FileSeen Blog

3 in 4 US government PDFs fail basic accessibility checks, with 6 months left before the ADA deadline

FileSeen Desk — Sat, 24 Oct 2026 20:40:00 +0000

On 26 April 2027, US state governments, and cities and counties with 50,000 or more people, must make their web content meet WCAG 2.1 Level AA under Title II of the ADA. PDFs count. FileSeen downloaded 4,779 government PDFs and checked every one: only 23.5% passed five basic checks.

184 days to 26 April 2027, when states and large cities and counties must meet WCAG 2.1 AA (184 days as of 24 October 2026).

What the test found

4,779 public PDFs from 272 state agencies, state portals, cities, counties and public universities in all 50 states and DC, fetched on 24 October 2026.

Only 23.5% pass five basic checks (tagged, language set, title shown, real text, alt text on images): 1,121 of 4,779 files.
32.7% have no tags at all, so a screen reader gets no headings, tables or reading order.
0.6% pass the PDF/UA-1 machine checks in veraPDF, the open-source PDF validator (28 of 4,767).
Files dated since the April 2026 delay still fail 64.4% of the time.
Forms and applications fail 74.7% of the time, and forms in use are not covered by the exception for older documents.
California’s state sites pass 92.3%. South Carolina’s sampled files pass 0%.

These are minimum failures. A file that passes an automated check can still be hard to use; a file that fails one is missing a feature assistive technology relies on.

What the rule says, and what changed

The Department of Justice published the ADA Title II web rule on 24 April 2024. An interim final rule published on 20 April 2026 (91 FR 20902) moved the dates back by one year. The dates in force today, in 28 CFR 35.200:

Who	Must meet WCAG 2.1 Level A and AA from
States, and other public entities with a total population of 50,000 or more (except special district governments)	26 April 2027
Public entities under 50,000, and all special district governments	26 April 2028

PDFs are named in the rule: 28 CFR 35.104 defines “conventional electronic documents” as content in “portable document formats (“PDF”), word processor file formats, presentation file formats, and spreadsheet file formats.” Agencies and state universities count with their state’s population under the same section, so every site in this test is on the 2027 date.

Two exceptions in 28 CFR 35.201 matter for PDFs:

Archived web content: made before the deadline, “retained exclusively for reference, research, or recordkeeping”, “not altered or updated after the date of archiving”, and stored in an area “clearly identified as being archived”.
Preexisting documents posted before the deadline, “unless such documents are currently used to apply for, gain access to, or participate in the public entity’s services, programs, or activities.” A permit application posted in 2019 is still covered if people use it today.

So the useful question is not only how many old PDFs fail, but whether the documents made today, and the forms people still fill in, are any better. That is why the results are split by document date and by type.

The results

Check	Pass rate
Tagged (has a structure tree)	67.3%
Document language set	68.2%
Title set and shown in the viewer	35.7%
Real text (not a scan or picture of text)	95.2%
Every image in a tagged file has alt text	35.8% of files with images
All five basic checks	23.5%
veraPDF PDF/UA-1 (machine-checkable rules)	0.6%

Of 57,333 images inside tagged PDFs, only 27.0% have a text alternative.

Newer files are better, but not good

PDF internal date	Files	Basic pass	Untagged
Before the rule (before 24 Apr 2024)	1,726	12.1%	43.6%
Between the rule and the delay	1,975	27.7%	24.9%
Since the delay (20 Apr 2026 or later)	1,006	35.6%	26.8%

Basic pass rate by the date stored inside each PDF.

The direction is right; the pace is not. At 35.6%, nearly two in three documents made since the delay would fail on day one, and anything posted after 26 April 2027 gets no “preexisting” exception at all.

Forms are no better. 1,166 files look like forms or applications: 74.7% fail the basic checks and 32.7% are untagged. Forms dated in the last 12 months do better (42.5% pass), but still mostly fail.

Cities trail everyone

Basic pass rate by type of entity, all sampled PDFs.

