00 — Legal Basis (`PRINT-LEGAL`)

Status: Normative reference. Requirement IDs are permanent (INVENTORY.md). Related: Issue #2852 · State-law layer in APPENDIX-state-law.md · Machine-readable rules in rules.json.

Framing: print IS regulated — just not by WCAG

There is a persistent myth that “accessibility law is about websites.” It is not. WCAG and Section 508 govern electronic content, but paper documents are squarely regulated in the United States through the effective-communication regime: ADA Title II (28 CFR Part 35), ADA Title III (28 CFR Part 36), Section 504 of the Rehabilitation Act (29 U.S.C. 794), and — for health programs — ACA Section 1557 (45 CFR Part 92). These regimes do not prescribe a point size for ordinary prose; they impose a functional duty: a covered entity must communicate with a person with a disability as effectively as it communicates with everyone else, and must furnish auxiliary aids and services (large print, Braille, accessible electronic formats, qualified readers) free of charge and in a timely manner. On top of that functional floor sit a small number of codified point-size mandates for specific document classes (Medicare Advantage / Part D materials, the Medicare ABN, FDA OTC Drug Facts) — the only places in federal law where a hard number has legal force. The state layer (insurance readability, contract conspicuousness, consent-form formatting) is jurisdiction-scoped and lives in the appendix.

This KB is an internal print-safe guardrail and reference for our conversion, remediation, forms, and audit pipelines — not a sellable certification product and not legal advice. Where the law gives a number, we cite it; where it gives only a functional duty, we say so and hold the line at SHOULD.

RFC 2119 discipline: MUST appears only where a requirement traces to a statute, regulation, or a standard we contractually claim. Everything downstream of a functional duty (e.g., “emit a request notice”) is SHOULD, because the law mandates the outcome, not our specific implementation of it.

PRINT-LEGAL-001 — ADA Title II auxiliary aids & effective-communication duty for hardcopy

Level: MUST Applies to: all documents Source: 28 CFR 35.160 (general effective-communication duty; primary consideration for the requested aid); 28 CFR 35.160(b)(2) Source strength: regulation Machine-checkable: no Validation: Human/process control. A pipeline can assist by ensuring an alternate-format request path exists on the output (see PRINT-FORM-022 / PRINT-ALT-009), but the underlying duty is discharged by the covered entity’s program, not by a file check.

A public entity subject to ADA Title II MUST take appropriate steps to ensure that communications with individuals with disabilities are as effective as communications with others, MUST furnish appropriate auxiliary aids and services (which include large print, Braille, accessible electronic formats, and qualified readers) where necessary, and in determining what is appropriate MUST give primary consideration to the aid or format requested by the individual.

Rationale: Excludes blind, low-vision, and print-disabled people from public services (benefits, notices, ballots, court forms) when hardcopy is the only channel. Non-compliance is a direct ADA violation enforceable by DOJ and by private suit. Implementation notes: This is the statutory root for our entire print program. Every output surface — preserve “flyer” PDF, reflow/WeasyPrint HTML-to-PDF, docx→AcroForm forms, and printed audit/ACR artifacts — should carry a machine-emittable alternate-format request notice so the entity using our tool can meet its 35.160 duty. Our audit/ACR tooling should surface “no alternate-format affordance present” as a finding, not assert compliance (we cannot know the entity’s back-office process).

PRINT-LEGAL-002 — ADA Title III auxiliary aids duty (public accommodations)

Level: MUST Applies to: all documents Source: 28 CFR 36.303(a)–(c) (auxiliary aids and services for public accommodations) Source strength: regulation Machine-checkable: no Validation: Human/process control; pipeline assists via request-notice presence check.

A public accommodation MUST take those steps that may be necessary to ensure that no individual with a disability is treated differently because of the absence of auxiliary aids and services, unless it can demonstrate that doing so would fundamentally alter the goods or services or result in an undue burden (see PRINT-LEGAL-005).

Rationale: Reaches private-sector documents (bank statements, medical intake, retail contracts, hotel and restaurant materials). Failure exposes the business to DOJ enforcement and private litigation. Implementation notes: Same surfaces as LEGAL-001. Note the Title II vs Title III difference in how much deference the requester’s chosen format gets — see PRINT-LEGAL-003, which our copy and defaults should reflect (Title III lets the entity offer an effective alternative; our default request-notice string should not over-promise a specific format).

