Which PDFs Actually Need to Be Accessible? A Practical Prioritization Framework

If you are responsible for digital accessibility, you have probably asked: Which PDFs actually need to be accessible?

With large document libraries, deadlines like the April 2026 ADA Title II updates, and budget and staffing restrictions, trying to remediate everything at once can be impractical. What you need is a clear way to prioritize.

This guide explains exactly which PDFs need to be accessible and how to decide what to fix first.

Which PDFs Need to Be Accessible?

PDFs need to be accessible if they provide information or services to the public.

This includes any document that:

• Is published on a public website
• Supports a service, transaction, or application
• Is required for users to access information or complete a task

If a user cannot access the content, they are effectively blocked from that information or service. 

Nearly 25% of the population have a disability, and many of those use assistive technology that can only parse digital information that is accessible. Leaving content inaccessible means leaving out a quarter of your potential audience. Beyond that, studies have shown that accessible content improves your UX and SEO, and LLM search engine results.

What Documents Are Required to Be ADA Compliant?

Documents that must be ADA compliant are those that ensure equal access to public programs, services, or information.

Title II of the ADA specifically requires that all state and local government agencies and their funding recipients make their PDFs accessible according to WCAG 2.1 standards.

Title III of the ADA, which applies to private businesses, requires that places of public accommodation be accessible to everyone. The DOJ has interpreted “places” to include public websites, and that includes content found there like PDFs. Over 5,000 ADA lawsuits were filed in 2025 related to digital accessibility issues.

Common examples of public-facing PDFs include:

• Application forms and service requests
• Program descriptions and eligibility documents
• Public reports, notices, and guides
• Educational and training materials

If the document plays a role in delivering a service or communicating essential information, it must be accessible.

Do Internal PDFs Need to Be Accessible?

Internal PDFs often need to be accessible to ensure equal access for employees.

While public-facing documents carry higher legal risk, internal accessibility is still important for:

• Employees with disabilities
• Inclusive workplace practices
• Broader compliance obligations

Title I of the ADA covers employment and requires that reasonable accommodations be made for those with disabilities. This may include creating accessible documents, and failure to do so can result in lawsuits.

Organizations should not assume internal documents are exempt.

Are Archived PDFs Exempt from Accessibility Requirements?

Archived PDFs are not automatically exempt if users can access them.

An archived document may still need to be accessible if it is:

• Available on a website
• Downloadable by users
• Still referenced or used

Some organizations address this by providing accessible versions upon request or clearly labeling archived content.

If archived content is on the website but rarely used or just stored there for convenience, it may be best to remove the content until it can be remediated. Any other PDFs that are outdated, unused, or duplicated should also be removed to eliminate any potential unnecessary risk.

Who Is Responsible for Vendor-Generated PDFs?

Your organization may still be responsible for the accessibility of PDFs created by vendors.

If you publish or distribute the document, you are typically accountable for ensuring it is accessible. This is a common compliance gap, especially for government agencies and their partners. The ADA TItle II requires all content to be accessible even if a third party produced it.

How to Prioritize PDF Accessibility

The best way to prioritize PDF accessibility is to focus on impact and risk.

Start with documents that are:

• Public-facing
• Frequently used
• Tied to essential services

This includes documents like forms and applications, benefits and program information, and other high-traffic, downloadable resources.

Then evaluate each PDF using these questions:

• Is this document public-facing?
• Does it support a service or required action?
• How often is it used?
• Could inaccessibility prevent someone from completing a task?

If the answer is yes to any of these, that document should be prioritized.

After remediating the most used PDFs, next tackle the easiest. Knock out as many as possible and make progress quickly. Finally, work through remaining content as time allows.

A Practical Approach to Staying Compliant

Trying to fix every PDF at once often leads to stalled progress. A better approach is to prioritize based on real user impact.

When you start with the most important documents, you reduce compliance risk and create a more manageable path forward. Over time, this approach helps you build a sustainable accessibility process instead of a growing backlog.

Accessibility is not just about checking a box. It is about making sure people can access the information and services they need. Prioritization is what makes that possible at scale.

Need more help? Check out this 8 Step Plan to Remediate PDFs on Your Website.

Nina Overdorff

Nina comes to Equidox with years of sales and marketing experience from a variety of industries and holds a BS in Language Arts Education. Nina has a passion for words, storytelling, and information, which she believes everyone should have access to regardless of ability. After spending time as a teacher with a blind student, she became much more aware of the limitations and abilities of web accessibility, and how essential it is to those experiencing disabilities. “Being able to access information equally ensures that everyone has an equal opportunity for education, employment, and success in life.”