Document accessibility law is fragmented across countries, sectors, and dates, and most summaries cover one regime at a time. This page puts the regimes that most commonly reach a document publisher side by side, with the primary source for each, so that a team responsible for PDFs in more than one jurisdiction can see what actually differs. Each row links to a fuller guide. This is general information, not legal advice; the sources are the law.
The table
| Regime | Who is covered | Technical standard | Key dates | Old documents |
|---|---|---|---|---|
| US: ADA Title II web rule (28 CFR 35 Subpart H) | State and local governments, including public schools and universities | WCAG 2.1 Level A and AA | April 26, 2027 (population 50,000 or more); April 26, 2028 (under 50,000 and special districts) | Preexisting conventional electronic documents excepted unless currently used to apply for, access, or participate in a service; archived content excepted under four conditions |
| US: HHS Section 504 rule (45 CFR 84 Subpart I) | Recipients of HHS financial assistance: hospitals, clinics, health centres, state health agencies | WCAG 2.1 Level AA | May 11, 2027 (15 or more employees); May 10, 2028 (fewer than 15), after a May 2026 extension | Mirrors the Title II exceptions |
| US: Section 508 (Revised 508 Standards) | Federal agencies and ICT they procure | WCAG 2.0 Level A and AA incorporated; documents tested against the ICT Testing Baseline for Electronic Documents v1.0 (September 30, 2024) | In force since January 2018 | No general legacy exception; agencies prioritise HTML over PDF |
| US: Colorado HB21-1110 | Colorado state agencies and local governments, including school districts | OIT Technology Accessibility Rules (8 CCR 1501-11), WCAG 2.1 Level AA | July 1, 2024; immunity extended to July 1, 2025 for good-faith efforts (HB24-1454); grace period now ended | No document cutoff in the statute; $3,500 statutory damages per violation per plaintiff |
| UK: Public Sector Bodies Accessibility Regulations 2018 | Public sector bodies | WCAG 2.2 AA (monitored by GDS since October 2024) | In force September 23, 2018; accessibility statement required | Documents published before September 23, 2018 exempt unless users need them to use a service |
| EU: Web Accessibility Directive (2016/2102) | Public sector bodies in member states | EN 301 549 V3.2.1 (WCAG 2.1 AA), cited in the Official Journal in 2021 | Fully applied since 2020 and 2021 | Office file formats published before September 23, 2018 excluded unless needed for active administrative processes |
| EU: European Accessibility Act (2019/882) | Economic operators providing listed products and services: e-books, consumer banking, e-commerce, and more | Functional requirements in Annex I; EN 301 549 under revision to support it | Applies from June 28, 2025; transitional period for some services to June 28, 2030 | Office file formats published before June 28, 2025 excluded from website content requirements; microenterprise service providers exempt |
| Canada: Accessible Canada Regulations (SOR/2025-255 amendments) | Federal public sector and federally regulated private sector with 100 or more employees | CAN/ASC-EN 301 549:2024 (EN 301 549 V3.2.1, WCAG 2.1 AA) | Web pages: December 5, 2027 (public sector), December 5, 2028 (private); non-web documents: December 5, 2028 (public sector and 500+ employee businesses) | Applies to newly created or updated content; heritage content exempt |
| Canada: Ontario AODA (O. Reg. 191/11) | Designated public sector organisations and businesses or non-profits with 50 or more employees | WCAG 2.0 Level AA, excluding 1.2.4 and 1.2.5 | January 1, 2021 | Applies to web content published after January 1, 2012; unconvertible content requires an explanation and summary on request |
What is the same everywhere
- Documents are web content. Every regime treats a PDF, Word, PowerPoint, or spreadsheet file published on a website or app as content subject to the standard, not as a separate category. The Title II rule defines "conventional electronic documents" precisely to make that clear.
- Live forms are never grandfathered. Each legacy exception stops at documents people use to access a current service; see accessible PDF forms.
- WCAG is the yardstick, at AA. The version differs (2.0, 2.1, or 2.2) but the level does not. PDF/UA is not named as the legal standard anywhere in the table; it is a technical route to WCAG outcomes, as the PDF/UA versus WCAG guide explains.
- Alternatives on request remain a duty. The ADA's effective communication obligation, the UK and Ontario accessible-format duties, and Canada's alternative-means requirement all sit alongside the technical standard.
What differs, and why it matters
Cutoff dates. The UK and EU public sector rules use September 23, 2018 as the document cutoff; the EAA uses June 28, 2025; the Title II and HHS rules use each entity's own compliance date; Ontario uses January 1, 2012. A document archive that spans several of these needs a single conservative policy rather than per-regime triage.
