But Don't we Need to Remediate the PDF? Your Top Questions Answered

Is DocAccess Fully WCAG 2.1 AA and ADA Title II Compliant, Even If the Original File Remains Unchanged?

Yes. DocAccess is designed from the ground up to meet WCAG 2.1 AA and ADA Title II standards—even if your original files, such as PDFs, remain unchanged. Here is how we ensure compliance:

Accessible HTML, Not Just Overlays

Unlike many solutions that simply add overlays to existing files, DocAccess creates fully accessible HTML pages. Each page has its own unique URL, making it easy for users to find, share, and navigate accessible content.

Why HTML Matters for Accessibility

• HTML is recognized by accessibility experts and the World Wide Web Consortium (W3C) as the most reliable format for assistive technologies.
• Properly structured HTML works seamlessly with screen readers and other assistive devices.
• HTML adapts responsively to any screen size, including mobile devices.
• It provides predictable, consistent accessibility support.

In contrast, PDFs are often rigid, inconsistent across devices, and can be difficult for screen readers to interpret. Have you ever tried reading a PDF from a phone? Have you ever tried to translate a PDF? Neither is a user-friendly experience. It's our dream to help government move to more modern formats, and we hope this will be a positive first step.

Meeting Title II Requirements

The Department of Justice (DOJ) requires that information be accessible to people with disabilities, but does not mandate that the original file be remediated. By creating accurate, accessible HTML versions, DocAccess ensures equal access in a way that aligns with Title II obligations.

Going Beyond Compliance: Real-Time Human Support

DocAccess integrates Aira, a live, human-in-the-loop assistance service. This allows users with disabilities to receive real-time help navigating documents, providing usability that goes beyond minimum compliance.

Multilingual and Mobile-Friendly

• HTML content created by DocAccess is responsive across all devices.
• It is easily translatable into multiple languages.
• It is designed to meet modern accessibility and usability expectations.

Are Accessibility Overlays or Screen Solutions Sufficient for Compliance?

No federal or state agency has issued blanket approval for accessibility overlays. In fact, overlays have often been criticized for masking inaccessible content without addressing the underlying issues.

How DocAccess Is Different

• Not an Overlay: We do not use scripts to "cover up" inaccessible files. Instead, we build independent, fully accessible HTML pages within your website, each with its own URL.
• Proven Accessible Format: Regulators consistently recognize properly structured HTML as an accessible format. Our process focuses on precise transcripts, semantic markup, and compatibility with screen readers.
• Live Support with Aira: Users who need additional support can access live, human guidance—a safeguard that technology alone cannot provide. This important distinction classifies DocAccess as a service.
• Regulatory Focus: The DOJ’s main concern is whether individuals with disabilities have equal access to information. DocAccess ensures this by providing all content in WCAG 2.1 AA–compliant HTML, rather than relying on overlays that may not address all accessibility barriers.

What Documentation or Legal References Support DocAccess’s Compliance Claims?

We have robust legal backing and documentation to support our compliance claims.

Legal Partnership

DocAccess was co-developed with two of the nation’s most recognized ADA defense attorneys—Stuart Tubis and Martin Orlick of Jeffer Mangels Butler & Mitchell LLP. Their expertise in public-sector Title II ADA complaints ensures our approach is both practical and defensible. We have worked with them since 2022.

Case Law and Settlements

While there is no single court ruling declaring overlays compliant, courts and regulators consistently evaluate whether information is made accessible. Properly built HTML has always been considered accessible under WCAG and ADA standards.

The regulation that causes confusion

The effective communication rules in 28 C.F.R. § 35.160 (Title II) and § 36.303 (Title III) require covered entities to furnish appropriate auxiliary aids and services to ensure effective communication. In practice, many read guidance to mean “you can only use alternative content if you cannot remediate the original,” but the core requirement is equal, effective access to information.

• Entities must honor the individual’s preferred aid unless another equally effective method exists or it would cause a fundamental alteration or undue burden.
• Alternative formats are acceptable when they provide equivalent access, particularly where the original cannot practically meet accessibility needs.

Why PDFs fall short for accessibility and modern delivery

• Not mobile-friendly: PDFs are fixed-layout and require zooming and panning on small screens, creating barriers for many users.
• Limited multilingual support: Translating PDFs is cumbersome; HTML can present content in multiple languages and allow easy switching.
• Inconsistent accessibility: Even tagged PDFs often break with complex layouts, while semantic HTML is more predictable for assistive tech.
• Poor discoverability: PDFs are less searchable and update-unfriendly; HTML is SEO-friendly and updates instantly without re-uploading files.

Applying the rule to PDFs versus DocAccess

DocAccess takes the position that the HTML versions are the new primary format, and that the PDF is provided only as an alternative format for printing and archival. Yet, if one rejects this premise, even under the strict reading that prefers fixing the original, PDFs generally cannot be made truly mobile-friendly or easily translatable. Therefore, a WCAG 2.1 AA–compliant HTML equivalent is both valid and superior as an auxiliary aid.

• DocAccess delivers accurate, accessible HTML that meets WCAG success criteria and Title II’s effective communication standard.
• If one rejects HTML as the primary format, it still qualifies as a valid alternative because the original format cannot provide comparable mobile or multilingual access. Like a PDF, it can be filled out, printed, and downloaded.
• With integrated Aira human support, DocAccess ensures practical, real-world accessibility beyond checkbox compliance.

Formal Legal Opinion

We can connect you directly with Stuart Tubis for a legal opinion tailored to your specific situation.

Supporting Documentation

Our DocAccess FAQ outlines how our process maps directly to WCAG 2.1 AA requirements. We also maintain detailed documentation demonstrating our compliance methodology, which is available upon request.

Ready to Make Your Content Truly Accessible?

DocAccess is committed to delivering not just compliance, but real usability for everyone. Contact us today to learn how we can help your organization meet—and exceed—accessibility standards.