To reduce a PDF for e-filing, find your own court’s per-document cap (caps differ by court; the pages we read range from 10 MB to 100 MB), run OCR on scans before you compress them, then shrink the images inside the file. Pictures of text are what make an exhibit heavy.
| What you are filing | Limit to check | Setting |
|---|---|---|
| A brief exported from a word processor | Still check the cap; text PDFs start small (our 21-page contract: 116,995 bytes) | Export PDF directly. That text-only contract still fell 36.1% under Smol. |
| Scanned exhibits, already OCR’d | 25 MB per document in Illinois trial courts; under 50 MB in N.D. Cal. | Large. Medium only if the cap forces it, then read the output at 100%. If your court sets a dpi rule for the file, see the settings table. |
| Photograph exhibits | Same per-document caps; check any envelope cap too | Large, or Original. Look at them at 100%. |
| Files that carry author or comment data | No size limit, a different risk | Compression does not strip metadata. Smol’s strip-metadata step is separate, and its limits are in the confidentiality section. |
We make Smol, so read the product claims as ours and the court limits as theirs. Every limit below was opened on the court’s own page on 9 October 2026, and the exceptions are listed where they apply.
What is the PDF size limit for e-filing in my court?
There is no national number. PACER says it directly: “Each court sets a limit on the size of PDF files submitted for electronic filing”, and it points filers to a court-by-court CM/ECF lookup. The caps we could read at the source:
| Court or system | Stated cap | Source wording |
|---|---|---|
| U.S. Supreme Court | 100 MB per file | “The maximum size of any single computer file that can be uploaded … is 100MB.” |
| Ninth Circuit (Circuit Rule 25-5(e), June 2026 handbook) | 100 MB per attachment; larger ones must be divided | “No single attachment shall exceed 100 MB in size.” Larger attachments must be divided. A scanned exhibit is allowed only “if the filer does not possess a word processing file version of the attachment”. |
| N.D. Cal. (CM/ECF) | Under 50 MB | “ECF will reject anything 50.0MB (50,000KB), or over.” |
| W.D. Wash. (CM/ECF) | 100 MB per document | “Each document/attachment included in your filing must not exceed 100 megabytes (MB).” |
| NYSCEF (New York) | 100 MB per PDF | “Yes. 100 megabytes per PDF document.” |
| California Rules of Court 8.74 (appellate) | 100 MB per filing | “An electronic filing may not be larger than 100 megabytes.” |
| San Diego Superior Court (civil) | 35 MB per document, 60 MB per order | “There is a 35 MB limit per document when uploading to the system.” |
| San Bernardino Superior Court (civil) | 25 MB per document, 50 MB per submission | “No single document can be larger than 25 MB.” |
| Florida Courts E-Filing Portal | 50 MB, then a storage medium the clerk accepts | “documents that exceed the 50MB file size limit” go on “an electronic storage medium that the Clerk has the ability to accept”. The text carries no date; the file sits under an August 2021 upload path and its PDF properties give 24 August 2021. |
| eFileIL (Illinois) | 25 MB per document, 50 MB per envelope | “The maximum file size for a document e-filed through eFileIL is 25mb., with a maximum envelope size of 50mb.” Reviewing courts: 150mb per envelope. |
| eFileTexas | Not stated on the pages we read | Neither the FAQ nor the Technology Standards (Version 11.0, June 2026) state a size cap. County clerks and e-filing service providers may quote their own, so ask the provider you file through. |
| Second Circuit (CM/ECF) | Court pages disagree: 10 MB on two, 50.0 MB on a third | “CM/ECF will not accept filing of a single PDF document that exceeds 10 MB in file size.” (page last modified 5/24/2016). Local Rule 25.1, last modified 12/14/2023, also speaks of 10 megabytes, while the court’s CM/ECF court-information page lists “Maximum PDF File Size” as 50.0 MB. |
Three things to watch in that table. The first is the envelope. San Diego (per order), San Bernardino (per submission) and Illinois (per envelope) cap the whole batch as well as each document, so three PDFs that each clear the per-file limit can still bounce together. The second is the word “under”: N.D. Cal. counts 1000 KB as 1 MB and rejects a file at exactly 50.0 MB.