PRINT-LEGAL-003 — Primary-consideration distinction: Title II honors requested format vs Title III’s flexibility

Level: SHOULD Applies to: all documents Source: 28 CFR 35.160(b)(2) (“primary consideration to the requests of individuals with disabilities”) vs 28 CFR 36.303(c)(1)(ii) (public accommodation “should consult with individuals with disabilities” but retains latitude to choose an effective aid) Source strength: regulation + agency guidance Machine-checkable: no Validation: Editorial/legal review of request-notice wording per deployment context.

Request-notice copy SHOULD reflect the operative regime: for Title II entities the notice SHOULD signal that the requested format will be honored absent a valid defense; for Title III entities it SHOULD offer to provide an effective alternate format rather than guaranteeing a specific one.

Rationale: Over-promising (“we will provide any format you name”) creates contractual/false-representation exposure for Title III users; under-promising for Title II users understates their legal right and invites complaints. Implementation notes: Product config should carry an entity-type flag (public entity vs public accommodation) that selects the request-notice string variant. Default to the more cautious Title III phrasing when the flag is unset; document the choice in PRINT-ALT-010.

PRINT-LEGAL-004 — No-surcharge rule: cannot bill the disabled person for alternate formats

Level: MUST Applies to: all documents Source: 28 CFR 35.130(f) (Title II); 28 CFR 36.301(c) (Title III); 45 CFR 92.202(b) (Section 1557 — auxiliary aids “free of charge”) Source strength: regulation Machine-checkable: no Validation: Policy/process control; verify request-notice text does not attach a fee to alternate-format provision.

A covered entity MUST NOT impose a surcharge on an individual with a disability (or on people with disabilities as a group) to cover the cost of auxiliary aids, alternate formats, or other measures required to provide nondiscriminatory treatment.

Rationale: A fee for large print or Braille converts a right into a pay-wall and is an independent regulatory violation even where the format itself is eventually provided. Implementation notes: Any request-notice string our products emit MUST state (or at minimum MUST NOT contradict) that alternate formats are provided at no cost. Bake “no charge” into the default PRINT-ALT-010 string. Never let a pricing/upsell surface attach a fee to the accessible-format path.

PRINT-LEGAL-005 — Undue-burden / fundamental-alteration defenses and their limits

Level: MAY (context-dependent defense) Applies to: all documents Source: 28 CFR 36.303(a) and 35.164 (undue burden = “significant difficulty or expense”; fundamental alteration); decision must be made by the head of the entity or designee, in writing, with reasons Source strength: regulation Machine-checkable: no Validation: Legal determination — outside tooling scope. Document that the defense exists but is narrow and procedurally gated.

An entity MAY decline a specific auxiliary aid only where it can demonstrate the step would fundamentally alter the service or impose an undue burden, judged against the entity’s overall resources; even then it MUST still provide an alternative aid that ensures effective communication to the maximum extent possible.

Rationale: Misunderstood as a general cost escape hatch; it is not. Cost is measured against the whole entity, the determination must be documented by leadership, and a fallback aid is still required. Implementation notes: Do NOT let this defense soften any of our output defaults. Our tooling produces the accessible artifact regardless; whether an entity may lawfully decline a downstream request is their legal call, not a switch in our pipeline. Reference-only in audit/ACR narrative.

PRINT-LEGAL-006 — Section 504 reach through federal financial assistance

Level: MUST Applies to: all documents Source: 29 U.S.C. 794 (Section 504, Rehabilitation Act); implementing regs incl. 45 CFR Part 84 (HHS recipients); auxiliary-aids/effective-communication duty parallel to ADA Source strength: statute + regulation Machine-checkable: no Validation: Applicability determination (does the entity receive federal funds?) + same request-notice presence assist as LEGAL-001.

Any program or activity receiving federal financial assistance MUST NOT exclude or deny benefits to a qualified individual with a disability, and MUST furnish appropriate auxiliary aids and effective communication — a duty that reaches recipients (schools, hospitals, grantees, state agencies) independent of ADA coverage.

Rationale: Captures entities that might argue thin ADA coverage but take federal money (universities, health systems, grant-funded nonprofits). Enforcement runs through funding agencies’ OCRs and can jeopardize federal funding. Implementation notes: For customers in higher-ed, healthcare, and government-grant sectors, 504 is often the operative hook alongside ADA. No new output behavior beyond LEGAL-001; note it in audit/ACR applicability sections so the record shows we considered 504, not just the ADA.

