ADA and PDFs: documents under the Title II rule

In brief

The Title II web rule calls PDFs, word processor files, presentations and spreadsheets "conventional electronic documents". They are web content, so the standard applies to them unless an exception does.

What counts

The definition lists portable document formats (PDF), word processor file formats, presentation file formats and spreadsheet file formats, when they are web content or content in mobile apps.

Two exceptions

• Preexisting documents: documents that existed before the compliance date are excepted, unless they are currently used to apply for, access or participate in services, programs or activities.
• Individualized, secured documents: documents about a specific person, property or account that are password-protected or otherwise secured.

New documents posted after the compliance date are not excepted. A form that people use to apply for a service has to be accessible even if it is old. See Title II exceptions.

Making documents accessible

The documents and PDF page explains tags, reading order, alternative text, form fields and testing. It was written for the European Accessibility Act, but the techniques are the same.

What to do

• Inventory the documents on your site, and mark which are still used to access services.
• Fix those first, then new documents.
• Set up a way to produce accessible documents from the start.
• Offer accessible versions on request for excepted documents.

Common mistakes

• Assuming all old PDFs are excepted.
• Posting a scanned image of a form as a PDF.
• Leaving individualized documents unsecured and claiming the exception.

Sources

• 28 CFR Part 35, Subpart H: Accessibility of Web Information and Services (eCFR), opens in a new tab
• 28 CFR 35.104: Definitions (eCFR), opens in a new tab
• First Steps Toward Complying with the Title II Web Rule (ADA.gov), opens in a new tab

This page is for informational purposes only and is not legal advice. For binding requirements, refer to the official ADA statute and regulations, and ask a lawyer how they apply to you.