The third is stale or conflicting pages. The Second Circuit’s clerk page says 10 MB and was last modified in 2016, its local rule still mentions 10 MB, and its CM/ECF court-information page lists 50.0 MB. When a court’s own pages disagree, ask the clerk. Other courts may have moved on too. The District of Delaware’s 2016 notice announces a raise from 5 to 35 MB, and the District of New Hampshire’s 2015 notice a raise from 5 to 10 MB. Both are still online, and neither tells you today’s limit. Courts do not always date the current one. Use the court’s CM/ECF page, or your e-filing provider.
Our working rule is to aim for 70% of the stated cap, a habit from our guide to PDFs that are too big to upload. A file at 49.5 MB against a 50 MB wall leaves no room for how a portal counts.
What else do courts require besides file size?
Size is the rule that rejects you at upload. The format rules decide whether the clerk accepts the document afterward, and they constrain how you compress.
| Requirement | Who states it | How it is worded | Source wording |
|---|---|---|---|
| Text-searchable PDF | California Rules of Court 8.74; San Bernardino Superior Court; eFileTexas standards | “Must” in California and Texas | “Electronic documents must be in text-searchable portable document format (PDF)” (Cal.). “An e-filed document must be in text-searchable PDF” (Texas Technology Standards, Version 11.0, June 2026). San Bernardino: filings “must be text searchable”. |
| Built from the word processor, not a scan | Ninth Circuit; eFileIL | Prohibited in the Ninth Circuit, exhibits excepted; “when possible” in Illinois | “PDF files created by scanning paper documents are prohibited; however, exhibits submitted as attachments to a document may be scanned” (Ninth Cir.). The OCR PDF “should be created directly from the program creating that document” (eFileIL, “when possible”). |
| PDF/A | NYSCEF; U.S. Supreme Court | Required in New York; “should” at the Supreme Court | “NYSCEF requires that all e-filed documents conform to PDF/A specifications.” “Documents submitted through the electronic filing system should be in the PDF/A format.” (Supreme Court). |
| Bookmarks | California Rules of Court 8.74 | “Must” | “Each electronic document must include an electronic bookmark to each heading, subheading, and the first page of any component of the document”, and the rule lists what counts as a component. |
| Scan resolution and color | NYSCEF; W.D. Wash.; eFileTexas; eFileIL; Florida portal | Resolution required in New York, Washington (W.D.) and Texas; “when possible” in Illinois; “should” in Florida | NYSCEF: 200 dpi required. W.D. Wash.: 300 dpi required, and scans should be black and white unless color is integral. Texas: scans must have 300 DPI. eFileIL, when possible: minimum 300, maximum 600 dpi, black/white. Florida: OCR scans “should be” at 300 DPI, and black and white documents “should be filed”. |
| No encryption | eFileIL; eFileTexas standards | “Cannot” in Illinois; “may not” in Texas | Documents “cannot contain any security or encryption” (Illinois). Texas: no “password protection or encryption”. |
Two of those rules bite on compression. Illinois and Texas bar encryption, so remove any password in your PDF editor before compressing; we have not tested how Smol handles a password-protected file. And the scan rows deserve a second look, because scanner settings alone can change file size by about 16 times. N.D. Cal. weighed the same 317-page document two ways and published the results next to its scanner settings:
| Scanner mode | Resolution the court states | Its 317-page test |
|---|---|---|
| Bitonal (1-bit black and white) | 300 to 600 ppi | 300 ppi: 23.86 MB, “sufficiently legible” |
| Gray scale (8-bit) | 300 to 400 ppi | 400 ppi: 374.47 MB |
| Color (24-bit RGB) | 300 to 400 ppi | Not tested on the page |
That is about 16 times between two settings the court allows. If your court wants black and white at 300 dpi, scan that way: bitonal was the small end of the court’s own test. If you are stuck with a color scan that must stay at 300 PPI, converting it to grayscale with Ghostscript first kept every page at 300 PPI in our test and took the file from 5,017,560 to 1,720,854 bytes, 65.7% smaller (the scanned-PDF guide has the command). That is done outside Smol.
