Accessibility has been part of New York’s digital standards for a long time, but many state agencies, schools, and other groups that share information with the public are taking a closer look at how those expectations apply to them.
Recent federal rules, along with updates from the State of New York, have brought more attention to digital accessibility, especially when it comes to documents published online. For many organizations in New York, these requirements are not entirely new. What has changed is the level of clarity, along with updated standards and timelines approaching over the next few years.
For the first time, state and federal requirements are closely aligned. New York has adopted WCAG standards as the basis for digital accessibility, while the ADA Title II web rule clarifies when public-facing digital content needs to be accessible. Together, these changes set clearer expectations for what is considered accessible and provide a realistic window to prepare.
In this article, we’ll walk through what New York expects when it comes to digital accessibility, how upcoming timelines affect documents and online content, and how to prepare ahead of time before these requirements take place.
How New York Defines Accessible Digital Content
When New York talks about digital accessibility, it applies to the information people interact with, download, and rely on, regardless of whether it appears as a web page, a form, or a document.
From the state’s perspective, digital content includes anything delivered through a website or online portal. That means PDFs, downloadable forms, guidance documents, reports, notices, applications, and similar materials are treated as part of the digital experience, not as separate or optional content.
This has actually been reflected in New York’s accessibility policies for years. State guidance consistently frames accessibility as a responsibility that extends to web-based information as a whole. If a document is published online and intended for public use, it falls under the same accessibility expectations as the website hosting it.
This is why accessibility reviews in New York go farther than website navigation and page templates. Documents that users are expected to download need to support screen readers, follow a logical reading order, and allow users to understand and interact with the content in a meaningful way. A PDF that looks fine visually but lacks proper structure or tagging can still create barriers.
For many teams, this is where accessibility efforts tend to stall. A website may be WCAG compliant, while the documents attached to it fall short. New York makes it clear that accessibility extends through the entire experience, including the files people open, fill out, and reference every day.
The Role of NYS-P08-005
New York’s approach to accessibility starts with a statewide policy known as NYS-P08-005, which has guided how digital information is created and shared across state agencies for many years.
NYS-P08-005 sets accessibility expectations for web-based information and applications used by the state. This applies not only to the technologies built into a website, but also to the information delivered through it, including PDF documents posted online.
When documents are shared to provide information, collect input, or support public services, they are treated as part of the state’s digital presence. Forms, guidance documents, reports, and notices are expected to meet the same accessibility expectations as the pages that host them.
Because of this, accessibility reviews in New York often extend into document libraries rather than stopping at website templates. Recent guidance has reinforced this approach, with greater emphasis on verifying that documents function properly for people using assistive technology.
What Changed in 2023
In 2023, New York updated its State Technology Law to strengthen and modernize its approach to digital accessibility. The update did not replace existing policies, but it clarified expectations by tying them directly to current Web Content Accessibility Guidelines, or WCAG.
Rather than locking requirements to a single version, the law allows accessibility standards to move forward as WCAG evolves. In practice, this has led many New York agencies to align with WCAG 2.2 AA, reflecting newer guidance around focus visibility, form behavior, and how users navigate content with assistive technologies.
For documents, this shift has real implications. PDF accessibility depends on structure, reading order, and tagging, areas that are harder to validate through basic checks alone. Documents that look acceptable visually may still fall short when tested with screen readers or keyboard navigation.
Overall, the 2023 update reinforces work already underway across the state while bringing it in line with current standards. For many teams, the focus has shifted from identifying requirements to figuring out how to apply them consistently across a growing volume of digital content.
How Federal ADA Title II Timelines Affect New York
In April 2024, the U.S. Department of Justice finalized its ADA Title II rule, which sets expectations for when state and local governments must meet accessibility standards for digital content.
For New York, this rule closely aligns with recent state updates. The ADA Title II rule references WCAG 2.1 AA, fitting within the state’s shift toward current WCAG standards following the 2023 law change.
The main impact of the federal rule is timing. Larger agencies and jurisdictions serving populations of 50,000 or more are expected to meet these requirements by 2026, while smaller municipalities, districts, and similar entities have until 2027.
Together, state and federal guidance give New York agencies a clearer framework for planning accessibility efforts over the next few years, allowing teams to move forward deliberately rather than responding to last-minute pressure.
How to Prioritize Accessibility Efforts in New York
For many New York businesses, agencies, and institutions, the biggest challenge with accessibility isn’t understanding the requirements, it’s figuring out where to start. Years of accumulated documents can make the task feel larger than it actually is.
A helpful first step is to focus on content that is still in active use. Documents that support current services, applications, public guidance, and ongoing communication tend to carry the highest priority. These are the materials people are expected to read, complete, or rely on today, and they are typically the first place accessibility efforts should be directed.
Older materials that are no longer part of active processes often fall into a different category. Records kept for reference, historical purposes, or internal archiving may not require the same level of immediate attention, especially when they are clearly labeled and not used as part of current services. Making this distinction allows teams to move forward without feeling pressured to address everything at once.
Prioritization also helps set a sustainable pace. By identifying which documents matter most and addressing them in stages, organizations can make steady progress while keeping accessibility work manageable. This approach aligns with how New York’s guidance is typically applied, emphasizing meaningful access to current information rather than exhaustive remediation of every file that has ever been published.
Once priorities are clear, the next step is figuring out how to prepare for accessibility in a way that fits existing processes and avoids unnecessary complexity.
Prepare for Accessibility Without Overcomplicating the Process
Preparing for accessibility does not require overhauling everything at once. For many New York businesses and institutions, progress starts with creating a clear, repeatable approach to how digital content is handled going forward.
The first step is setting consistent standards for new documents. When accessibility is considered at the point of creation or publication, it reduces the need for rework later and keeps content from drifting out of alignment over time. This is especially helpful for documents that are actively being used, such as forms, notices, and guidance materials.
For groups that still rely heavily on paper records, digitization often plays a role in long-term accessibility planning. Converting paper documents into digital files makes it easier to apply accessibility standards consistently and manage content as requirements evolve. When digitization and accessibility are considered together, it simplifies ongoing maintenance.
Accessibility preparation also benefits from thinking in terms of process rather than one-time projects. Establishing clear responsibilities, simple review steps, and an understanding of which documents need attention helps teams keep pace as new content is added.
With a thoughtful plan in place, accessibility work becomes part of normal publishing practices rather than a last-minute response to deadlines. For New York businesses and institutions, this kind of preparation makes it easier to meet expectations steadily and with confidence.
Getting Ahead of New York’s Accessibility Requirements With SecureScan
Preparing for New York’s accessibility requirements is easier when documents are handled with accessibility in mind from the start. For many businesses and institutions, that begins with having records in a digital format that can support current standards and future updates.
SecureScan has more than 22 years of experience helping our clients scan and manage their documents in a way that supports long-term accessibility. Paper records can be converted into text-searchable digital files, creating a solid foundation for meeting WCAG requirements as expectations continue to evolve.
For existing digital documents, SecureScan also provides PDF remediation software that help teams bring active files into alignment without adding unnecessary complexity. This makes accessibility work muc more manageable, even when volumes are high.
If you’re looking to get ahead of upcoming accessibility timelines or want guidance on where to start, SecureScan’s team can help you plan next steps with confidence. Contact us to speak with one of our technicians or request a free quote.