PRINT-LEGAL-007 — Section 508 scope ends at electronic content; hardcopy handled by 504/ADA

Level: SHOULD (scope note — governs how we frame, not a print obligation) Applies to: all documents Source: 29 U.S.C. 794d (Section 508 — “electronic and information technology”); U.S. Access Board 508 Standards (36 CFR Part 1194, ICT scope) Source strength: statute — scope note Machine-checkable: no Validation: Documentation/editorial control — ensure our materials do not cite 508 as authority for a paper requirement.

Section 508 governs electronic and information technology developed, procured, maintained, or used by federal agencies; it does NOT impose requirements on ink-on-paper hardcopy. Print obligations for the same content flow instead from Section 504 and the ADA. We SHOULD NOT cite 508 as the legal basis for any print rule.

Rationale: Citing 508 for a paper mandate is a category error a reviewer will catch immediately and undermines the credibility of the whole KB. It also mis-scopes remediation (a 508-conformant PDF is an electronic deliverable; the moment it is printed, 504/ADA govern the artifact). Implementation notes: In audit/ACR/VPAT output, keep the 508 conformance claims attached to the electronic file and route any printed-artifact reasoning to 504/ADA. The tag-tree editor and flipbook export produce electronic artifacts (508 domain); the print-safe profile (PRINT-FIDELITY-002) is where the handoff to 504/ADA is documented.

PRINT-LEGAL-008 — ACA §1557 disability provisions & effective communication

Level: MUST Applies to: all documents (health programs and activities) Source: 45 CFR 92.202 (effective communication for individuals with disabilities; incorporates 28 CFR 35.160–35.164 standard; auxiliary aids “free of charge, in accessible formats, in a timely manner”); ACA §1557, 42 U.S.C. 18116 Source strength: regulation Machine-checkable: no Validation: Applicability (covered health entity) + request-notice presence assist.

A health program or activity receiving federal financial assistance, administered by an Executive agency, or under a Title I marketplace MUST ensure effective communication with individuals with disabilities and provide appropriate auxiliary aids and services free of charge, in accessible formats, and in a timely manner, applying the ADA Title II effective-communication standard.

Rationale: Health documents (EOBs, notices of coverage, patient instructions, consent forms) reach a population with elevated disability prevalence; §1557 layers a health-specific, funding-linked duty on top of ADA/504. Implementation notes: Healthcare customers using our forms and PDF pipelines fall here. Operative status (2026): the 2024 Part 92 final rule is in effect; litigation (Texas v. Becerra; Tennessee v. Becerra) stayed/enjoined the rule’s gender-identity provisions and, in Texas and Montana, the rule more broadly — but the disability effective-communication provisions (92.202) remain operative nationally. Treat as MUST for health customers.

PRINT-LEGAL-009 — §1557 Notice of Availability of language/format assistance

Level: MUST Applies to: all documents (health programs — on significant publications and communications) Source: 45 CFR 92.11 (Notice of availability of language assistance services and auxiliary aids and services) Source strength: regulation Machine-checkable: partial Validation: A pipeline CAN check for the presence of a notice-of-availability block on covered health documents (text/marker match); it cannot verify legal adequacy of wording or the taglines.

Covered health entities MUST provide a Notice of Availability of language assistance services and auxiliary aids and services, disseminated on significant publications and communications, informing individuals that such aids and services are available free of charge.

Rationale: The notice is the mechanism by which a print-disabled reader learns an alternate format can be requested; omitting it defeats the effective-communication duty in practice. Implementation notes: For health-sector deployments, our tooling SHOULD offer to emit a notice-of-availability block and SHOULD flag its absence on covered documents. Operative status (2026): §92.11 has a compliance date of one year after the rule’s July 5, 2024 effective date and is in force — it was not among the enjoined gender-identity provisions. This is a partial-machine-check win: presence is detectable; adequacy is human review.

PRINT-LEGAL-010 — 2024 DOJ Title II web rule increases (not reduces) print exposure — dual-regime note

Level: SHOULD (analytical framing) Applies to: all documents Source: 28 CFR 35.200–35.201 (WCAG 2.1 Level AA for state/local government web content and mobile apps); compliance dates extended by 89 Fed. Reg. rule as amended — Federal Register 2026-07663 (April 20, 2026): ≥50,000 population → April 26, 2027; <50,000 and special districts → April 26, 2028 Source strength: regulation — analytical Machine-checkable: no Validation: Framing/editorial — used to position, not to gate a file.

