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.

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. 
 

Archived content must still be provided in an accessible format upon request.

A PDF can be archived if all four conditions are met.

1. It was created before the April 24, 2026 compliance deadline
2. It is kept only for reference, research, or record-keeping
3. It has not been modified or updated since being archived
4. 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., 2017-Flyer-Archived.pdf)
• Moved into an dedicated archive box.com folder and labeled publicly as archived.

What to do with archived PDFs

Please follow the detailed archive guideline to move archivable PDFs into box.

• Eligibility: Content can be archived if it meets all 4 criteria: created before ADA compliance date, kept only for reference/research/recordkeeping, stored in a designated archive area, and unchanged since archiving
• Step 1 - Move to Box: Create an "Archived [Content Name]" folder in Box, upload files there, and rename each file to include "Archived" in the filename
• Step 2 - Update Drupal: Add a new section at the bottom of your page (or in a second column) with:
  • H2 heading titled "Archived [Content Name]"
  • Required disclaimer text about accessibility standards and ADA Title II exemption
  • Bulleted list of archived files with Box shared links
• Step 3 - Create A Single Box Link: Put that link into the archived section. All traffic to your archived files should flow through that single link.
• Step 4 - Cleanup: Delete the original files from Drupal after successfully moving them to Box to avoid confusion
• Key Note: Archives should be placed at the bottom of pages to lower content hierarchy, with clear labeling and the mandatory accessibility disclaimer
• You do not need to remediate them, as long as they remain inactive and clearly labeled and stored in an "archive" section of your page.
• 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.

Use the following disclaimer in Archive sections:

“Archived Content: This content is no longer maintained and may not meet current accessibility standards (WCAG 2.1 AA). It has been archived in accordance with the Archived Web Content exception defined in ADA Title II, 28 C.F.R. § 35.104. To request an accessible version or an equally effective alternative format, please email [email protected]".

please send an email [email protected] to schedule a consultation.

This checklist helps determine whether a PDF hosted on a public-facing Cal State Los Angeles 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.

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. Cal State Los Angeles 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.

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.