Entity type	Files	Basic pass	Untagged
Public universities	644	35.4%	28.0%
State agencies	2,809	26.3%	29.4%
State portals	207	25.1%	36.2%
Counties	499	12.6%	37.7%
Cities	620	6.3%	47.6%

Of the 25 cities with at least 5 files tested, 12 had not a single passing PDF.

State by state

State government files only: the main portal plus the same five agencies in every state (public health, transportation, revenue, labor and environment). A state is ranked only with at least 25 files from at least 2 sites. Samples are small: treat a gap of a few points as noise.

Rank	State	Basic pass	Untagged	Files	Sites
1	California	92.3%	1.1%	91	5
2	Minnesota	78.0%	7.3%	41	3
3	Colorado	74.2%	19.4%	62	4
4	Texas	61.7%	11.1%	81	5
5	Iowa	49.4%	11.1%	81	5
6	North Dakota	46.5%	16.8%	101	6
7	Illinois	39.0%	19.0%	100	5
8	Maryland	38.3%	31.7%	60	3
9	Wisconsin	35.9%	20.7%	92	5
10	Washington	35.1%	28.7%	94	5
11	Tennessee	34.0%	25.0%	100	5
12	Montana	31.7%	25.6%	82	5
13	Florida	28.8%	22.5%	80	4
14	Nebraska	28.6%	16.7%	42	3
15	Indiana	27.5%	20.0%	120	6
16	Maine	27.0%	32.0%	100	5
17	New York	24.5%	46.9%	49	3
18	South Dakota	24.0%	26.0%	100	5
19	Kentucky	21.7%	53.3%	60	3
20	Hawaii	20.8%	35.6%	101	6
21	Alabama	18.8%	42.5%	80	4
22	West Virginia	17.2%	29.7%	64	4
23	Missouri	17.1%	26.8%	41	3
24	North Carolina	16.7%	35.7%	42	3
25	Pennsylvania	15.0%	22.0%	100	5
26	Wyoming	12.0%	48.0%	25	3
27	Connecticut	11.9%	33.1%	118	6
28	Vermont	11.8%	23.7%	93	6
29	Ohio	11.8%	26.3%	76	5
30	Georgia	11.1%	37.8%	45	4
31	Virginia	10.0%	22.5%	40	2
32	Oklahoma	9.1%	52.7%	110	6
33	Delaware	7.6%	37.0%	92	5
34	Nevada	7.5%	25.0%	40	2
35	New Mexico	7.1%	69.0%	42	3
36	Alaska	5.0%	50.0%	40	2
37	Mississippi	4.7%	40.7%	86	5
38	Arkansas	3.2%	54.8%	62	5
39	New Jersey	2.5%	41.2%	80	4
40	South Carolina	0.0%	35.0%	40	2

Not ranked. No state government site could be tested in Louisiana, Massachusetts, Michigan, New Hampshire, Oregon, Utah. Too few files to rank: Arizona, Idaho, Kansas, Rhode Island. Washington, DC is counted with the cities.

California’s lead is hard to miss. Its transportation, revenue and labor agencies passed on every file tested, and only 1 of its 91 sampled state files was untagged.

Why so many fail: the export, not the author

87.1% of PDFs exported from Microsoft Word or Office are tagged, yet only 28.4% pass, usually because the export skips the document title setting or the language. Files from Adobe Acrobat or Distiller workflows are tagged only 35.1% of the time. Scanned pages (4.2% of files) are the hardest case: 201 files are pictures of text, including meeting minutes, letters, signed documents and a Title VI complaint form.

The most common failures are settings, not rewrites: export with tags, set the document language, set a title and turn on “show document title”, and add alt text to images.

The coverage gap

Read this before the ranking.

What is missing

130 of the 455 sites listed could not be tested: 102 refused automated access, 27 could not be reached and 1 stalled and was stopped. A further 53 had no PDF a polite crawler could find.