The 2024 DOJ Title II web rule sets WCAG 2.1 AA for public-entity web and mobile content; it does not displace the print effective-communication duty. Public entities SHOULD treat the electronic and print regimes as cumulative: making the website conformant does not discharge the obligation to provide accessible hardcopy of the same content on request.

Rationale: A common misread is “we did the website, we’re covered.” A PDF posted to a conformant site can still be handed out on paper, at which point 35.160 (not 35.200) governs the artifact. The rule raises overall exposure by codifying a hard electronic standard while the older functional print duty persists underneath. Implementation notes: Operative status (2026): the rule is in force and was NOT rescinded; the only change (Fed. Reg. 2026-07663) extended the compliance dates by ~one year (2027/2028) without altering the WCAG 2.1 AA standard, the exceptions in 35.201, or scope — consistent with the compliance-deadline dates tracked project-wide. Use this entry to explain, in audit/ACR narrative and sales/positioning, why “the site is accessible” is not a print defense.

PRINT-LEGAL-014 — CMS ABN (CMS-R-131) point-size instruction

Level: MUST (for the ABN document class) Applies to: forms only (the Advance Beneficiary Notice of Noncoverage, Form CMS-R-131) Source: CMS Form CMS-R-131 form instructions, Medicare Claims Processing Manual, Chapter 30 (§50.6.2); form is OMB-approved and its format is prescribed Source strength: agency guidance (binding form instructions) Machine-checkable: yes Validation: Measure rendered glyph height on the ABN; flag any entry text below 10-point. Applies to a specific, identifiable form, so the check is deterministic once the document is recognized as an ABN.

Entries and added text on the ABN (CMS-R-131) MUST NOT be smaller than 10-point type; CMS instructs that entries be large enough for ease of reading (approximately 12-point), with 10-point permitted only where detailed information will not otherwise fit the allotted space.

Rationale: The ABN determines a Medicare beneficiary’s financial liability; sub-10-point text can render a required notice defective and shift liability improperly, harming low-vision beneficiaries first. Implementation notes: In the docx→AcroForm converter and any ABN-template path, enforce a 10-point floor on all filled/added text (recommend 12-point). The audit tool can measure this deterministically when the document is identified as a CMS-R-131. Note this is form instruction, not a CFR point size — cite it as agency guidance, not regulation.

PRINT-LEGAL-015 — Medicare Advantage / Part D materials type-size: 42 CFR §§ 422.2267(a)(1) & 423.2267(a)(1)

Level: MUST (for the covered material class) Applies to: all documents (required MA / Part D beneficiary materials and content) Source: 42 CFR 422.2267(a)(1) (Medicare Advantage); 42 CFR 423.2267(a)(1) (Part D). Carve-out: member ID cards excluded from the 12-point requirement — 42 CFR 422.2267(e)(30)(vii) and 423.2267(e)(32)(vii) Source strength: regulation Machine-checkable: yes Validation: Measure rendered type size on covered MA/Part D materials; require ≥12-point, Times New Roman or equivalent; exempt member ID cards.

Required Medicare Advantage and Part D materials and content MUST be in a 12-point font, Times New Roman or equivalent. Member ID cards are excluded from the 12-point requirement.

Rationale: These materials (ANOC, EOC, formularies, enrollment and rights notices) drive coverage decisions for an older, higher-disability-prevalence population; the regulation fixes a hard floor precisely because small type had been used to bury material terms. Implementation notes: This is a true CFR point-size mandate — one of only three federal hard numbers. In our PDF and forms pipelines serving MA/Part D plan customers, enforce a 12-point floor (“or equivalent” allows non-TNR faces at equivalent x-height/legibility — do not hard-require the literal typeface). Wire the member-ID-card carve-out into any automated check so ID-card layouts don’t false-fail. parameters.point_size = 12 in rules.json.

PRINT-LEGAL-016 — FDA OTC Drug Facts type-size & format, 21 CFR 201.66

Level: MUST (for the OTC Drug Facts panel) Applies to: all documents (over-the-counter drug product labeling — the Drug Facts panel) Source: 21 CFR 201.66(d)(2) (minimum type sizes); 21 CFR 201.66(d)(10) (modified format for small packages / where labeling exceeds 60% of available surface); 21 CFR 201.66(e) (exemption/deferral by FDA) Source strength: regulation Machine-checkable: yes Validation: Measure type size on the Drug Facts panel: body/subheading text ≥6-point; headings the larger of 8-point or (text + 2 point); title “Drug Facts” larger than the largest type in the panel. Apply the small-package variant where triggered.

