When most agencies think about digital accessibility, the first thing that comes to mind is the website. They evaluate color contrast, test for keyboard navigation, and maybe even add alt text to images. But while websites get all the attention, there’s a hidden risk lurking deep in your digital presence—one that’s often overlooked, yet just as critical:
👉 Your public document archive.
Agendas, minutes, permits, applications, notices, forms, reports—the bread and butter of public transparency and service delivery—are often stored as PDFs, Word documents, or scanned images. And far too often, those files are completely inaccessible to the people who need them most.
With the new 2024 Department of Justice rule setting a 2026 deadline for compliance under the Americans with Disabilities Act (ADA), ignoring your document archive could put your entire agency at risk.
What’s in a “Document Archive”?
A document archive refers to all the digital files your agency has made publicly available through your website or portals over the years. This includes:
- Meeting agendas and minutes
- Permits, forms, and applications
- Budget documents and financial reports
- Planning documents and maps
- Emergency notices and health advisories
- School calendars and lunch menus
- Archived newsletters or announcements
These files might live in:
- A dedicated document repository or “Document Center”
- Linked folders on Google Drive or SharePoint
- Individual department pages
- Scattered links in meeting calendars or news posts
The issue isn’t how they’re stored—it’s how they’re built.
Most PDFs Are Not Accessible
Even if you’re using a sleek CMS and have added accessibility features to your website itself, chances are your documents tell a different story.
We regularly audit municipal and agency websites, and here’s what we find:
- No Tags: Many PDFs are completely untagged, making them unreadable by screen readers.
- Auto-Tagged Garbage: Some are auto-tagged but still lack proper headings, lists, or reading order.
- No Alt Text: Charts, tables, or maps have no descriptions or alternative formats.
- Scanned Images: Entire files are just flat image scans with no searchable or selectable text.
- Incorrect Reading Order: Paragraphs are jumbled or fragmented, especially in multi-column layouts.
None of this meets the standard of WCAG 2.1 Level AA or the PDF/UA standard expected under the new ADA rule.
Why This Puts You at Risk
The 2024 DOJ rule clarifies that all public-facing digital content must be accessible, including:
- Websites
- Mobile apps
- Documents and PDFs
Agencies serving 50,000+ residents must comply by April 24, 2026. Smaller agencies have until 2027.
📣 And yes, this includes historical documents still in active use.
If someone with a disability can’t:
- Fill out an application form
- Read a meeting notice
- Understand a budget document
…then you’re not meeting the requirements of the ADA. And that can lead to:
- 🧑⚖️ Lawsuits or DOJ investigations
- 💸 Loss of federal funding
- 📉 Erosion of public trust
Real People Are Affected
Digital accessibility isn’t just a legal checkbox—it’s a matter of inclusion and equity. Inaccessible documents can block access for:
- Blind users relying on screen readers
- People with low vision who zoom or adjust contrast
- Users with cognitive disabilities who need clear headings and structure
- People who use voice navigation or alternative input devices
Imagine being unable to:
- Apply for housing assistance
- Find information about your child’s school
- Learn about an upcoming town hall
That’s the real impact of inaccessible documents.
Where to Start
Here’s how to assess and address the risk in your document archive:
1. Inventory Your Files
- How many documents are public-facing?
- Where are they hosted?
- What file types are most common?
2. Prioritize High-Risk Documents
- Frequently accessed or downloaded
- Forms, permits, and applications
- Emergency notices or critical updates
3. Audit for Accessibility
- Use tools like PAC 2021, CommonLook, or Adobe Acrobat’s accessibility checker
- But don’t rely on automation alone—manual review is essential
4. Remediate or Replace
- Tag and structure PDFs using PDF/UA best practices
- Convert scanned files to readable text using OCR
- Rebuild in accessible HTML when possible
5. Establish a Workflow
- Require accessibility for all newly created documents
- Train staff and vendors
- Include accessibility requirements in procurement documents
- Create an accessibility page with a feedback mechanism
Need Help? That’s What We Do.
I’m Ann Landis, a CPACC-certified accessibility consultant with 20+ years in web and document accessibility.
I specialize in:
- Accessibility audits (websites, documents, and portals)
- PDF/UA remediation
- Strategic compliance roadmaps
- Staff and vendor training
We help agencies like yours meet the new ADA standards—without blowing up your workflow or budget.
Book a Free 30-Minute Consultation
We’ll review your current state and help you prioritize next steps.
Let’s Make It Accessible for Everyone
Your agency exists to serve the public. Let’s make sure everyone in your community can access the information and services they need—starting with your documents.
