ADA/WCAG Accessibility Requirements Are Coming for Audit Reports Uploaded to the Tennessee Comptroller’s Website

June 1, 2026
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Garrett Williams | CPA

Tennessee local governments, boards of education, utility districts, nonprofit organizations, and CPA firms that submit audit reports to the Tennessee Comptroller’s Office should begin preparing now for a significant change in how publicly released audit reports are prepared and submitted.

Based on the Comptroller’s notice, audit reports submitted to the Comptroller’s Office on or after April 26, 2027 must comply with updated accessibility requirements under the Americans with Disabilities Act and the Web Content Accessibility Guidelines, commonly referred to as WCAG 2.1.

This change affects more than the visual appearance of audit reports. Itaffects how audit reports are exported, structured, reviewed, and submitted inelectronic format.

Key Takeaways

The April 26, 2027, deadline gives Tennessee governmentsand CPA firms time to prepare, but the change should not be treated as alast-minute PDF conversion issue.

Audit reports submitted to the Tennessee Comptroller’s Office will need to be accessible because they are publicly posted online. This means reports should be prepared with accessibility in mind from the beginning, including proper document structure, tagged PDFs, accessible tables, searchable text, logical reading order, and usable navigation.

The transition period before the deadline should be used to test current report preparation processes, correct template issues, train staff, and ensure that audit reports can be submitted in an ADA- and WCAG-compliant format.

Background: Why This Change Is Happening

In April 2024, the U.S. Department of Justice issued a final rule under Title II of the Americans with Disabilities Act. The rule requires public entities to make web content and mobile applications accessible to individuals with disabilities. The DOJ rule incorporates the Level AA success criteria and conformance requirements of WCAG 2.1.

Because audit reports submitted to the Comptroller are publicly posted publicly on the Comptroller’s website, reports submitted on or after that date must be accessible.

In practical terms, this means that audit reports can no longer betreated only as printed documents converted to PDF. They must also function asaccessible digital documents.

Who Is Responsible?

The Comptroller’s notice states that local governments and otherorganizations are ultimately responsible for ensuring compliance withapplicable accessibility requirements for reports submitted to theComptroller’s Office.

However, the notice also encourages those entities to work with theircontracted CPA firms. In practice, this responsibility will likely requirecoordination between:

  • The local government or organization
  • The CPA firm preparing or issuing the audit report
  • Anyone involved in formatting the report
  • Anyone converting the report to PDF
  • Anyone responsible for final report submission

Although the government or organization is ultimately responsible, CPA firms will likely play a major role because they often prepare, assemble, or finalize the audit report PDF.

Effective Date for Reports Submitted to the Comptroller

Any audit report submitted to the Comptroller’s Office on or after April26, 2027 must comply with the updated ADA and WCAG accessibility requirements.

This date is based on submission date, not necessarily fiscal year-end. For example, a June 30, 2026 audit report submitted before April 26, 2027, may fall before the mandatory compliance date, while a report submitted on or after April 26, 2027 would need to comply.

That distinction is important for governments and auditors withlate-issued reports.

What Will Change in Audit Report Preparation?

The biggest practical change is that audit reports will need to be prepared as accessible documents, not merely converted to PDF at the end of the process.

An accessible audit report generally needs features such as:

  • A properly tagged PDF structure
  • Searchable text, not scanned, image-only pages
  • Logical reading order
  • Proper headings    
  • Bookmarks or navigation structure
  • Alternative text for meaningful images, charts, and graphics
  • Tables that can be read correctly by assistive technology
  • Sufficient color contrast
  • Descriptive hyperlinks
  • Proper document title and metadata
  • Accessible page numbering and footers where applicable

For audit reports, the most significant areas will likely be thefinancial statements, notes to the financial statements, combining schedules,statistical schedules, tables, and scanned supplemental materials.

What Is a Tagged PDF?

A tagged PDF is a PDF that contains behind-the-scenes structuralinformation that tells assistive technology how to read the document.

For example, a tagged PDF identifies:

  • Headings
  • Paragraphs
  • Tables
  • Lists
  • Footnotes
  • Figures
  • Reading order
  • Document sections

This matters because a PDF may look correct visually but still beinaccessible to a person using a screen reader. Without tags, a screen readermay read content out of order, skip information, or misinterpret tables.

For audit reports, this is especially important because the reports often contain complex tables, financial statements, note disclosures, combining schedules, and supplementary schedules.