OTC Drug Facts labeling MUST use type no smaller than 6-point for subheadings and all other information in 201.66(c)(2)–(c)(9); headings MUST be the larger of 8-point or 2 points greater than the body text; and the “Drug Facts” title MUST be larger than the largest type used in the panel. Under the small-package format (labeling >60% of available surface), the “Drug Facts (continued)” title floor drops to 7-point and headings to the larger of 7-point or text+1-point, but the 6-point body floor is retained; leading below 0.5-point is permitted only if ascenders/descenders do not touch.

Rationale: Drug Facts convey dosing, warnings, and contraindications; sub-legible type is a direct safety hazard, disproportionately for low-vision consumers. FDA fixed the numbers rather than leaving them to design judgment. Implementation notes: Third and last of the federal hard numbers. For any OTC-label workflow, enforce the 6-point body floor and the heading/title ratios; branch to the 201.66(d)(10) small-package variant when the >60%-surface trigger is met (the branch relaxes heading/title floors, not the 6-point body floor). Note the FDA exemption/deferral pathway in 201.66(e) exists but is granted case-by-case — do not treat it as a default relaxation. parameters capture 6/8/7-point figures in rules.json.

PRINT-LEGAL-017 — International scope note: EN 301 549 / AODA / EAA (US-first, non-binding here)

Level: MAY (context — informational, out of US scope) Applies to: all documents Source: EN 301 549 (ETSI/CEN ICT accessibility standard — scope is ICT, i.e. electronic; V3.2.1 (2021) references WCAG 2.1 AA, V4.x tracking WCAG 2.2); European Accessibility Act (Directive (EU) 2019/882); AODA (Ontario, Accessibility for Ontarians with Disabilities Act, 2005) and its Information & Communications standard Source strength: consensus standard / foreign law Machine-checkable: no Validation: Informational — no gate. Flag only when a customer explicitly targets a non-US jurisdiction.

For non-US deployments, additional regimes MAY apply: EN 301 549 and the EAA (EU), and AODA (Ontario). Note these are predominantly ICT/electronic in scope — EN 301 549 explicitly covers ICT products and services, not ink-on-paper — so they reinforce our electronic deliverables more than the print artifact. This KB is US-first; these are non-binding here and are recorded for awareness only.

Rationale: Prevents a US-scoped requirement from being mis-cited as a global mandate, and flags that “European accessibility” is largely a digital regime — a customer expecting it to govern their printed brochure would be mistaken. Implementation notes: No output behavior. If we later add jurisdiction targeting, EN 301 549 conformance maps to our electronic artifacts (tag tree, PDF/UA, flipbook), while print obligations abroad would need country-specific research and are out of scope for v1.

PRINT-LEGAL-019 — Enforcement, remedies, and penalties for inaccessible hardcopy

Level: informational Applies to: all documents Source: 42 U.S.C. 12133 (Title II remedies, incorporating 29 U.S.C. 794a); 42 U.S.C. 12188(a)(1) (Title III private remedies, incorporating 42 U.S.C. 2000a-3(a)) and 12188(b)(2)(C) (DOJ civil penalties); 28 CFR 85.5 (inflation-adjusted penalty table); 28 CFR 35.174 (DOJ Title II civil action); 42 U.S.C. 12205 (attorney’s fees); 29 U.S.C. 794a and 34 CFR 104.61 → 34 CFR 100.8 (Section 504 remedies and fund termination); 42 U.S.C. 18116 (§1557); Barnes v. Gorman, 536 U.S. 181 (2002); Cummings v. Premier Rehab Keller, 596 U.S. 212 (2022); Duvall v. County of Maui, 260 F.3d 1124 (9th Cir. 2001) (en banc) Source strength: statute + regulation + case law Machine-checkable: no Validation: n/a — reference entry. Imposes no requirement on our output and gates no file. Exists so audit/ACR narrative and customer-facing positioning describe consequences accurately instead of inventing them.

There is no “print accessibility penalty.” No agency issues a citation for a sub-floor point size or a missing alternate-format notice. Hardcopy accessibility is enforced only as disability discrimination, through whichever antidiscrimination regime covers the entity (PRINT-LEGAL-001, -002, -006, -008). Consequences therefore depend on the regime, not on the defect.