Why is my exhibit PDF so big in the first place?
Because it is a stack of photographs of pages. In our test, the same three-page agreement came to 87,788 bytes as a text PDF and 5,017,560 bytes as a 300 PPI color scan: 57 times larger, with zero characters of searchable text, as measured in our scanned-PDF guide.
That is why the fix differs by file. A scan has no fonts to subset and nothing to merge, so resolution and color are the levers. A word-processor export has few images, so a preset has little to work on, though a 21-page text-only contract still fell from 116,995 to 74,731 bytes under Smol, to 56,321 under Ghostscript, and grew to 247,782 under Preview’s Reduce File Size (method and all five routes here).
If you hold the original Word file, export a PDF from it instead of printing and scanning. The Ninth Circuit, the U.S. Supreme Court and eFileIL each say as much in their own rules, and in our test the scan was 57 times larger than the text PDF and had no searchable text.
Which Smol preset gets a scanned exhibit under the cap?
Smol’s five PDF presets are long-edge pixel caps with a JPEG quality attached: 600, 900, 1,200, 1,800 and 2,400 px at roughly quality 25, 45, 60, 75 and 88. They are not DPI targets, so the PPI you get depends on the page. This is the measured result on a three-page scan (2,550 × 3,300 pixels, so the 2,400 px Original cap already downsamples it) that was OCR’d first, by a tool other than Smol:
| Preset | Long edge | File size | Effective PPI | Searchable words |
|---|---|---|---|---|
| Source (OCR, uncompressed) | 3,300 px | 5,032,225 B | 300 | 1,405 |
| Original | 2,400 px | 1,736,280 B | 218 | 1,405 |
| Large | 1,800 px | 624,925 B | 164 | 1,405 |
| Medium | 1,200 px | 284,590 B | 109 | 1,405 |
| Small | 900 px | 166,998 B | 82 | 1,405 |
| Tiny | 600 px | 65,126 B | 55 | 1,405 |
Every row kept all 1,405 words, because an OCR layer is text and image compression does not touch it. The same scan without OCR tells the other half: re-OCR accuracy was 96.8% at 82 PPI and 1.42% at 55 PPI. Read the order into that: OCR first, compress second. The full test and the one built-in tool that destroys the layer are in the scanned-PDF guide.
| Document | Preset | Why |
|---|---|---|
| Scanned exhibits a judge or clerk will read | Large | 164 PPI on the test page, above the 150 PPI floor we recommend for body copy. |
| Same exhibits against a tight cap | Medium, only if the cap forces it | 109 PPI on that fixture, below the 150 PPI floor. Open the result at 100% and read the smallest type before you file. |
| Photograph or image exhibits | Large, or Original | Original is not lossless: it re-encodes, and resamples anything above 2,400 px. |
| Small and Tiny | Not for filings | Tiny drops the test page to 55 PPI, where a human reader loses the text even though search still works. |
| A court that requires 200 dpi in the file (NYSCEF) | Original only | 218 PPI on a letter page. Large (164) is below 200, and so is every preset on a legal-size page. |
| A court that requires 300 dpi in the submitted file | None of them | On a letter page the highest preset is 218 PPI. Grayscale conversion with Ghostscript, outside Smol, kept 300 PPI in our test; see the scan-resolution section above. |
Page size changes the arithmetic, because the presets cap pixels and not inches. Legal-size exhibits are common in filings, and on them even Large drops below the floor:
| Page | Original (2,400 px) | Large (1,800 px) | Medium (1,200 px) |
|---|---|---|---|
| Letter, 8.5 × 11 in | 218 | 164 | 109 |
| A4, 8.27 × 11.69 in | 205 | 154 | 103 |
| Legal, 8.5 × 14 in | 171 | 129 | 86 |
| Tabloid, 11 × 17 in | 141 | 106 | 71 |
So on legal-size or larger pages, treat Large as the floor you test rather than the safe default, treat Medium as a last resort, and check the output at 100%. If the type is not readable, the file is under the cap and still wrong.
Loose photos are a separate case. If you shrink image files before placing them in a PDF, Smol resizes images to fit inside 2000 × 2000 px by default, so raise or switch off that limit when detail matters, and the photographers’ delivery page covers image files in more detail. The preset behavior is explained at length in what the PDF presets actually do.

