Which PDFs Should Local Governments Fix First for Digital Accessibility?

Most organizations can’t remediate every PDF by hand at once. Years of publishing have piled up into vast document libraries. A Department of Justice (DOJ) study sampled 28 state and local government websites and found 43,502 PDFs across them. Multiply that across every city, every county, every special district in the country, and the total volume of public PDFs nationwide likely runs into the millions.

The DOJ’s Title II rule requires state and local governments to make public PDF documents accessible. For organizations with large document inventories, deciding what to address first becomes just as important as deciding how to remediate these documents.

How to Decide Which PDFs to Prioritize

The DOJ recommends prioritizing accessibility work rather than treating every document the same. That starts with the content residents rely on most to access programs, services, and information. When prioritizing content, you may want to break PDFs into categories like:

• Essential tasks: documents residents use to submit forms, make payments, or access services
• Reach: content accessed frequently enough to affect a large number of users
• Reported barriers: documents people with disabilities have already flagged as inaccessible
• New and active content: documents currently in development or recently published, so new barriers are addressed proactively while old ones get fixed
• Shared templates: repeated formats or templates where one fix improves accessibility across every document built from them

Together, these factors provide the foundation for a consistent prioritization process, and a structured framework for PDF compliance can help apply them consistently across a large document library.

A Simple Framework for Prioritizing PDF Accessibility

Using the PDF prioritization factors identified by the DOJ above, here’s a framework local governments can adapt. Work through them in order, then adjust based on legal counsel, community needs, and what’s actually in your PDF library.

Priority 1: Documents Residents Need to Access Essential Services and Rights

These documents come first because an accessibility barrier here doesn’t just inconvenience a resident. It can cost them a deadline, a benefit, or access to information they need in an emergency. This tier includes:

• Permit applications, licenses, registrations, and payment forms
• Benefit applications and service requests
• Public safety information, election materials, and emergency communications
• Documents tied to legal rights or statutory deadlines

Within this tier, current versions take priority over previous or superseded versions. An accessible 2019 permit form doesn’t help someone who needs this year’s form, so prioritize existing PDFs accordingly.

Priority 2: Frequently Accessed Public Information

How many residents rely on a document, and how often they need it, determines its place in this tier. These are documents that support transparency, public participation, and ongoing communication between residents and their local government. It includes:

• Agendas, meeting packets, and calendars
• Reports, budgets, and ordinances
• Strategic plans and policy documents

Priority 3: Informational and Reference Documents

These documents give residents background and context. They aren’t tied to a service or task, so they fall later in the sequence. They still belong in an organization’s accessibility plan, even though they carry less urgency than documents residents need to complete a task or access a service. This includes:

• Informational guides and project summaries
• Archived meeting materials that remain actively referenced
• Historical reports and other lower-use publications

Priority 4: Archived Content

Archived content may qualify for one of the DOJ’s limited exceptions when it meets the definition of archived web content. But keep in mind:

• Older and historical documents shouldn’t automatically be treated as archived simply because they’re old or no longer updated.
• Just putting content into an archive isn’t enough to make the content qualify for this exception.

Archived status depends on how a document is maintained, whether it remains necessary for current programs or services, and whether it satisfies the rule’s other conditions. Organizations should evaluate archived content against DOJ guidance and consult legal counsel before deciding whether specific documents qualify.

Archiving a document, or pulling it off the website entirely, isn’t a workaround for remediation. A document that doesn’t actually meet the rule’s definition of archived content is still subject to WCAG 2.1, Level AA, no matter where it’s filed. And even when a document does legitimately qualify for the exception, removing it doesn’t serve residents who still need what’s in it. Hiding a barrier isn’t the same as removing one.

Organizations don’t have to choose between fixing every PDF by hand and pulling content residents rely on. Tools like DocAccess offer a way to meet the DOJ’s standard without taking documents down.

Make Prioritization Part of Your Publishing Workflow

The fastest way to reduce future work is to stop publishing inaccessible PDFs in the first place. Accessible templates and standardized workflows put PDF accessibility best practices in place before a document goes live, so new PDFs enter the library already meeting WCAG 2.1, Level AA, instead of adding to a future backlog. That takes staff who understand both accessible document creation and the organization’s prioritization process.

Regular reviews of the PDF library catch new, frequently used, or high-impact documents early, before accessibility issues pile up into another large-scale project. PDF automation tools can lighten that ongoing load too, helping organizations keep pace with what’s published without pulling staff off higher-priority work.

Estimate the Time and Cost of Making Your Documents Accessible

A prioritization framework tells you where to start. It doesn’t tell you how long that work will take or what it will cost, and that’s the next question to determine once you’ve worked through your PDF prioritization.

PDF remediation can be so challenging that many local governments remove important documents from their websites simply to stay compliant. DocAccess offers a different approach. It automatically converts PDFs into accessible HTML, so your documents become WCAG 2.1, Level AA-aligned without manual, page-by-page work. These screen reader-friendly transcripts are searchable, can be quickly translated into over 250 languages, and qualify as the preferred alternative format under federal guidelines.

Use the Document Accessibility ROI Calculator to estimate how much time and money your organization could save by reducing manual PDF remediation with DocAccess.

Frequently Asked Questions

What’s the difference between a regular PDF and an accessible PDF?

A regular PDF may look complete on screen but lack the underlying structure assistive technology needs to interpret it. An accessible PDF includes tagged headings, a defined reading order, alt text for meaningful images, and labeled form fields. These are features that let screen readers and other assistive tools navigate and interpret the document correctly.

Why are PDFs not ADA accessible?

Most PDFs aren’t automatically accessible because they’re missing the structural elements screen readers rely on. Untagged documents lack a defined reading order, which means a screen reader may read content in the wrong sequence or skip it altogether. Scanned documents saved as image-only PDFs create an even bigger barrier, since there’s no underlying text for assistive technology to read at all.

Disclaimer: This content is provided for general informational purposes only and does not constitute legal advice. CivicPlus makes no guarantees as to the accuracy or suitability of this material and disclaims all liability for actions taken or not taken based on it. Use of this content does not create any attorney-client or advisory relationship. You should consult your own legal counsel before adopting or implementing any policies. CivicPlus may update or withdraw this material at any time without notice.