The Department of Justice (DOJ)’s April 2024 final rule underscored that responsibility, setting clear technical standards and deadlines for digital accessibility under the Americans with Disabilities Act (ADA). The rule formally extends long-standing accessibility obligations to websites, mobile apps and digital documents, including the beloved PDF, which must now conform to the Web Content Accessibility Guidelines (WCAG) 2.1 AA. Larger jurisdictions (with 50,000 residents or more) must comply by April 2026; smaller ones (with fewer than 50,000 residents) by April 2027.
For many CIOs, IT directors and clerks, that raises an urgent question: How can we make decades of digital documents accessible, on a fixed timeline, without draining budgets or eroding transparency?
WHY PDFs STRUGGLE WITH ADA COMPLIANCE
At a basic level, an ADA-compliant PDF must meet the same accessibility standards as web content under WCAG 2.1 AA. That means text must be searchable, images need alternative text descriptions, headings should follow a logical structure, the reading order must make sense for screen readers, and more.
In theory, that sounds straightforward. In practice, it’s not. Making PDFs accessible — whether creating them from scratch or remediating existing files — requires specialized software, technical training and painstaking attention to detail. For most local governments managing thousands of PDFs, that level of effort simply isn’t realistic.
Even with careful remediation, PDFs are fundamentally limited as an accessible format. They create barriers that make equal access difficult to achieve:
- PDFs don’t adapt to mobile screens, forcing residents to pinch and scroll.
- They are difficult to translate into multiple languages, frustrating multilingual communities.
- They deliver inconsistent experiences for screen readers, even when tagged correctly.
- They require costly, time-intensive remediation — often $7–$20 per page.
- And perhaps most importantly, remediation is a one-time fix. If standards evolve — as they likely will with WCAG 2.2 on the horizon — agencies may need to remediate the same files again.
That’s double the cost for a format that still feels clunky and outdated to residents. When governments quietly remove inaccessible PDFs to avoid these costs, the consequences are worse: Residents often assume information is being hidden, even when the intent was simply to manage expenses. That perception can erode trust and damage the very transparency governments are working to strengthen.
WHY HTML IS THE BETTER PATH
The path forward isn’t more expensive remediation — it’s a smarter format. HTML, the backbone of the web, is inherently more accessible, adaptable and sustainable than PDFs. Properly structured HTML is:
- Responsive across devices, from desktops to smartphones.
- Screen-reader friendly, with semantic markup that communicates headings, lists and tables.
- Searchable and discoverable, improving transparency and search engine optimization.
- Translatable into multiple languages with far less friction.
- Easy to update, without specialized software.
Most importantly, the DOJ rule focuses on effective communication. It doesn’t require that the original PDF be remediated [1], only that residents with disabilities have equal access to the same information. In many cases, an HTML version isn’t just acceptable — it’s superior to a remediated PDF.
Forward-thinking agencies are beginning to adopt HTML as the accessible version of record, while keeping PDFs available only for archival or print purposes. It’s a strategic shift from patching legacy files to building accessible content that can evolve alongside technology and standards.
HOW HTML FITS WITHIN THE FEDERAL ADA FRAMEWORK
Agencies don’t need to choose between transparency, compliance and budgets. By adopting HTML and human-in-the-loop AI, they can:
- Provide accessible content that residents actually want to use.
- Avoid paying twice for temporary PDF fixes.
- Strengthen transparency and community trust.
- Ensure compliance in a sustainable, legally grounded way.
Importantly, Title II of the ADA provides flexibility for agencies facing practical constraints. The law does not require strict WCAG 2.1 conformance when doing so would create undue financial or administrative burdens (28 CFR § 35.200). For many local governments, manually remediating thousands of PDFs by hand is simply not feasible within existing budgets or staff capacity.
The ADA also recognizes equivalent facilitation (28 CFR § 35.203) — meaning agencies may use alternative designs or methods that deliver substantially equivalent or greater accessibility and usability. When a PDF is converted into an accessible HTML page that meets WCAG 2.1 AA standards, it not only satisfies this provision — it often exceeds it.
Finally, under minimal impact provisions (28 CFR § 35.205), an agency is considered compliant if any remaining non-WCAG elements have no meaningful effect on access or usability. In practice, that means if residents with disabilities can access the same information, perform the same actions and participate in the same services through an accessible HTML version, the legal standard is met.
Solutions like DocAccess align squarely with these principles — generating unique, WCAG-compliant HTML pages for each document, with human oversight built in. The result is not an overlay or a workaround, but a defensible, sustainable workflow that balances accessibility, transparency and resource realities.
THE SCALE CHALLENGE
Even if HTML is the better path, local governments still face a daunting reality: tens of thousands of documents already online. Remediating them manually is rarely feasible.
That’s where automation and AI come into play. Modern tools can:
- Audit large repositories and flag accessibility issues.
- Auto-tag headings, paragraphs and lists.
- Generate alt text and correct reading order.
- Scale remediation across thousands of files in minutes, not years.
Automation is clearly the future — the real question for government leaders is how to implement AI responsibly, in a way that delivers both scale and accuracy.
HUMAN-IN-THE-LOOP: A RELIABLE MODEL
The emerging best practice is human-in-the-loop (HITL) AI. In this model, AI handles the heavy lifting at scale, while human experts provide oversight to ensure accuracy, nuance and usability.
- AI speeds the process, dramatically reducing cost and time.
- Human specialists review, correct and improve outputs — ensuring compliance is defensible.
- Continuous human feedback improves the AI over time, making the system smarter and more adaptable.
Some agencies are even pairing HITL AI with real-time human support, allowing residents with disabilities to get immediate help navigating documents. This ensures no one is left behind, even when technology encounters its limits.
For government leaders, this dual approach — HTML as the accessible baseline and AI for scale with human oversight for accuracy — represents a sustainable, future-ready path.
THE LEADERSHIP IMPERATIVE
The DOJ’s 2024 rule has set a clear timeline. But beyond the legal requirement lies a bigger opportunity: to build a digital government that every resident can trust and use.
When people can’t read a budget on their phone or access a council agenda with a screen reader, they often feel left out — or assume their government is hiding something. Accessibility isn’t just about avoiding risk; it’s about showing that transparency and inclusion are core to public service.
Agencies that move early won’t just meet compliance deadlines — they’ll strengthen public confidence, reduce long-term costs and position themselves as models of modern governance.
Accessibility is no longer just an IT initiative. It’s a leadership imperative — one that defines how government communicates its values in the digital age.
[1] See 28 C.F.R. § 35.200 (undue financial and administrative burdens may excuse full WCAG 2.1 compliance when accessibility efforts would be technically or legally infeasible); 28 C.F.R. § 35.203 (“Equivalent facilitation” permits alternative designs or methods that achieve substantially equivalent or greater accessibility and usability); 28 C.F.R. § 35.205 (minimal-impact noncompliance is deemed compliant if access for individuals with disabilities is not materially affected in timeliness, privacy, independence, or ease of use).
ABOUT THE AUTHOR
Mac Clemmens is the CEO of Streamline, a gov tech company helping local governments bridge the gap between technology, governance and compliance. He is deeply committed to helping agencies navigate evolving ADA and transparency requirements through accessible, modern technology solutions. A longtime advocate for digital inclusion, Mac received the Access Award from Disability Rights California for his leadership in making government websites more accessible to the public.
