventory Checklist
A complete inventory of your publicly available documents is the foundation of your compliance effort. You cannot remediate what you have not identified.
Inventory Steps
- Crawl your entire website. Use a web crawler to discover every document linked from your site. This includes PDFs, Word docs, Excel files, and PowerPoint presentations. A manual review will miss documents buried deep in your site structure.
- Check all subdomains and microsites. Many governments operate multiple web properties — a main site, a parks portal, a utilities site, a transparency portal. Each must be inventoried separately.
- Include third-party hosted documents. Documents hosted on platforms like Issuu, Scribd, Google Drive, or Dropbox that are linked from your website are covered by the rule.
- Catalog document metadata. For each document, record the URL, file type, page count, department of origin, date published, and last modified date. This metadata is critical for prioritization.
- Run initial accessibility scans. Use automated tools to test each document for basic accessibility — is it tagged? Does it have a title? Is the language set? This gives you a quick severity assessment for every document.
- Count and categorize. How many total documents? How many are PDFs? How many are scanned images (zero accessibility)? How many have some tags but are incomplete? How many are fully compliant? These numbers define the scope of your project.
3. Remediation Priority Checklist
With thousands of documents to remediate, prioritization is essential. Not all documents carry equal risk or serve equal purpose. Focus your initial efforts where they matter most.
Priority 1 — Immediate
High-Traffic, High-Impact Documents
- Budget documents and financial reports — Among the most frequently accessed government documents, often legally required to be publicly available.
- Meeting agendas and minutes — Regularly published documents with high public interest. Boards, councils, and commissions generate these weekly or monthly.
- Applications, permits, and forms — Documents that residents must use to access government services. Inaccessible forms directly prevent participation.
- Emergency and public safety documents — Emergency plans, public health notices, and safety information must be accessible to all residents.
Priority 2 — High
Legally Required and Frequently Accessed
- Ordinances and municipal codes — Legal documents that affect residents' rights and obligations.
- Comprehensive plans and land use documents — Planning documents with high public interest, especially during public comment periods.
- Policy documents and procedures — Internal policies that affect public services and employee operations.
- Annual reports and performance metrics — Transparency documents that the public and media frequently access.
Priority 3 — Standard
Remaining Active Documents
- Historical documents still published online — Past meeting minutes, archived reports, and legacy content still accessible on your website.
- Newsletters and communications — Public-facing communications, press releases, and informational materials.
- Training materials and presentations — Internal and external training content published online.
Consider Removal
Before remediating every document, ask whether each one still needs to be publicly available. Outdated documents, superseded policies, and content with no current relevance may be better removed than remediated. Every document you remove is one fewer you need to fix and maintain. However, ensure removal does not violate records retention requirements.
4. Technical Compliance Checklist
Each document must meet these technical requirements to conform to WCAG 2.1 AA and PDF/UA standards. Use this checklist to verify every remediated document.
Document Structure
- Document is tagged (not an untagged or image-only PDF).
- All content is within the tag tree or marked as an artifact.
- Headings are tagged with H1-H6 in a logical hierarchy (no skipped levels).
- Paragraphs are tagged with P tags.
- Lists are tagged with L, LI, Lbl, and LBody elements.
- Reading order matches the logical visual flow of the document.
Images and Visual Content
- Every meaningful image has descriptive alt text that conveys the same information as the image.
- Decorative images are marked as artifacts (not tagged as Figures).
- Charts and graphs have alt text that describes the data, not just the chart type.
- Complex images have extended descriptions where needed.
- Information is not conveyed by color alone.
Tables
- Tables are tagged with Table, TR, TH, and TD elements.
- Header cells use TH tags with appropriate Scope attributes.
- Complex tables with merged cells have Headers attributes linking data cells to their headers.
- Layout tables (used for positioning, not data) are avoided; if present, they are not tagged as Table elements.
Metadata and Properties
- Document title is set to a meaningful, descriptive title (not a filename).
- DisplayDocTitle is set to true.
- Document language is set (e.g., "en" for English).
- PDF/UA identifier is present in XMP metadata.
- All fonts are embedded with Unicode mappings.
Navigation
- Bookmarks are present for documents longer than a few pages.
- Bookmarks mirror the document's heading structure.
