The blind spot: pages pass, documents fail

You’ve invested in making your website accessible. Great. But the real exposure is usually in the documents linked from those pages—forms, agendas, reports, policies. Under ADA Title II (and Section 508 for federal contexts), those files need to meet WCAG 2.1 AA and PDF/UA as well. If they don’t, constituents can’t complete tasks, and your agency carries legal and reputational risk.

At a glance

• Who this is for: Leadership and owners of accessibility risk (Agency leadership, CIO/IT, Legal, ADA Coordinator, Communications)

• What changed: DOJ’s ADA Title II rule sets WCAG 2.1 Level AA as the technical standard for state and local government web content and mobile apps. “Web content” includes documents. ADA.gov

• When it matters: Compliance deadlines are April 24, 2026 (population 50,000+) and April 26, 2027 (0 to 49,999 and special districts). ADA.gov

• Why it’s tricky: Your web pages can look “fine,” while PDFs, forms, and posted notices create the real accessibility risk.

• Practical path: Connect → Fix → Save documentation per file → Govern, using the systems you already have (SharePoint/ECM/CMS).

• Fast first step: Run PAC (PDF Accessibility Checker) on your top public-facing PDFs to identify issues and document results. PAC checks many PDF/UA and WCAG requirements and also supports needed visual checks.

What “Public-Facing” actually covers

Think everyday business:

• Forms and applications (benefits, permits, HR)

• Agendas/minutes and public notices

• Policies, reports, fee schedules, DOT plans

• PRR/FOIA responses

These live where your teams already work—SharePoint/ECM, website CMS libraries, Box/Drive/OneDrive.

Why this becomes a leadership issue

• Constituent experience: When a veteran using a screen reader cannot access a PDF benefits application, or a parent cannot read a school system's new policy document, the mission-critical service fails. This isn't a technical glitch; it's a barrier to access that erodes public trust and slows the process for much-needed benefits.

• Compliance and credibility: ADA Title II and Section 508 non-compliance is a significant financial and reputational risk. This exposure isn't just theoretical; it arrives in the form of demand letters, lawsuits, and Department of Justice (DOJ) enforcement actions, which can cost millions and divert critical funds from public services.

• Operational drag: your agency is already paying the price for inaccessible documents. This 'operational drag' is the hidden cost of staff time—from your communications team to your legal department—manually 'chasing issues,' re-formatting one document at a time, and responding to one-off complaints instead of solving the systemic problem.

Common pitfalls (and how to avoid them)

Many well-intentioned agencies get stuck in a reactive cycle. Here's what to avoid:

• The 'Website-Only' Focus: Believing that an accessible website is the end of the story, while the hundreds or thousands of PDFs linked from it remain a liability.

• The 'Manual Whack-a-Mole': Assigning one person to manually fix PDFs as complaints come in. This approach is not scalable, is incredibly expensive, and offers no long-term proof of compliance.

• The 'Repository-as-a-Black-Box': Ignoring the tens of thousands of existing documents in your SharePoint, CMS, or other repositories. The real risk often lives in these established libraries, not just in new uploads.

A simpler way to get control without rebuilding your site.

Connect → Fix → Save proof → Govern. Four steps, all in the systems you already use.

• Connect (to where your files actually live). 
  We plug into your existing repositories—SharePoint/ECM, website CMS media libraries, Box/Drive/OneDrive. No replatforming, no site rebuild. We inventory high-risk files (top downloads, PRR/FOIA sets, critical forms) and create a clean “Top-200” list per department so work starts where impact is highest. For IT, we support SSO/RBAC, least-privilege scopes, and activity logs.

• Fix (at scale, with the right level of effort). 
  Our platform automates the heavy lift—remediating thousands of files and handling the ~80% of common issues (tags, reading order, headings, basic alt-text prompts, table structure). Anything complex (forms, multi-table reports, graphic-heavy PDFs) routes to experts for Full (100%) conformance, while routine content targets Enhanced (≥95%). You get fast progress in days, not months—without pulling staff off their day jobs.

• Save proof (put evidence where it belongs). 
  For defensibility, include a PAC-Summary.pdf, a one-page result from PDF Accessibility Checker showing pass/fail and key checks.

• We recommend storing the PAC-Summary.pdf next to the document in your repository. This makes it easier for Legal, Records, and the ADA Coordinator to locate evidence for PRR/FOIA requests, complaint review, and internal QA.

• Govern (so the problem doesn’t come back). 
  We provide you with tools to “turn off the tap” of non-compliant uploads with lightweight guardrails:

• A Governance Kit (alt-text mini-guide, archive/exception policy, evidence-retention SOP)

Result: new documents ship accessible by default, high-risk libraries stay clean, and leadership sees steady, measurable progress—without changing your website platform or document systems.

A 30-day starter plan that shows progress

• Week 1 – Inventory: Find the highest-risk files (top downloads, PRR/FOIA sets, critical forms).

• Week 2 – Prioritize: Agree on a Top-200 list across departments.

• Week 3 – Remediate: Run PAC, fix, and re-publish—no broken links.

• Week 4 – Prove & Prevent: Save PAC report in the same folder; roll out posting standards and quick training.

What “good” looks like

• Your most-used documents meet WCAG 2.1 Level AA /PDF/UA; complex forms are 100% verified.

• PAC summary lives next to the file in SharePoint/ECM.

• Dashboards show a shrinking backlog and rising first-publish pass rates.

• Records, Legal, and the ADA Coordinator have evidence on file for audits and PRR/FOIA.

Glossary

• WCAG 2.1 AA = accessibility standard for digital content.

• PDF/UA = accessibility standard for PDFs.

• PAC = a quick PDF Accessibility Checker report you can save as evidence.

Where to start

If you’re looking for a low-effort first step, book a 20-minute personalized demo to see the PAC Tool in action. To schedule your demo, fill out this form.