Why Audit Reports May Be Difficult to Make Accessible

Government audit reports are not simple documents. They often include:

  • Independent auditor’s reports
  • Management’s discussion and analysis
  • Government-wide financial statements
  • Fund financial statements
  • Notes to financial statements
  • Required supplementary information
  • Combining and individual fund schedules
  • Schedule of expenditures of federal awards
  • Findings and questioned costs
  • Corrective action plans
  • Statistical sections in some reports

Many of these sections contain wide tables, merged cells, multi-columnformats, footnotes, and repeated headers. Those features can createaccessibility issues if the report is not prepared carefully.

A report that looks professional in PDF may still fail accessibility checks if the underlying structure is not correct.

Early Review Period Before the Deadline

The Comptroller’s notice states that reports submitted before the compliance deadline may be reviewed for accessibility compliance. If issues are identified, the Comptroller’s Office may notify the submitting entity so corrective action can be taken on future reports.

The notice also states that, until the compliance deadline, reports will not be rejected for ADA noncompliance and will continue to be posted to the Comptroller’s website.

This creates an important transition period. Governments and CPA firms should use the time before April 26, 2027 to test their process, identify problems, and correct formatting issues before compliance becomes mandatory.

Practical Impact on Tennessee Local Governments

For Tennessee local governments, the change means audit report accessibility should become part of the audit planning and report preparation process.

Local governments may need to:

  • Discuss accessibility expectations with their CPA firm
  • Determine who is responsible for producing the accessible PDF
  • Review whether current report templates are accessible
  • Avoid submitting scanned image-only reports
  • Confirm whether financial statement tables are properly tagged
  • Plan extra time for accessibility review before submission
  • Update internal policies or engagement expectations as needed

This may be especially important for smaller governments that relyheavily on their auditors to assemble the report.

Practical Impact on CPA Firms

For CPA firms, this change may affect report production workflows.

Firms may need to evaluate:

  • Whether their Word, Excel, and PDF templates are accessible
  • Whether staff know how to export tagged PDFs
  • Whether the final PDF passes accessibility checks
  • Whether scanned pages are being inserted into reports
  • Whether tables are properly structured properly
  • Whether third-party PDF software is needed
  • Whether accessibility review should be added to the report issuance checklist

This may also affect timing. Accessibility remediation can take additional time, especially for reports with numerous many tables or schedules.

Financial Statement Tables Will Need Special Attention

Tables are likely to be one of the most challenging parts of compliance.

Audit reports often contain complex tables with:

  • Multiple header rows
  • Indented line items
  • Comparative columns
  • Prior-year data    
  • Combining fund columns
  • Totals and subtotals
  • Footnotes
  • Negative amounts
  • Blank rows for formatting

For accessibility purposes, tables should be built in a way that allows a screen reader to understand the relationship between row labels, column headers, and data. Tables should not be created using spaces, tabs, text boxes, or manual formatting that only works visually.

This may require changes to how financial statements and supplementary schedules are prepared.

Scanned Pages May Create Problems

Scanned pages can create accessibility issues unless they are properlyprocessed and tagged.

For example, a scanned signature page, management representation attachment, corrective action plan, or other supplemental document may appear readable to a sighted user but may not be readable by assistive technology.

Where scanned documents must be included, they may need optical characterrecognition (OCR) and accessibility tagging. However, OCR alone is not alwaysenough. The document still needs proper structure and reading order.

This Is Not Just a Website Issue

A common misunderstanding is that the ADA web accessibility rule onlyaffects the Comptroller’s website. The notice makes clear that the impactextends to audit reports submitted to the Comptroller because those reports aremade publicly available on the Comptroller’s website.

That means the accessibility of the report PDF itself matters.

In other words, uploading the report to an accessible website does not automatically make the report accessible. The document being posted also needs to meet applicable accessibility requirements.

Recommended Steps Before April 26, 2027

Governments and CPA firms should begin preparing now. A practical implementation plan could include the following:

  1. Review current audit report templates
        Identify whether the Word, Excel, or PDF templates currently used to prepare audit reports support accessible formatting.
  2. Export test reports as tagged PDFs
        Test whether reports can be exported to tagged PDF format without losing structure.
  3. Run accessibility checks
        Use PDF accessibility tools to identify issues such as missing tags, incorrect reading order, missing document title, inaccessible tables, and missing alternative text.
  4. Review complex tables
        Pay special attention to government-wide statements, fund statements, notes, combining schedules, and SEFA schedules.
  5. Avoid image-only report sections
        Minimize scanned pages where possible and ensure any scanned content is made accessible.
  6. Update report issuance checklists
        Add accessibility review as a required step before report submission.
  7. Coordinate early with the     Comptroller’s Office if issues are identified
        Since the Comptroller has indicated it may provide feedback before the deadline, governments and auditors should use that feedback to improve future submissions.

References Listed in the Comptroller Notice

The notice identifies the following resources:

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