The test ran from a server outside the US, and several states appear to block non-US networks. Refusals were respected, not worked around: no US proxy, no browser automation. Sites with heavy bot protection may differ from the rest.

No state government site at all could be tested in Louisiana, Massachusetts, Michigan, New Hampshire, Oregon, Utah.

Type	Listed	Tested	Refused	Unreachable	No PDFs
Public universities	50	44	0	0	6
State agencies	250	154	59	14	23
State portals	50	21	11	6	12
Counties	30	21	4	3	2
Cities	75	32	28	4	11

Every site’s outcome, with the reason, is in entities.csv.

Method

Who: 455 public entities: each state’s portal; five agencies per state with the same functions everywhere; about the 75 largest cities; 30 of the largest counties; and each state’s flagship public university (four replaced by another large public university in the same state because the flagship’s site refused automated access). A purposive list, not a random sample.
How: a crawler read each site’s robots.txt and obeyed it, made at most one request every 2 to 3 seconds per site, and never logged in or filled a form. It read sitemaps and up to 35 pages per site and downloaded up to 20 PDFs per state site and 30 per city, county or university, spread across document types and favouring recent files.
Checks: the PDF catalog and structure tree were read directly (pikepdf, pypdf, pdfium), and every file was validated with veraPDF 1.30.3 against PDF/UA-1. A random 40 files were re-checked with separate code: 40 of 40 agreed on tags, language and text.
When: 24 October 2026, 19:26 to 20:25 UTC, from first request to last check.

The method and checks are the same as in FileSeen’s EU bank PDF accessibility study, so the two can be compared: EU bank PDFs passed the same five checks 24.5% of the time.

Limitations

Automated checks show the minimum. No tool can tell whether alt text is meaningful, whether reading order is right or whether a table makes sense read aloud. Real pass rates are lower than these.
Coverage. 130 sites were blocked, unreachable or stopped, and 53 more had no findable PDF (see the coverage gap above).
A sample, not an inventory. Up to 20 or 30 files per site, chosen by keyword and recency.
Dates and types are estimates. Dates come from each PDF’s own metadata; “form” is a guess from the file name and link text.
Not a legal finding. The deadline has not arrived, exceptions apply file by file, and this test does not say that any government breaks the law.

Download the dataset

Free to reuse under the Creative Commons Attribution 4.0 licence. Credit FileSeen.

pdfs.csvOne row per PDF (4,779 rows): entity, state, source URL, document type, fetch time and every check result, including veraPDF. 4.5 MB
entities.csvOne row per site (455 rows), including sites that could not be tested and why. 112 KB
summary.jsonEvery aggregate in this post, with definitions. 153 KB

Licence: CC BY 4.0. Suggested credit: FileSeen, “US government PDFs and the ADA Title II deadline”, 24 October 2026, https://fileseen.com/blog/government-pdfs-ada-6-months-left/. The PDFs themselves are not redistributed: each row links to the original URL. Data last checked 24 October 2026.

EU Digital Identity Wallet by 24 December 2026: what changes for signing PDFs

FileSeen Desk — Sat, 24 Oct 2026 19:46:00 +0000

Every EU member state must offer at least one European Digital Identity Wallet, and every wallet must let people sign with a qualified electronic signature, free of charge. Here is what the regulation itself says, the dates that follow from it, and what FileSeen found when it edited a signed PDF.

61 days to 24 December 2026, the date FileSeen counts from the regulation for the first wallets (61 days as of 24 October 2026).

Where 24 December 2026 comes from

Article 5a(1) of Regulation (EU) 2024/1183 says each Member State “shall provide at least one European Digital Identity Wallet within 24 months of the date of entry into force of the implementing acts referred to in paragraph 23 of this Article and in Article 5c(6).”

Those implementing acts are five Commission Implementing Regulations of 28 November 2024 (2024/2977, 2024/2979, 2024/2980, 2024/2981 and 2024/2982). Each was published in the Official Journal on 4 December 2024 and enters into force “on the twentieth day following that of its publication”: 24 December 2024. Twenty-four months later is 24 December 2026.

