Don't start with the whole backlog. Start with the documents people rely on to use your services, such as forms, notices and applications, and make those accessible first. Then set a rule for everything new going forward, and work through the older archive in order of how often people actually ask for it. A scanned page is a picture, so a screen reader can't read it until someone prepares it.
Why this is landing on your desk now
If you work in a city, county, school or other public office, you may have heard that the ADA Title II rule now covers web content, including PDFs. For many records and clerk's offices, that means a question nobody planned for: what do we do about the thousands of scanned documents already posted or sitting in our systems?
The dates depend on the size of your entity. Under the Justice Department's April 2026 rule, state and local governments serving 50,000 people or more have until April 26, 2027. Smaller entities and special district governments have until April 26, 2028. The technical standard is WCAG 2.1 Level AA.
These dates have already moved once, so check the current rule before you plan around them. This is general information, not legal advice, and your counsel can tell you what applies to your organization.
Why a scan on its own doesn't work
Scanning solves a different problem. It makes a record easy to store and easy to search. But a scanned page is an image of text, and a screen reader has nothing to read aloud until the document has been prepared.
Preparing a document usually means a few things. The text has to be recognized so it can be read. The document needs tags and a logical reading order, so a screen reader moves through a page the way a person would. Images and charts need short text descriptions. Long files are easier to use with bookmarks and clear document properties. And forms need to work with a keyboard and a screen reader.
Done by hand across a large backlog, this is slow work, which is why many offices put it off.
Sort the backlog before you touch it
You don't have to treat every document the same way. A practical sort looks something like this.
- Documents people use to apply for or receive services. Forms, applications, notices and instructions. These go first.
- New documents from here on. It is much cheaper to create an accessible document than to fix it later. Set the expectation now for anything your staff produces or scans from today forward.
- Older archived documents. The rule has narrow exceptions, including older documents posted before your compliance date that people don't use to apply for or get services. Whether a given record qualifies is a question for your counsel.
- Documents nobody needs online. If a record doesn't need to be posted, the simplest fix may be to take it down and provide it on request. Check your retention rules before removing or destroying anything.
Where a person still needs to look
Software can do a lot of the repetitive preparation, such as adding tags and a reading order. It doesn't replace judgment. Complex tables, charts, handwritten notes and legally required notices deserve a person's review, because a wrong reading order or a missing description can make a document harder to use, not easier.
The useful question for each document is how much review it needs. A simple internal archive and a public notice people depend on shouldn't get the same level of attention.
What to do this week
- Find out which compliance date applies to your entity, and confirm it with your counsel.
- List the documents on your website and in public portals that people use to apply for or get services.
- Pick one or two of those and check them with a screen reader or a free accessibility checker to see what the gap looks like.
- Decide who in your office is responsible for new documents going forward.
- Estimate how many scanned records you have, so you can size the older archive separately.
Frequently asked questions
Where should we start with a large backlog of scanned PDFs?
Start with the documents people use to apply for or get services, and fix how new documents are created. Work through the older archive after that, in order of how often people need it.
Is a scanned PDF accessible?
Not on its own. A scan is an image of a page. It needs recognized text, tags, a reading order and, where relevant, image descriptions before a screen reader can use it.
Are older documents exempt?
The rule has narrow exceptions, including some older documents posted before your compliance date that people don't use to apply for or get services. Many documents are not exempt, so confirm with your counsel before assuming one is.
Do we have to fix every document?
Not necessarily. Some records can be removed from public view and provided on request. Whether that works for a given record depends on your obligations and your retention rules, so ask your counsel.
Let's talk about your documents
If you have scanned records or PDFs that need to be prepared for screen readers, we can talk through what you have and how much review each kind needs. You can read more on our document management page, or talk with us about your records.