Many governments, municipalities, and universities produce a lot of PDFS-From meeting minutes, to transcripts, court documents, downloadable materials, and everything in between. Often these are automated to some degree. For example: Simply paste your content or upload your file and a PDF is created and posted to the website automagically!
Why Business Operations and Vendors Cause PDF Accessibility Risks
In Phase 3 of PDF Accessibility Simplified, you want to analyze the business operations and systems that may be creating and causing accessibility violations. It’s about knowing the inputs and testing the outputs.
Why? Because in general, third party vendors, applications, and software systems are the biggest accessibility risks government agencies and municipalities have today.

Key ADA Compliance Deadlines for Governments and Municipalities
*Important* Government agencies and municipalities with 50,000 residents or more are subject to the new rules under the ADA as of April 24, 2026. For governments with less than 50,000 residents, the deadline is April 24, 2027.
The new rules under the ADA do not allow for any PDFS, or electronic files of any kind, to be published to the website unless they meet accessibility standards. Because of this, there will be swarms of demand letters and lawsuits for PDF accessibility in 2026.
How Inaccessible PDFs Multiply Legal Liability
It’s worse for some of our local government clients where fees add up quickly and exponentially. In Colorado, each individual inaccessible PDF is considered 1 violation. But that’s multiplied by the number of residents making the same claim. Meaning, 2 residents with complaints about the same 100 files equals 200 individual accessibility compliance violations and fines.
How to Test PDF Compliance in Your Systems
To test the accessibility PDF compliance risk of your business processes and operations, do the following.
Using the PDF accessibility best practices and guidance from Phase 1 – Essentials Guide and Phase 2 – Complex Tables and Forms, create an accessible version of the file or content you will upload into your system. It is critical to be sure that this content, data, or file is accessible. The input must be accessible first so that we can quantify the accessibility of your business operations and systems outputs.
For help with ensuring your files, data, and or content being uploaded are indeed accessible, reach out to us here or hire another expert who specializes in PDF accessibility.
After you collect the file outputs, test each for accessibility using automation and manual testing.
You will want to pay close attention to the reading order, heading navigation, table accessibility, interactive elements (if any), and that alternative text attributes and labels are still functional. Make sure that alternative text attributes and form labels are still functional.
Test using Adobe’s Accessibility Checker, JAWS, NVDA, and Voiceover. If available, testing with Dragon and keyboard-only navigation will provide additional assurance on accessibility compliance or if accessibility regressed.
Understanding what business operations and systems are hurting your accessibility compliance is critical to reducing your legal risk and exposure to ADA litigation now and in the long-term.

How AccessAbility Officer Helps Governments Stay ADA Compliant
AccessAbility Officer specializes in helping government agencies and municipalities minimize ADA compliance risks. For help with PDF accessibility, web accessibility, or upskilling your team with functional, hands-on trainings, let’s talk.
Ready to reduce your PDF compliance risk?
Request an Accessibility Audit today. Digital Accessibility Audits
Master All 3 Phases of PDF Accessibility Simplified
Phase 3 addresses business operations, but your PDFs must first be remediated at the content level. Make sure you’ve covered:
- Phase 1: PDF Accessibility Essentials Guide – Fix missing headings, image alt text, and color contrast.
- Phase 2: Complex PDF Accessibility – Tables, Forms, and Interactive Elements – Go deeper into fixing advanced components.