The regulation states the rule, not the calendar date. The date here is FileSeen’s count from the texts on EUR-Lex, for example Implementing Regulation (EU) 2024/2981 on wallet certification.

The two deadlines that follow from Articles 5a(1) and 5f(2).

What changes for signing PDFs and contracts

A free qualified signature for every person. Each wallet must “offer all natural persons the ability to sign by means of qualified electronic signatures by default and free of charge” (Article 5a(5)(g)).
Free for private use, perhaps not for work. Member States “may provide for proportionate measures to ensure that the use of qualified electronic signatures free-of-charge by natural persons is limited to non-professional purposes” (same article).
Same weight as ink. “A qualified electronic signature shall have the equivalent legal effect of a handwritten signature” (Article 25(2) of Regulation (EU) No 910/2014, unchanged).
The wallet itself is free. “The issuance, use and revocation of the European Digital Identity Wallets shall be free of charge to all natural persons” (Article 5a(13)).
Nobody has to use it. “The use of European Digital Identity Wallets shall be voluntary”, and services must stay open to people who do not use one (Article 5a(15)).

Who must accept the wallet, and when

Who	Rule	When
Public sector online services	Where they require electronic identification, they “shall also accept” the wallet (Article 5f(1))	Once wallets are provided
Private services legally or contractually required to use strong authentication (banking, transport, energy, health, telecoms and more)	Must accept the wallet on the user’s voluntary request. Micro and small enterprises are excepted (Article 5f(2))	“No later than 36 months” from the implementing acts: 24 December 2027
Very large online platforms	Must accept and facilitate the wallet for log-in on the user’s voluntary request (Article 5f(3))	No separate date in the article

FileSeen’s test: what editing does to a signed PDF

A free signature only helps if it survives. FileSeen signed a test PDF with a test certificate, ran it through its own free tools, and validated each result with pyHanko, an open-source signature validator.

Signed test files before and after each tool. Tested 24 October 2026.

The compressor declined the small signed agreement because it would not get smaller. On a signed 10.7 MB photo report it did shrink the file, and the smaller copy had no signature left. The integrity check is the same for any PDF signature, qualified or not: if the signed file changes afterwards, the signature fails. So add passwords, watermarks and redactions first, and sign last.

What to do now

Watch your own government’s announcement. The regulation sets the deadline; each country chooses how and by whom its wallet is provided (Article 5a(2)).
Finish a contract before signing it. Edits, watermarks, passwords and redactions come first; a change after signing invalidates the signature.
Keep the signed original as it is. Send that exact file. Do not run it through any tool afterwards.
Check whether your use counts as professional. Free signing may be limited to non-professional use where you live.
If your firm must use strong customer authentication, plan to accept the wallet by 24 December 2027.

Acrobat Pro price: US$19.99 a month, and 10 PDF jobs that cost nothing

FileSeen Desk — Sat, 24 Oct 2026 19:46:00 +0000

Adobe’s own plans page, checked on 24 October 2026, lists Acrobat Pro at US$19.99 a month on an annual plan, Standard at US$14.99 and Studio at US$24.99. Many everyday PDF jobs need none of them. FileSeen ran 10 of them through free browser tools and checked every output.

What Acrobat costs, from Adobe’s own page

Prices shown to a US visitor on Adobe’s plans page on 24 October 2026, for the “Annual, billed monthly” option.

Plan	Price	What Adobe says it is
Acrobat Reader	Free	“Open and view PDFs with Acrobat Reader. Free. Always.”
Acrobat Standard	US$14.99/mo	“Essential PDF tools”
Acrobat Pro	US$19.99/mo	“Advanced PDF toolset”, including redaction, web forms and turning scans into editable PDFs
Acrobat Studio	US$24.99/mo	“Includes everything in Acrobat Pro, plus AI Assistant.”
Acrobat Express	US$9.99/mo	Listed on Adobe’s AI Assistant page: AI summaries, PDF Spaces and content creation

Each paid plan carries the same line on Adobe’s page: “Fee applies up to half your remaining annual commitment if you cancel after 14 days.” Sources: Adobe Acrobat plans and pricing and Acrobat AI Assistant, both checked 24 October 2026.

