# PDFs under 35.201 — inventory vs OCR everything

Federal Title II does not ask cities to OCR every old PDF on the server on day one. The rule focuses on public-facing web content — pages and documents people use now. Start with an inventory of in-scope PDFs, ticket what residents still need, and fix the source file when you can.

## Who this is for

Website vendors, communications staff, and clerks who searched **ADA PDF accessibility** and got pitched **remediate every PDF by 2026** — or a bulk OCR quote — without a **city inventory**.

## What vendors often sell

Search results mix **document shops**, **PDF platforms**, and **overlay-style “accessible viewers.”** Common pitches:

- OCR the whole drive before the deadline.
- Drop in a JavaScript layer so the PDF “counts” as accessible.
- Sell remediation per page with no tie to **what residents still download**.

Title II for **public entities** is narrower: **know what is on the public site**, fix what people **still use**, and do not pretend a wrapper replaces the file on the shelf.

## What 35.201 actually asks

On the [PDFs](/pdfs) citation page we keep the clerk version short. For implementers, the split is:

1. **Inventory** archived and preexisting conventional electronic documents on the public site.
2. **Ticket or remediate** when a document is **still used** to apply, pay, participate, or when it is **newly posted** after the entity’s applicable date.
3. **Prefer the source** — Word, InDesign, HTML — over one-time OCR on a scan of a scan.

Read the regulation at [28 CFR 35.201](https://www.ecfr.gov/current/title-28/chapter-I/part-35/subpart-H/section-35.201) alongside [ADA.gov’s web rule materials](https://www.ada.gov/resources/2024-03-08-web-rule/).

## Practical order of work

1. Export a **list of PDF URLs** on the public hostname (not every share drive).
2. Mark **high traffic** — agendas, applications, tax forms, recreation signups.
3. **Fix or replace** those files in the CMS; do not only patch the link text.
4. Keep the **inventory** updated when clerks upload new packets.

Automated checks still miss part of WCAG — see [Method](/method). PDF tickets belong in the same **monthly file** as page tickets ([How it works](/how-it-works)).

## Push back on the clerk

- “We OCR’d the archive, so we are done.”
- “The PDF opens in our accessible viewer.” (Residents still need the download.)
- “Title II means every historical scan by April.” (Inventory first; prioritize in-use files.)

ActaPack looks at **public pages and public PDFs** each month and writes tickets — **$8,400/year**. We do not certify conformance.

## This month

List public PDFs on the site. Prioritize packets and forms people download this month. Send tickets to whoever owns the source files. We do not certify WCAG conformance on the archive.

## For implementers

28 CFR 35.201 separates inventory from remediation: archived and preexisting conventional electronic documents get listed; OCR or replace when they are still used to apply, pay, or participate, or when newly posted after the entity’s deadline. A client-side transcript layer is not the same as fixing the downloadable PDF.