Does Your City's MOU Meet the April 2026 ADA Deadline?
If your city, county, or special district has a Memorandum of Understanding posted on its website, there is a very good chance it does not meet the federal accessibility standard that takes effect on April 24, 2026 — even if the file is labeled "ADA Accessible."
We know this because we audited one. The results were startling.
What the April 2026 Deadline Actually Requires
On April 24, 2024, the U.S. Department of Justice published its final rule updating Title II of the Americans with Disabilities Act. The rule sets a specific technical standard for all digital content published by state and local governments: WCAG 2.1 Level AA.
For agencies serving populations of 50,000 or more, the compliance deadline is April 24, 2026 — less than three weeks away at the time of this writing. For smaller agencies and special districts, the deadline is April 26, 2027.
The rule applies broadly. It covers websites, mobile apps, and — critically — documents posted on those websites. That includes PDFs, Word documents, spreadsheets, and presentations. Labor agreements, agendas, budgets, resolutions, and annual reports all fall within scope.
The only documents that may be exempt are those that were posted before the compliance deadline and are not currently being used to access government services, programs, or activities. An active MOU — one that governs the pay, benefits, grievance rights, and working conditions of your employees right now — almost certainly does not qualify for that exemption.
What We Found When We Audited a Real MOU
Earlier this year we ran a PDF accessibility audit on a labor agreement published by a California city. The document had been prepared and posted by the agency's HR department. The filename included the words "ADA Accessible."
We ran it through PAC — the PDF Accessibility Checker, the ISO 14289-1 certified tool used by accessibility professionals to verify PDF/UA-1 compliance. Here is what we found:
Checkpoint
Failures
Content
1,668
Natural language
1,580
Fonts
2
Metadata
1
Total failures
3,253
Total failures: 3,253.
The document had zero structural tags, no language declaration, no document title metadata, and no reading order defined. To a screen reader — the assistive technology used by blind and low-vision employees — the document was essentially unreadable. An employee trying to understand their own employment contract using a screen reader would have received a disorganized stream of unstructured text with no way to navigate between articles, find specific sections, or understand the document's hierarchy.
That is the gap between what most agencies believe about their documents and what is actually inside them.
Why MOUs Are Particularly High-Risk
MOUs and collective bargaining agreements are among the most important documents a public agency publishes. They directly govern the terms of employment for your workforce. Under the ADA, employees with disabilities have the same right to access those documents as any other employee.
They are also among the most commonly non-compliant document types we encounter, for a few specific reasons:
They are often created by word processors without accessibility settings enabled. Most MOUs start life as a Microsoft Word document. Word can export accessible PDFs — but only if the author has enabled the right settings before exporting. Most don't. The result is a PDF that looks fine visually but has no underlying tag structure for assistive technology to read.
They are frequently updated and re-posted. Each time an MOU is amended and re-posted, the preexisting document exception no longer applies. The updated version must meet WCAG 2.1 Level AA regardless of when the original was first posted.
They are actively used documents. Even if an older MOU might otherwise qualify for the preexisting document exception, the DOJ rule carves out documents that are currently being used to access government services, programs, or activities. An active labor agreement is precisely that kind of document — employees reference it daily to understand their rights, file grievances, and access benefits.
What PDF/UA-1 Compliance Actually Means
The standard required under WCAG 2.1 Level AA for PDF documents is PDF/UA-1, formally known as ISO 14289-1. A document that meets this standard must have:
Proper document tagging. Every element — headings, paragraphs, lists, tables, figures — must be tagged with a structural role so screen readers can interpret the content correctly.
A defined reading order. The logical reading order must be specified in the tag tree, not just implied by the visual layout.
Language declarations. The document's primary language must be declared so screen readers pronounce text correctly.
Accessible tables. Tables must have properly marked header rows so screen readers can identify column and row relationships.
Document metadata. The title, author, and subject must be set in the document properties. The document title must be set to display in the title bar.
A PDF/UA-1 identifier in the XMP metadata. The document must contain a machine-readable declaration that it conforms to the PDF/UA-1 standard.
A document that passes PAC verification — with zero failures across all checkpoints — meets this standard. That passing PAC report is your objective, third-party proof of compliance.
What Happened When We Fixed It
After running the audit on the non-compliant MOU described above, we rebuilt the document from scratch using proper accessibility authoring practices. We then converted it to PDF with full tagging, language declarations, table headers, and PDF/UA-1 XMP metadata.
We ran it through PAC again. Here is what the second report showed:
Checkpoint
Passed
PDF Syntax
1,006
Fonts
6
Content
44,435
Natural language
20,956
Structure elements
126
Structure tree
936
Role mapping
942
Metadata
3
Document settings
3
Total failures
0
The PAC report confirmed: "The PDF/UA requirements checked by PAC are fulfilled."
That is the standard your documents need to meet. And it is achievable — for every document you publish.
Does the Exception Apply to Your MOU?
We get this question frequently. The DOJ rule does include a preexisting conventional electronic documents exception, which covers PDFs and Word documents posted before the compliance deadline. But the exception has clear limits that most agencies do not fully understand.
The exception does not apply if:
The document was created or updated after your compliance deadline
The document is currently being used by the public or employees to access government services, programs, or activities
The document has been modified and re-posted since it was originally published
An active MOU — particularly one covering the current contract period — almost certainly fails on at least one of these grounds, and in most cases fails on all three. Agencies that are counting on the exception to cover their labor agreements are likely taking on more risk than they realize.
What You Should Do Before April 24
The practical steps are straightforward:
Step 1 — Audit your highest-priority documents first. Start with your active MOUs, your most-downloaded agendas, and any forms the public uses to access city services. These are your highest-risk documents and the most likely to be the subject of a complaint.
Step 2 — Run a PAC check. PAC is a free tool. You can download it at pdfua.foundation and run your own documents through it in minutes. The report will tell you exactly how many failures exist and in which categories.
Step 3 — Remediate before the deadline. If your documents fail PAC, they need to be remediated — rebuilt with proper accessibility structure — before April 24. This is not a cosmetic fix. It requires restructuring the document's underlying tag tree, which cannot be done by simply re-saving the file.
Step 4 — Get the passing PAC report. When remediation is complete, run the document through PAC again. The passing report is your documentation of compliance. Keep it on file. If your agency ever receives a complaint or DOJ inquiry, that report is your evidence.
How AccessRight Can Help
AccessRight specializes exclusively in ADA document accessibility compliance for California public agencies. We audit, remediate, and certify public documents to PDF/UA-1 standard — and every delivery includes the passing PAC report as objective proof of compliance.
Our process is straightforward. You send us a document. We run the free PAC audit and send you the full failure report within 24 hours. If you want us to fix it, we rebuild the document and deliver a compliant PDF plus an accessible Word source file within 2–3 business days. You receive the before and after PAC reports so compliance is documented, not assumed.
The first audit is always free. No contract required to get started.
→ Request your free audit at accessright.io
The Bottom Line
The April 24, 2026 deadline is not a suggestion and the preexisting document exception is narrower than most agencies assume. If your city has active MOUs, current-year agendas, or public-facing forms posted on your website, the safest assumption is that they need to be audited and likely remediated before the deadline passes.
The good news is that compliance is achievable, the process is straightforward, and a passing PAC report gives you documented proof that you have met the standard. The question is not whether to address it — it is whether to address it before or after a complaint is filed.
AccessRight provides ADA Title II document accessibility compliance services for California public agencies. Every remediated document is verified with a passing PAC report under ISO 14289-1 (PDF/UA-1). Free audits available at accessright.io.