Left out: claims Adobe’s pages do not show

Some reports mention a 15% first-year discount on Acrobat Studio for existing Standard and Pro customers, ending 31 October 2026, and separate AI Assistant prices. Neither appeared on Adobe’s plans page or AI Assistant page on 24 October 2026, so neither is used here.

10 PDF jobs, tested on free tools

Each job was run on FileSeen’s free tools in a Chromium browser on 24 October 2026, and every output was opened and checked with separate software.

Lock a PDF with a password

A PDF reader refused to open the result without the password. With it, the file opened: AES encryption, all 3 pages.

Password-protect PDF

Put your own watermark on every page

“COPY FOR MARIA KELLER” appeared on all 3 pages, and the original text was still selectable.

Watermark PDF

Mark a file as DRAFT

One click on the DRAFT preset filled in the text; DRAFT was stamped on every page.

Watermark PDF, DRAFT preset

Black out emails, phone numbers and IBANs

The tool found the email address, phone number and IBAN on each page. After redaction none of them was left in the text layer.

Redact PDF

Black out names and case numbers you type

“Maria Keller” and “CASE-55821”, typed into the word box, were found on every page and removed.

Redact PDF

Redact a scanned page

On a scan with no text layer, the tool flagged the page, read it on the device, and found the email address and phone number.

Redact PDF, read scanned text

Keep a record of what was removed

The downloaded report listed each redaction with masked values only: no full email address or name in it.

Redact PDF, redaction report

Shrink a PDF under an upload limit

A 10.7 MB photo report came out at 1.3 MB with the “Under 2 MB” target, still 4 pages.

Compress PDF

Turn photos into one PDF

Three receipt photos became one 3-page PDF.

Photos to PDF

Send several PDFs in one locked zip

Two PDFs went into one AES-256 zip. 7-Zip refused the wrong password and opened it with the right one.

Password-protect ZIP

In every run, the browser’s network log showed no request carrying the file. The work happened on the device: nothing was uploaded, and no account was needed.

Job 8 as it ran: 10.7 MB to 1.3 MB against a 2 MB target.

Where the free tools change your file

Three of the tools work by redrawing pages. That matters for some documents.

Compress PDF turns every page into an image. The test output had no text layer at all, as the tool itself warns. Do not use it on a file that has to work with a screen reader or be searchable.
Redact PDF turns redacted pages into images. With “Keep the other text selectable” on (the default), the words that touch no box are written back as invisible text, so the rest of the page stays searchable. Pages without redactions stay as they were.
Password and watermark tools rewrite the file. A PDF that already carries a digital signature shows that signature as invalid afterwards. FileSeen tested this; see the signing post.

Job 6: a scanned letter after redaction. The email and phone number were found by reading the scan on the device.

What still needs a full PDF editor

The free tools above do not edit the text inside a PDF, build fillable web forms, collect e-signatures or turn a scan into editable text. Adobe lists those among Acrobat Pro’s tools. If a job needs one of them, a paid editor is the honest answer.

For locking, marking, redacting, shrinking, combining and zipping, the 10 runs above show the free route works, with the trade-offs listed.

How this was checked

Prices: Adobe’s plans page and AI Assistant page, loaded from a US connection on 24 October 2026, with the page text and a screenshot kept.
Test files: a 3-page agreement with a made-up name, email, phone number, IBAN and case number; a scanned letter with no text layer; a 10.7 MB photo report; three photos.
Checks on each output: pdfinfo (password, pages), pdftotext (what text remains), pdfimages (pages turned into images), page renders (watermarks) and 7-Zip (zip encryption).