The ADA Title II web rule and your PDFs: what the rule says about the 2027 and 2028 dates

What the rule covers

The U.S. Department of Justice rule is in 28 CFR part 35, subpart H. Section 35.200(a) says a public entity shall ensure that the following are readily accessible to and usable by individuals with disabilities: (1) Web content that a public entity provides or makes available, directly or through contractual, licensing, or other arrangements.

Section 35.104 lists conventional electronic documents among its examples of web content, and defines that term as portable document formats ('PDF'), word processor file formats, presentation file formats, and spreadsheet file formats. Whether the rule reaches a particular file is a question for your attorney.

The technical standard in 35.200(b) is Level A and Level AA success criteria and conformance requirements specified in WCAG 2.1. Section 35.201 lists exceptions, such as archived web content and certain documents posted before the date that applies to you. Each has conditions in the rule text. Your attorney can tell you whether an exception fits a document.

The two dates

DOJ moved these dates from April 2026 and April 2027 in an interim final rule published April 20, 2026 (Federal Register document 2026-07663). The eCFR text above shows the current dates.

How population is counted

Section 35.104 defines total population. For a public entity with a Census count, it is the population estimate for that public entity as calculated by the United States Census Bureau in the most recent decennial Census. For an independent school district, it is the estimate as calculated by the United States Census Bureau in the most recent Small Area Income and Poverty Estimates.

A special district government is a public entity other than a county, municipality, township or independent school district, authorized by State law to provide a limited number of functions, and whose population is not calculated by the Census Bureau in those two sources. Which category and which date apply to your entity is a question for your attorney.

What we found in a small test

We tested 31 PDFs linked from the websites of 22 Texas cities, counties, school districts and colleges in September 2026. Four of the 31 were hosted by another public body or a third party. It was a small sample taken from public websites, so it doesn't describe every entity. Results:

• 25 of 31 failed at least one basic check: tags, document language, title, or a text layer.
• 16 of 31 had no tags at all, so a screen reader gets no headings, lists or table structure.
• 6 of 31 were scans with no text a screen reader can read.
• All 31 failed the PDF/UA-1 test in veraPDF, a free checking tool.

Failing files included budgets, meeting notices, academic calendars, a tax rate notice and a fillable form. We haven't measured which document type fails most often.

What staff can do in Word

If the PDF starts as a Word file, most problems are cheaper to prevent than to repair.

1. Use the built-in Heading styles (Heading 1, Heading 2) instead of bold or larger text.
2. Use real bullet and number lists, not typed dashes or numbers.
3. Build tables with Insert, Table. On the Design tab, in Table Style Options, turn on Header Row.
4. Add alt text to each picture that carries information: right-click the picture, choose Edit Alt Text, and describe the picture in a sentence or two. For a purely decorative picture, check Decorative in the same pane.
5. Write link text that names the destination page. Microsoft advises against Click here, See this page, Go here and Learn more.
6. Use the built-in Title style for the document title.
7. Select Review, then Check Accessibility, and fix what the Accessibility pane lists.
8. Choose File, Save As (or Save a Copy), pick PDF, select More options, then Options, and make sure Document structure tags for accessibility is checked.

These steps follow Microsoft's own support pages, listed under Sources. Menus can differ by Word version.

A scan, or a PDF that was never a Word file, can't be fixed this way. Those need the text and structure rebuilt.

If you'd rather hand it off

We fix PDF and Word documents to WCAG 2.1 AA and test each one with PAC and NVDA before we return it. Send a few documents and we'll send you a quote.

Sources

All read 2026-09-30 unless noted.

1. 28 CFR 35.200, requirements and dates: 28 CFR part 35, subpart H on eCFR. Cites AG Order 5919-2024 (89 FR 31337) as amended by AG Order 6742-2026 (April 20, 2026).
2. 28 CFR 35.104, definitions (web content, conventional electronic documents, total population, special district government, archived web content). Same subpart H page on eCFR, section 35.104.
3. 28 CFR 35.201, exceptions. Same subpart H page on eCFR, section 35.201.
4. Date extension: Federal Register document 2026-07663, April 20, 2026, read 2026-09-28.
5. DOJ fact sheet: ada.gov web rule fact sheet, DOJ Civil Rights Division. Not re-read on 2026-09-30.
6. Microsoft Support, all read 2026-09-30:
   • Make your Word documents accessible to people with disabilities
   • Improve accessibility with the Accessibility Checker
   • Add alternative text to a shape, picture, chart, SmartArt graphic, or other object
   • Save Word documents as accessible PDFs
7. Our PDF numbers: ScreenReady Docs test of 31 public PDFs from 22 Texas entities, September 2026 (25 of 31, 16 of 31, 6 of 31 and 31 of 31 as stated above). We make no claim by entity size.