How do I compress a folder of exhibits, step by step?
Find the cap and set your target at 70% of it
Use the court’s CM/ECF page or your e-filing provider, and note whether the cap is per document, per envelope, or both.
OCR any scan at full resolution first
Smol does not OCR, so use Acrobat or OCRmyPDF. On our scan, the OCRmyPDF defaults cut the file by 45.1% at 300 PPI (to 2,754,671 bytes) while adding the text layer. Adding
--optimize 3 --jpeg-quality 70took the same scan from 5,017,560 to 1,372,066 bytes, still at 300 PPI, before Smol touched it. Use one of these two commands:brew install ocrmypdf ocrmypdf exhibit-12.pdf exhibit-12-ocr.pdf ocrmypdf --optimize 3 --jpeg-quality 70 exhibit-12.pdf exhibit-12-ocr.pdfThe 5,032,225-byte OCR’d source in the preset table below is a different file from these two outputs, so do not expect 624,925 bytes after this step.
One catch: OCRmyPDF’s documentation says it writes PDF/A by default and that
--output-type pdfturns that off. So this step may be what makes your file PDF/A, which some courts want and some do not.Press
⌘Fin Preview and search a word you can see on the page. If it finds nothing, the layer is not there.Drag the files, or the whole folder, into Smol
Choose the Large preset, unless your court sets a dpi rule for the uploaded file (see the settings table). A mixed pile of PDFs and photographs can go in together, and Smol writes each result next to the original with a
_compressedsuffix. The original is never overwritten by default.Read the per-file results
Any file that would have grown stays as it was (the direct compress path). Exhibits that did not move may already be optimized, and those are the ones to look at by hand.
Check size, text and structure
Get Info on each output against your 70% target. Search a word. Page through at 100%. If your court wants bookmarks or PDF/A, confirm them now with a validator, because we have not tested either after compression and the OCR step may be what created the PDF/A.
Clean metadata as a separate pass, and sign last
Compression does not strip metadata (next sections). Apply any digital signature after compressing; we have not tested what a compression pass does to an existing signature.
Speed in our batch test: 100 copies of one 1.6 MB four-page scan (152 MB, a duplicated test set rather than a mixed real folder) took 12.2 seconds at the Small preset on an M2 Pro. The full write-up is in batch compressing PDFs on a Mac.
What if the file is still over the cap?
Split it. PACER’s own advice is “to break the document into separate, smaller documents”, and W.D. Wash. spells out how: anything over 100 MB “must be divided into smaller documents/attachments” and labeled, with its example being Exhibit 1, Part 1 and Part 2. The Ninth Circuit likewise requires oversized attachments to be divided. Florida points oversized material to an electronic storage medium the clerk can accept. Smol does not split PDFs, so use Acrobat or any PDF editor that extracts page ranges.
Check one thing before you cut. Splitting our twelve-page layout into three files produced 91.5 MB of output from a 34.8 MB input, because each part carried its own copy of every shared image. On a scan, where each page has a unique image, splitting changed nothing: 5,017,560 bytes in, 5,016,808 out.
- Respect the envelope. Splitting an exhibit into three documents does not help if the submission cap is the one you are hitting.
- Upload in small groups. N.D. Cal. says ECF is less likely to freeze if you submit no more than 8 to 10 files at a time, whatever their size.
- Check the judge’s standing orders. They can add rules about how exhibits are grouped or excerpted beyond what the court’s CM/ECF page says.
