For city, county and school-district web teams: WCAG 2.1 AA applies from April 26, 2027 (population 50,000+) or April 26, 2028. Type your page counts and see which documents the 35.201 exceptions take off the bill — in the example, $460,246.67 of a $478,062.67 fix-everything budget.
Who: cities, counties, school districts and special districts under ADA Title II. WCAG 2.1 AA applies to your web content from April 26, 2027 if your population is 50,000 or more, from April 26, 2028 if smaller or a special district (28 CFR 35.200).
At stake: a scanner flags every failing PDF. The rule exempts archived content, older documents nobody uses for a service and individual documents behind a login (28 CFR 35.201). Example: 1,200 of 32,200 pages must be fixed — $17,816.00 instead of $478,062.67. Miss the forms people still use and they fail the rule on day one.
Check here: type your population and the page counts from your media library.
| WCAG 2.1 AA required from April 26 of | 2027 |
| Pages you must fix before that date (35.201(b) does not exempt them) | 1,200 |
| Pages exempt under 35.201(a), (b) and (d) | 31,000 |
| Pages in your document inventory | 32,200 |
| Share of your inventory the rule does not require you to fix | 96.27% |
| Hours to fix the pages you must fix | 400 |
| Cost to fix the pages you must fix | $17,816.00 |
| Cost if you fix every page in the inventory | $478,062.67 |
| Budget the exceptions take off the bill | $460,246.67 |
| Weeks of one full-time person (40 h) before the date | 10 |
| Hours per year to post new documents accessibly from that date | 1,000 |
| Cost per year for new documents from that date | $44,540.00 |
Full version — $21 once: the .xlsx with these 12 live formulas plus a dated Document Register that marks each PDF Must fix or Exempt under 28 CFR 35.201 (a) to (e). Get the .xlsx →
Everything updates as you type. Nothing is uploaded. This runs in your browser.
Sources: 28 CFR 35.200 (dates April 26, 2027 / April 26, 2028), 35.201 (exceptions a–e), 35.104 (definitions of archived web content, conventional electronic documents, special district government, total population), read on Cornell LII on October 1, 2026 · BLS OEWS 2025, web developers (SOC 15-1254), median $44.54 an hour. The exceptions lift the WCAG 2.1 AA rule only; other Title II duties such as effective communication on request (28 CFR 35.160) still apply. A scoping tool, not legal advice.
The .xlsx workbook ($21 once): a dated Document Register where you list each document (title, URL, pages) and answer the 5 tests of 28 CFR 35.201 (a) to (e); a formula marks every row Must fix or Exempt with the paragraph and totals the pages per status for the Your inventory tab 2014 a scope record
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BLS OEWS 2025: web developers (SOC 15-1254) earn a median $44.54 an hour — the person who remediates the PDFs. DOJ's Fitzpatrick Matrix rates attorney time for billing year 2026 at $578 to $998 an hour.
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Real numbers from this tool, line by line.

$460,246.67 of this city's PDF budget is exempt under ADA Title II — US city and county web teams, 62,000 people, WCAG 2.1 AA from April 26, 2027. The finished result for its 32,200 pages online:
A scanner tells you every PDF on your site fails. The ADA Title II rule does not ask you to fix all of them.
Who this is for. You run the website for a city, a county, an independent school district or a special district. The Department of Justice's ADA Title II web rule, 28 CFR 35.200, says your web content and mobile apps must meet WCAG 2.1 Level A and AA. The dates are later than many summaries still say: April 26, 2027 for a public entity with a total population of 50,000 or more, and April 26, 2028 for a smaller one or for any special district government.
What the rule leaves out. Section 35.201 lists five exceptions. (a) Archived web content: made before your date, kept only for reference, research or recordkeeping, never changed after archiving, and stored in an area clearly marked as the archive. (b) Preexisting conventional electronic documents, meaning PDFs, word processor files, presentations and spreadsheets posted before your date, unless people still use them to apply for, get access to or take part in a service, program or activity. (c) Content posted by a third party that is not working for you under a contract or licence. (d) Documents about one person, their property or their account that sit behind a password or are otherwise secured. (e) Social media posts published before your date.
What that does to the budget. Take an example city of 62,000 people with 32,200 pages of documents online. 1,200 pages are forms, applications and permit packets residents still use. 18,000 pages are older reports nobody uses for a service, 9,000 pages sit in a proper archive, and 4,000 pages are tax bills behind a login. At 20 minutes a page and $44.54 an hour, the BLS OEWS 2025 median for web developers, fixing everything costs $478,062.67. The rule requires the 1,200 service pages: 400 hours, $17,816.00, about 10 weeks of one full-time person. The exceptions take $460,246.67 off the bill.
Where people get it wrong. The opposite mistake costs more. A form posted years ago is not exempt if residents still fill it in, so it must meet WCAG 2.1 AA on your date. And from that date every new agenda, minutes file or notice you post has to be accessible too. With 3,000 new pages a year, that is $44,540.00 a year at the same rate.
When the date moves. Change the population to 18,000 and the same inventory gets April 26, 2028; the pages and the cost stay the same, you get one more year. A special district always gets 2028, whatever its size.
What the exceptions do not do. They lift the WCAG 2.1 AA requirement only. Other Title II duties still apply, such as effective communication when a resident asks for a document in a form they can use (28 CFR 35.160).
Check your own inventory. The free calculator on our page takes 8 entries, your population and the page counts from your media library, and returns 12 results, among them your date, the pages you must fix, the pages exempt, hours, cost and the yearly cost of new documents. Nothing is uploaded. The paid workbook adds a Document Register: one row per document with the five 35.201 tests and a Status column that names the paragraph, so you can hand council a dated scope record.
It applies the DOJ's ADA Title II web rule to your document inventory. From your population it gives your WCAG 2.1 AA date (April 26, 2027 or April 26, 2028, 28 CFR 35.200). From your page counts it applies the 28 CFR 35.201 exceptions and returns 12 results: pages you must fix, pages exempt, hours, cost and the yearly cost of new documents.
Web managers, clerks, IT and ADA coordinators at cities, counties, independent school districts and special districts covered by ADA Title II. If your site holds thousands of old PDFs and someone asked you to budget the remediation before April 26, 2027 (population 50,000 or more) or April 26, 2028 (smaller or special district), this is the first number you need.
A free scanner tells you which pages fail WCAG. It does not tell you which of them the rule requires you to fix. 28 CFR 35.201 exempts archived web content, preexisting documents not used to apply for or access a service, third-party posts and individual documents behind a login. Scanning every PDF and fixing every failure prices work the rule never asked for.
Free in the browser: the whole check, 8 inputs and 12 results, as often as you like, no account. The paid .xlsx ($21 once) adds a dated Document Register: one row per document with its URL, pages and the 35.201 tests, a formula that marks each row Must fix or Exempt with the paragraph, page totals per status, and the same 12 live formulas to hand to council or finance.
With the example inventory, 1,200 pages that must be fixed take 400 hours: $17,816.00 at the BLS OEWS 2025 web developer median of $44.54 an hour. Fixing all 32,200 pages would cost $478,062.67. A lawyer's hour on the D.C. Fitzpatrick Matrix for 2026 runs $578 to $998; the workbook is $21 once, not a subscription.
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