ADA Title II (public entities). Remedies run through 42 U.S.C. 12133, which incorporates §505 of the Rehabilitation Act (29 U.S.C. 794a) and in turn Title VI. No civil monetary penalties exist against a public entity — DOJ cannot fine one under Title II. Available: injunctive relief (the primary remedy); compensatory damages, but only on a showing of intentional discrimination, which nearly every circuit reads as deliberate indifference (Duvall); and attorney’s fees under 42 U.S.C. 12205, in practice usually the largest figure in the case. Punitive damages are barred (Barnes v. Gorman). DOJ may bring its own civil action under 28 CFR 35.174 and typically resolves via settlement agreement or consent decree with multi-year monitoring.

ADA Title III (public accommodations). Private plaintiffs get injunctive relief and attorney’s fees only — no damages (42 U.S.C. 12188(a)(1)). DOJ pattern-or-practice suits may seek civil penalties under 42 U.S.C. 12188(b)(2)(C), statutory $50,000 / $100,000, inflation-adjusted annually under 28 CFR 85.5. State law is frequently where the actual money is: California’s Unruh Act sets a $4,000-per-violation statutory minimum (Cal. Civ. Code 52(a)) on an ADA-predicate violation with no separate intent showing.

Section 504 (federal-funds recipients). Same damages structure as Title II. Adds termination of federal financial assistance (34 CFR 104.61 incorporating 34 CFR 100.8) — procedurally gated and vanishingly rare, but enormous leverage against a university or health system. The realistic route is an agency OCR complaint closing in a resolution agreement: document remediation inventory, staff training, corrected grievance process, periodic reporting. No fine, but expensive and public.

ACA §1557. Borrows the remedies of the underlying statutes including 504 (42 U.S.C. 18116); HHS OCR enforcement with fund termination as backstop.

The damages caveat. Cummings held emotional-distress damages unavailable under Spending Clause statutes, which covers §504 and §1557. Because the injury from an inaccessible document is usually dignitary rather than economic, this substantially deflated the damages side of 504 claims. It does not plainly reach Title II, which rests on §5 of the Fourteenth Amendment rather than the spending power, and the circuits have split; treat the question as unsettled.

Rationale: The KB documented every duty and no consequence, which left the most common customer and reviewer question — “what actually happens if we don’t?” — to be answered from memory, the failure mode this KB exists to prevent. Stating consequences precisely also guards the other direction: overstating exposure (invented fines, penalties against public entities that cannot be penalized) is a credibility risk in exactly the procurement and audit contexts where this reference gets cited.

Implementation notes: Reference-only — no output behavior, no gate, no rules-engine threshold. Rules for audit/ACR narrative and any customer-facing surface:

Never state or imply a dollar figure for a public entity. Title II and 504 carry no civil monetary penalties. The 28 CFR 85.5 amounts are Title III DOJ pattern-or-practice only and are routinely misquoted as generic “ADA fines.”
Verify penalty amounts at time of use. 28 CFR 85.5 is re-adjusted for inflation and the operative amount is keyed to the date the penalty is assessed. parameters carries the figures verified on the date in penalty_amounts_verified_date; re-check the current table rather than trusting the cached number.
Notice is the trigger worth communicating. Before a request is made, exposure is essentially injunctive. Once a person requests an accessible format and does not receive one in a timely manner, deliberate indifference is in play and the damages door opens. This is the substantive argument for remediating a corpus proactively rather than on complaint, and it ties directly to PRINT-ALT-008’s timestamp_requests_for_audit.
Route the “which regime?” question to applicability, not to this entry. Coverage turns on entity type, funding, and jurisdiction (PRINT-LEGAL-001/002/006/008); the undue-burden and fundamental-alteration defenses are at PRINT-LEGAL-005; PRINT-LEGAL-018 governs all of it.
Our tooling reports findings, not verdicts — consistent with PRINT-LEGAL-001, we surface “no alternate-format affordance present,” never “this document is unlawful.”

PRINT-LEGAL-018 — Disclaimer: engineering guidance, not legal advice

Level: informational Applies to: all documents Source: n/a (internal governance) Source strength: n/a Machine-checkable: no Validation: n/a

This section is engineering guidance for building print-safe, accessibility-aware documents — not legal advice. Citations were verified against primary sources (eCFR/CFR text, Federal Register, HHS/CMS/FDA/DOJ materials) as of the updated date, but statutes, regulations, agency form instructions, and litigation status change, and applicability turns on facts (entity type, funding, jurisdiction, document class) that this KB cannot resolve. Jurisdiction- or entity-specific questions — including whether a given entity is covered, which point-size mandate governs a specific document, or the current status of any rule under litigation — must go to counsel. Nothing here creates a warranty of legal compliance for any output our pipelines produce.