- Hyperlinks have descriptive text (not "click here" or bare URLs).
- Tab order follows the document structure.
Visual Design
- Text has a contrast ratio of at least 4.5:1 against its background (3:1 for large text).
- Color is not the sole means of conveying information.
- Text is actual text, not images of text (with limited exceptions for logos).
5. Forms and Interactive Content
Interactive PDF forms — applications, permits, surveys, registrations — have additional accessibility requirements beyond static documents. If your organization publishes fillable PDFs, every form must meet these criteria.
Form Accessibility Checklist
- Every form field has a descriptive label that a screen reader can announce.
- Required fields are identified programmatically, not just visually (e.g., not just a red asterisk).
- Tab order follows the logical sequence of the form (top to bottom, left to right for multi-column layouts).
- Radio buttons and checkboxes are properly grouped with group labels.
- Dropdown menus have descriptive labels and all options are accessible.
- Submit and reset buttons have descriptive names.
- Form validation provides clear, specific error messages that identify what needs to be corrected.
- Tooltips or help text is programmatically associated with their form fields.
6. Validation and Testing
Remediation is only complete when a document passes validation. Use this checklist to verify every document before publishing.
Validation Checklist
- Run veraPDF or PAC validation — Every remediated document should pass PDF/UA-1 validation with zero failures.
- Run Adobe Acrobat accessibility check — Use as a supplementary check. Address any issues flagged.
- Test with a screen reader — Listen to a sample of remediated documents with NVDA, JAWS, or VoiceOver. Verify that the reading order makes sense, headings are navigable, and table headers announce correctly.
- Review alt text quality — Automated tools check that alt text exists but cannot evaluate quality. Manually review alt text on images, charts, and diagrams to ensure it conveys the same information as the visual.
- Verify color contrast — Spot-check text contrast, especially in documents with colored backgrounds, branded headers, or watermarks.
- Document the results — Maintain a compliance log for each document showing the validation tool used, date tested, and results. This creates an auditable record of your compliance efforts.
7. Ongoing Compliance Maintenance
Compliance is not a one-time project. Every new document published to your website must be accessible from day one, and your existing library must be monitored for regression. Build these practices into your operations.
Maintenance Checklist
- Train staff on accessible document creation. Every person who creates or publishes documents needs to understand accessibility basics — using heading styles, adding alt text in Word before exporting to PDF, running accessibility checks before publishing.
- Establish a publishing workflow. No document goes live without passing an accessibility check. Build this gate into your CMS or publishing process.
- Schedule periodic audits. Re-crawl your website quarterly to identify new documents that may have been published without accessibility review. Catch gaps before a complainant or the DOJ does.
- Update vendor requirements. Require all vendors who produce documents for your organization to deliver accessible content. Include WCAG 2.1 AA and PDF/UA conformance in procurement specifications.
- Monitor regulatory changes. Accessibility standards evolve. WCAG 2.2 has been published, and future regulatory updates may adopt it. Stay informed about changes that could affect your compliance obligations.
- Maintain a remediation log. Track which documents have been remediated, when, by whom, and what validation results were obtained. This log is your primary defense in any enforcement inquiry.
- Designate a complaint response process. Have a documented process for responding to accessibility complaints. Prompt, good-faith response to complaints significantly reduces legal risk.
8. Deadline Awareness
The ADA Title II rule established firm compliance deadlines with no extension mechanism. Understanding your timeline is critical for planning and resource allocation.
Deadline 1
April 24, 2026
Entities serving 50,000+ residents.
Less than 2 months away
Deadline 2
April 26, 2027
Entities serving fewer than 50,000.
About 13 months away
There is no phased rollout or partial compliance option. By your deadline, all web content and digital documents must conform to WCAG 2.1 Level AA. Governments that miss the deadline are immediately subject to DOJ enforcement actions, private lawsuits, and civil penalties of up to $75,000 for a first offense and $150,000 for subsequent violations.
The time to start is now. Document remediation at scale takes weeks to months, and compliance programs need time to build momentum across departments. Organizations that wait until the final months face rushed timelines, higher costs, and greater risk of gaps.
Start your compliance assessment today.
Our free scan crawls your website, inventories every document, and shows you exactly where you stand. It is the first item on this checklist — and it takes just minutes.