Who enforces. The ADA and Section 504 are enforced by the DOJ and HHS and through private litigation; Colorado created a private right of action with statutory damages; the UK's regulations are monitored by the Government Digital Service and enforced by the equality commissions; the EAA is enforced by national market surveillance authorities; Canada's regulations by the Accessibility Commissioner. The practical difference is the speed and cost of a complaint.
Version drift. WCAG 2.2 is the current W3C recommendation, the UK has moved to it, and EN 301 549 is being revised toward it, while U.S. rules cite 2.1 or 2.0. Building documents to WCAG 2.2 AA satisfies every row of the table, which is why DocAccessible's automated checks target 2.2 AA; see WCAG 2.2 AA for documents.
Deeper guides
- ADA Title II: the 2026 extension and the Title II exceptions for documents
- The HHS Section 504 rule for health providers
- Section 508 document testing
- Colorado HB21-1110 and documents
- UK public sector PDFs
- EN 301 549 clause 10 and the EAA and the EAA and e-books
- Canada: the Accessible Canada Regulations and AODA
Frequently asked questions
Which laws require PDFs to be accessible?
In the United States, the ADA Title II web rule (state and local government, WCAG 2.1 AA from April 26, 2027 or 2028), the HHS Section 504 rule (health providers, from May 11, 2027 or May 10, 2028), Section 508 (federal agencies), and Colorado's HB21-1110. In the UK, the Public Sector Bodies Accessibility Regulations 2018 (WCAG 2.2 AA). In the EU, the Web Accessibility Directive for the public sector and the European Accessibility Act from June 28, 2025. In Canada, the Accessible Canada Regulations (from December 5, 2027) and Ontario's AODA (WCAG 2.0 AA).
Is PDF/UA required by law?
None of the regimes checked for this guide names PDF/UA as the legal standard. They name WCAG at Level AA (version 2.0, 2.1, or 2.2 depending on the regime) or, in the EU, EN 301 549, which applies WCAG-derived requirements to documents. PDF/UA is a technical route to those outcomes and useful evidence, not a substitute.
Do old PDFs have to be made accessible?
Usually not, if they predate the regime's cutoff and are not used for a current service. The UK and EU public sector rules exempt documents published before September 23, 2018 unless needed for a service or active administrative process; the ADA Title II and HHS rules exempt preexisting documents unless currently used to apply for or participate in a programme; the EAA excludes office files published before June 28, 2025 from website requirements. Any document still used for a live process is in scope regardless of age.
Sources
The statements above rest on the primary sources below. Where a source is a law or standard, the version and date named in the text are the ones checked on the review date. This guide is general information, not legal advice.
- eCFR: 28 CFR Part 35, Subpart H, Web and Mobile Accessibility
- Federal Register, May 11, 2026: HHS extension of compliance dates for web content and mobile applications
- U.S. Access Board: ICT Testing Baseline for Electronic Documents
- Colorado OIT: FAQ, HB21-1110 Colorado Laws for Persons with Disabilities
- Colorado General Assembly: HB24-1454
- GOV.UK: Understanding accessibility requirements for public sector bodies
- EUR-Lex: Directive (EU) 2016/2102 (Web Accessibility Directive)
- EUR-Lex: Commission Implementing Decision (EU) 2021/1339
- EUR-Lex: Directive (EU) 2019/882 (European Accessibility Act)
- Canada Gazette, Part II, December 17, 2025: Regulations Amending the Accessible Canada Regulations (SOR/2025-255)
- Ontario.ca: How to make websites accessible
Keep reading
ADA Title II exceptions for PDFs and documents
What 28 CFR 35.201 actually excepts from the WCAG 2.1 AA requirement, with the DOJ's own examples: archived web content, preexisting conventional electronic documents, third-party content, individualized password-protected documents, and social media posts.
Read the guide →EN 301 549 clause 10 for documents and the EAA
Clause 10 of EN 301 549 applies WCAG-derived requirements to downloadable documents such as PDFs. What it covers, the version cited in EU law, the V4 draft moving to WCAG 2.2, and how the European Accessibility Act, in force since June 28, 2025, uses it.
Read the guide →Canada document accessibility: ACA regulations and AODA
Canada's amended Accessible Canada Regulations set December 2027 and 2028 dates for web pages, apps, and non-web documents against CAN/ASC-EN 301 549:2024. Who is covered, the exemptions, and how Ontario's AODA (WCAG 2.0 AA) applies to documents.
Read the guide →