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Manual PDF remediation runs $5 to $25 per page. A thousand-document library will not be finished by spring.

002
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There is a better first move, and it starts with treating your document library as a digital product.

003
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WCAG-EM 2.0 replaced web-page-only vocabulary with broader terms like digital product.

004
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Its glossary lists PDF, Word, and EPUB as examples. Your document library is now something the methodology knows how to evaluate.

005
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Before the practical steps, one boundary is important to set clearly.

006
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Sampling your library gives you an evaluation. It tells you which remediation to buy and in what order.

007
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It does not give you a conformance claim. Covered documents must be accessible, not just sampled. The DOJ rule is clear on this.

008
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Map the methodology's steps onto documents and it becomes concrete quickly.

009
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Start with common views: the documents everyone lands on, like fee schedules, application forms, and meeting agendas.

010
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Next, find essential functionality. Fillable forms are the hardest category to remediate, so surface them in week one, not March.

011
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Then sort by how files were made: scanned image, Word export, InDesign, newsletter, financial report. Each is a different failure profile and a different cost.

012
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Record the technologies behind your content: the CMS, the Word template, the InDesign file, the report generator that produces untagged pages.

013
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Fix your accessibility statement, grievance procedure, and alternate-format instructions this week, regardless of what the rest of the sample shows.

014
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Add a random 10 percent set on top of the structured set. If it surfaces something new, your categories were wrong and you go back a step.

015
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Two details will come up when you write the scope document.

016
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Set your conformance target to WCAG 2.1 Level AA. The DOJ Title II rule adopts 2.1 AA. Write it into the scope and do not let a vendor evaluate you against a different standard.

017
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Product enclosure means you cannot exclude pieces from inside your scope boundary. A department cannot opt its archive out of the review.

018
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The preexisting-document exception is narrower than most people expect. It does not cover documents used to apply for or access your programs.

019
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Government PDFs test at roughly 97 percent inaccessible across large samples.

020
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That number is not describing thousands of unique problems. It is describing a few broken pipelines running at scale.

021
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A representative sample finds those pipelines.

022
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Fixing a Word template or an export setting stops new inaccessible documents at a cost of a few staff days. No per-page vendor can sell you that.

023
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Then work the backlog in order of program access: the documents residents use to apply, pay, appeal, or attend.

024
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Automated remediation is not conformance. Complex tables, forms, and anything with legal consequence for the reader still need human hands.

025
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Find the broken pipeline. Fix the source. Then work the backlog by program access. Start with the sample.

026
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Sources: WCAG-EM 2.0 W3C Group Note, WCAG-EM 1.0, 28 CFR Part 35 Subpart H, and the Allyant PDF Accessibility Index 2025 to 2026.