Earlier this year, we published Preparing for the April 2027 ADA Deadline & Beyond: A Guide to PDF & Document Accessibility to help organizations understand upcoming Title II requirements and begin planning for compliance.
Since then, the Northwoods team has been partnering with government agencies, municipalities, higher education institutions, and K-12 school districts to assess their digital content environments and build practical accessibility roadmaps.
As organizations adapt to the Department of Justice’s (DOJ) updated compliance timeline, several clear patterns are emerging. The DOJ has set the deadline at April 26, 2027 for large public entities (50,000+ population) and April 26, 2028 for smaller entities and special districts. While every organization faces unique hurdles leading up to these deadlines, we’re seeing striking consistencies in both the challenges that arise and the most effective solutions to address them.
The good news? The updated timeline gives organizations the space to address these issues thoughtfully. The better news? Many are using that time to move beyond short-term compliance "fixes" and toward sustainable digital governance.
Here’s what we’re seeing in the field.
PDFs Remain the Largest Accessibility Gap
Over the past several years, most organizations have made meaningful progress on core website accessibility. Modern content management systems, automated monitoring tools, improved design practices, and increased internal awareness have significantly improved outcomes across public-facing websites.
However, when we perform comprehensive accessibility assessments today, one issue consistently rises to the top: PDFs and other non-HTML files remain the single largest source of accessibility risk.
In many cases, documents account for the vast majority of compliance issues identified during an audit. Common findings include:
- Missing or incomplete document structure and heading tags
- Incorrect reading order for screen readers
- Inaccessible interactive elements, such as fillable forms
- Missing navigation elements, like bookmarks in long documents
- Incomplete metadata, such as titles, language tags, etc.
- Complex tables and layouts that do not work with assistive technologies
It isn’t surprising that non-HTML files are so prevalent. PDFs have long been an easy way to publish information online. They allow teams to quickly upload reports, agendas, forms, policies, studies, and presentations. Over time, those documents accumulate. What does surprise organizations, however, is just how much content has quietly piled up over the years and that the bulk of it was never created with accessibility in mind.
Most Organizations Underestimate the Scope
One of the first lessons our clients learn during an audit is that the challenge is significantly larger than anticipated.
A department may estimate that it has a few hundred documents online. A comprehensive digital scan often reveals thousands of files spread across multiple websites, forgotten subdomains, historical repositories, and content systems.
In addition to PDFs, organizations frequently uncover:
- Word documents and Excel spreadsheets
- PowerPoint presentations
- Duplicate files uploaded across different pages
- Legacy content that hasn’t been accessed in years
- Documents hosted outside the primary website by third-party vendors
Before remediation can begin, you need an exact inventory of what exists. This discovery process has become one of the most critical first steps in accessibility planning and budgeting.
The Risk Landscape Has Changed
For years, organizations understood that PDFs were not the ideal way to deliver information online. However, limited staff resources, competing priorities, and budget constraints made large-scale remediation difficult to justify when the perceived risk of enforcement was low.
That environment has completely changed. Organizations are increasingly dealing with:
- Direct digital accessibility complaints from constituents
- Demand letters from law firms targeting non-compliant documents
- Public scrutiny regarding equity and digital inclusion
- Frantic, expedited remediation projects driven by tight internal deadlines
As a result, accessibility is no longer viewed solely as an IT or compliance obligation. It is increasingly recognized as an operational and reputational risk that requires proactive leadership. The organizations making the most progress are the ones addressing these issues now, while they still have the runway to build a sustainable approach.
There Is No "Set It and Forget It" Solution
Given the sheer volume of documents, it’s understandable that many organizations look for a silver bullet approach. While automated remediation tools and artificial intelligence continue to improve, automation alone is not a cure-all.
As we've mentioned before, web accessibility overlays and 100% automated shortcuts simply don't work. Accessibility at scale requires a process, not just a tool.
