D-PAR PDF Decision Checklists
Digital accessibility is a legal and ethical obligation that ensures everyone—including people with disabilities—can access, understand, and use digital content equitably. Under the ADA (Titles I & II) and the Rehabilitation Act (Sections 504 & 508), public institutions must make both public-facing and employee-facing content accessible. This includes websites, documents, forms, training materials, and internal portals.
The tables below provide clear checklists to help teams determine when PDFs must be accessible, when they may be left alone, and when they should be removed or replaced. They also outline the technical features required for a PDF to meet WCAG 2.1 AA standards, and offer specific guidance for internal documents hosted behind login systems or on intranets.
D-PAR PDF Remediation Guidelines
Inclusion/Exclusion Checklist – Does the PDF Need Remediation?
This checklist helps determine whether a PDF hosted on a public-facing SF State website must be remediated to meet WCAG 2.1 AA accessibility standards under ADA Title II or Section 508. It guides content owners in identifying which PDFs must be made accessible, which may be left as-is, and which can be removed based on their usage, date of publication, and relevance.
| Condition or Situation | Recommended Action |
|---|---|
| PDF was posted or updated after your ADA/WCAG compliance date (April 2026) | Remediate |
| PDF is actively used for critical services, forms, or public processes | Remediate |
| PDF is frequently accessed or downloaded | Remediate |
| PDF contains legally required or program-critical information | Remediate |
| PDF is historical, pre-dates the rule, and is archived (not updated or used) | Left Alone (unless requested) |
| PDF is outdated, rarely accessed, and no longer needed | Remove |
| PDF content duplicates an accessible webpage | Remove or Left Alone if clearly marked archival |
| PDF is mostly visual and cannot be remediated practically | Remove or replace with accessible alternative |
| PDF is an image-only scan and lacks a searchable text layer | Remove or replace with accessible version |
ADA Title I Accessibility Checklist for PDFs Behind SSO or Intranets
This table provides guidance on whether internal documents (e.g., behind a login or on intranet) must be made accessible under ADA Title I. While not public-facing, these materials are essential for employees to perform job duties or access workplace benefits, and therefore must be accessible to ensure equal employment opportunity. SF State websites sharing information regarding internal operations will be moved behind SSO in 2026. This is a good time to decide which PDFs need to be accessible.
| Condition or Situation | Accessibility Required? | Recommended Action |
|---|---|---|
| PDF used for essential employee tasks (training, job functions, procedures) | Yes | Remediate |
| Internal policy documents (employee handbooks, HR guidelines, safety instructions) | Yes | Remediate |
| PDF containing benefits information, payroll, or legally required employment notifications | Yes | Remediate |
| Internal forms necessary for employment-related processes (e.g., leave requests, accommodation requests) | Yes | Remediate |
| Archived internal documents (historical reference, no active use, clearly labeled as archival) | No, unless requested | Left Alone (Provide accommodation if requested) |
| PDF posted for internal use after ADA compliance policy implementation | Yes | Remediate |
| PDF contains duplicate content available through an already accessible internal HTML or text-based document | No | Remove or mark clearly as archival/redundant |
| Internal-use PDF is rarely or never accessed, outdated, and irrelevant to current procedures or practices | No | Remove or archive offline |
| Complex PDF (image-based scans, complex graphics) critical for employee use but challenging to remediate | Yes | Replace with accessible alternative or HTML-based equivalent |
| Employee-generated PDFs uploaded for personal use, not broadly shared or required by others | No | Left Alone (unless requested for accessibility) |
WCAG 2.1 AA PDF Accessibility Technical Checklist
Once a PDF is identified as needing remediation, this technical checklist outlines the specific accessibility features it must include to conform to WCAG 2.1 Level AA. Each row describes a required feature—such as semantic tagging, alt text, and language declaration—and provides practical action steps for compliance. This is especially helpful for content creators, editors, and accessibility teams preparing or auditing public-facing documents.
| Checkpoint | Criteria Description | Action Required |
|---|---|---|
| Tagged PDF | Proper semantic tags for headings, lists, tables | Apply tags using Acrobat or remediation software |
| Text Readability | Text must be selectable, with logical reading order | Review reading order in Acrobat's Order pane |
| Image Alt Text | All meaningful images must have descriptions | Use Acrobat to add alt text to images/figures |
| Tables | Header cells tagged with correct scope and structure | Tag and verify table headers, use table editor |
| Form Fields | All form inputs labeled and keyboard-accessible | Add tooltips/labels and test keyboard operability |
| Links | Descriptive link text, not "click here" | Edit links for clarity and context |
| Color Contrast | Text must meet 4.5:1 contrast ratio minimum | Test using Acrobat or WebAIM contrast checker |
| Document Title | PDF must have a descriptive title in metadata | Set in File > Properties > Title |
| Bookmarks | Bookmarks for navigation in longer PDFs | Add via Acrobat's Bookmarks panel |
| Language Declaration | Document language must be specified | Set language in Document Properties > Advanced |
| No Text as Images | Text must not be rendered as images only | Use OCR tools to convert image-only text into real text |
Can I Archive this PDF?
The 2024 ADA Title II Final Rule allows certain PDFs to be exempt from accessibility remediation if they qualify as archived content. However, this exemption only applies to Title II public-facing content, not to internal content covered under Title I.
| ADA Title | Covers | Archive Rule Applies? | Examples |
|---|---|---|---|
| Title II | Public-facing content and services provided by state and local government (e.g., university websites, admissions info, academic program pages) | Yes — if all archive conditions are met | PDFs on department websites, archived event flyers, old academic catalogs |
| Title I | Employment-related information, internal systems, and documents used by employees (e.g., HR onboarding, internal training, staff portals) | No — archived PDFs must still be accessible to employees with disabilities | HR forms, benefits guides, job instructions behind SSO or on intranet |
A PDF can be archived if all four conditions are met.
- It was created before the April 24, 2026 compliance deadline
- It is kept only for reference, research, or recordkeeping
- It has not been modified or updated since being archived
- It is clearly marked as archived, either by:
- Being stored in an “Archive” section
- Having “Archive” or “Archived” in the file name or page title (e.g.,
Archived-2017-Flyer.pdf)
Remediation of non-employee facing PDFs behind SSO that are not accessible may have their remediation deferred. All PDFs must be made accessible upon request.
What to do with archived PDFs
- You do not need to remediate them, as long as they remain inactive and clearly labeled
- You must still provide an accessible version upon request to meet effective communication standards
- Archived files should not appear in current navigation, homepage links, or service pages
please reach out to access@sfsu.edu to schedule a consultation.