- Automation is fantastic for catching and resolving baseline issues, including:
- Missing tags and basic document structures
- Initial metadata improvements
- Common formatting errors
However, human or AI-assisted review is still necessary to validate:
- Reading order: Ensuring a screen reader reads content in the logical sequence
- Complex layouts: Multi-column structures, data tables, charts, and graphics
- Image context: Ensuring alt text accurately conveys the meaning of a graphic rather than just describing it literally
- Forms and interactivity: Making sure a user can navigate a document using only a keyboard
AI is becoming increasingly helpful in our accessibility workflows to accelerate reviews and assist with heavy lifting, but it cannot fully replace human judgment. Accessibility is ultimately about usability, and usability requires understanding context, intent, and the experience of real users.
A Pragmatic, Three-Step Strategy Is Emerging
As organizations move from assessment to action, we’re seeing a highly practical three-step strategy emerge. The goal isn't to remediate every single document in your archive immediately; it’s to focus your resources where they create the greatest impact.
Step 1: Reduce the Problem First
Before remediating anything, determine what content actually needs to remain online. This sounds simple, but it is often the most challenging part of the process.
Look for opportunities to:
- Remove outdated or under-accessed content
- Eliminate duplicate files
- Archive legacy materials that qualify under the DOJ’s historical exceptions
By partnering with an experienced accessibility team, you can utilize automated scanning tools to map out your document ecosystem. In many cases, organizations discover that a substantial portion of their document inventory no longer serves an active business purpose. Archiving or deleting those files instantly slashes your remediation scope and costs.
Step 2: Convert High-Value Content to Webpages
Instead of asking, "How do we make this PDF accessible?" successful organizations are now asking, "Should this content be a PDF at all?"
For frequently accessed information, HTML webpages provide a vastly superior long-term solution. Converting high-value content to webpages offers significant advantages:
- Easier maintenance: Accessibility is far easier to achieve and maintain natively in your CMS than in an external file.
- Mobile-first design: Webpages automatically scale to mobile screens, whereas PDFs force users to pinch and zoom.
- SEO & AI discoverability: Search engines and AI discovery systems can crawl, index, and interpret native web content much more effectively.
Step 3: Remediate the Documents That Need to Stay
Not every document can or should become a webpage. Annual reports, legally regulated forms, meeting packets, massive datasets, and official public records often need to remain in document format.
Once you’ve cleared out the noise and converted high-value content to HTML, you can target your remediation budget strictly toward the documents that must stay. At this stage, you can prioritize files based on traffic, user impact, and complexity.
The Long-Term Play: Governance
The single biggest mistake we see organizations make is treating accessibility as a one-time project. Even if you successfully remediate thousands of documents today, the exact same compliance gaps will return tomorrow if your team continues to publish inaccessible files.
The ultimate solution to PDF accessibility isn't technical – it's organizational. True compliance requires establishing sustainable content governance early by implementing:
- Clear document creation standards
- Accessible, pre-tagged document templates
- Ongoing training programs for content authors
- Strict publishing review workflows
Without clear organizational standards and continuous monitoring, remediation becomes a recurring expense rather than a permanent solution.
Moving Beyond the Compliance Box
The upcoming ADA deadlines are an important milestone, but compliance shouldn't be your only goal. The organizations finding the most success are using this regulatory pivot to modernize their content, clean up their digital footprint, and create better online experiences for everyone.
Accessibility is not a one-and-done project. It is an ongoing commitment to delivering information in a way that works for all users. The work you do now, done thoughtfully and with the right strategy, builds a foundation that extends well beyond any single deadline. The teams that we see building accessibility into their DNA today will be the ones best positioned for success tomorrow.
Need help navigating the upcoming ADA deadlines? Whether you need a comprehensive scan of your document library, expert manual remediation, or accessibility training for your content creators, Northwoods is here to help. Contact our digital accessibility experts today to get started.