How does Smol compare with Acrobat, Preview and online compressors?
| Tool | What it does well | Where it falls short for filings |
|---|---|---|
| Adobe Acrobat Pro | OCR, redaction, PDF/A, bookmarks and Bates numbering in one app. PDF Optimizer sets color, grayscale and monochrome images separately. | US$239.88 a year prepaid, US$19.99 a month on an annual plan billed monthly, or US$29.99 month to month (Adobe, read 9 October 2026). Overkill if you only need smaller files. |
| Preview, Reduce File Size | Free and already on the Mac. Fine for one image-heavy PDF. | A fixed filter: JPEG 0.70, 144 DPI, 2,400 px. It left 188 of 1,405 words searchable in our OCR test, and it enlarged a text-only contract by 111.8%. |
| Ghostscript and OCRmyPDF | Free, scriptable, genuine resolution targets; Ghostscript beat Smol on the text-only contract. OCRmyPDF adds the text layer. | Terminal work, and a shell loop that someone has to maintain and get right. |
| Online compressors such as Smallpdf | No install; it runs in the browser. Smallpdf’s privacy notice (read 9 October 2026) says: “If you access our services via a User Account, we delete User Files within one hour unless you save them to your file storage.” Without an account, it “will generally aim to delete User Files within a reasonable period of time after the last time they were opened”. | The document is transmitted to a server. Whether that is acceptable is a question for your engagement terms, not for us. |
| Smol | Whole folders at once, five presets, originals kept by default, per-file results, nothing uploaded. $29 once. | No OCR, redaction, PDF/A, bookmarks, Bates numbering or splitting. Presets cap pixels, not DPI. |
If you already pay for Acrobat for redaction and OCR, keep using its optimizer and skip Smol. The case for a second tool is a large folder of exhibits, or the colleague who should never need a command line. Our Acrobat comparison and seven-tool PDF test go further, and the Smallpdf comparison covers the upload question.
What does local processing mean for client confidentiality?
Smol runs on your Mac. It has no account and no server for your files, and it uploads nothing. The shot below shows Activity Monitor with zero bytes sent. That is a fact about where the bytes go. It is not a statement about any law, bar rule or engagement letter, and we are not able to tell you what your jurisdiction requires.

Compression is not metadata removal
Our 162,058-byte test contract fell to 57,377 bytes at the Tiny preset, 64.6% smaller, and every Document Info key and XMP tag survived. Comment authors and embedded attachments survive too. Smol has a separate strip-metadata operation for document properties. On our test file, one command from a free command-line tool restored the cleared properties in our test (the PDF metadata test has the method), so do not treat the result as permanent.
Metadata removal is not redaction
N.D. Cal. warns that metadata “can reveal anything that was contained in the file at any time” and that tools which “black-out, cover over or remove sections of text” can be undone “by anyone to reveal the text underneath” (the court’s redaction page). Smol does not redact, and its metadata stripping is no substitute for redaction. Use a real redaction tool, then check the output by extracting its text. The wider picture for sensitive files is on our confidential documents page, and the two sibling posts cover legal and HR documents and what compression leaves in place.
How does a firm roll this out across an office?
Smol is a one-time purchase: $29 for one Mac, $49 for the Team license (three Macs, seats managed from an admin dashboard), or $20 a seat for 5 to 500 seats on Enterprise, also managed from one dashboard. Updates are free and there is no per-file quota. See pricing.
Consistency is the point for a team. Write down the settings (Large preset, originals kept) and have each person set them on their own Mac, so a paralegal, an associate and the records clerk start from the same choices. A Finder Quick Action adds a right-click for the person who will never open the app.
A watched folder can compress new files automatically, but it fits legal work only with care. Scans must be OCR’d before they reach it, because compressing first can wreck OCR (in our test, re-OCR accuracy was 1.42% at 55 PPI), and we have not tested a scanner-to-folder flow. Use the Large preset, which keeps 164 PPI on a letter page. Watched folders can make already-optimized files larger, a defect we disclose in that post, so do not point one at a folder of finished filings.
When is Smol the wrong tool for e-filing?
Seven cases, and the first three matter most.
Your court needs more than a small file. If it requires PDF/A, bookmarks, OCR, redaction or Bates numbering, Smol supplies none of them. Acrobat Pro does (US$239.88 a year prepaid, per Adobe’s pricing page). If you need those, Acrobat is the right tool.
The submitted file must be 200 or 300 dpi or higher. Every preset caps the long edge at 2,400 px, which is 218 PPI on a letter page. If your court’s resolution rule applies to the file you upload rather than to the scanner, a Smol preset takes you below 300, and only Original clears a 200 dpi rule such as NYSCEF’s (Large, at 164, does not). Use the OCRmyPDF defaults, which kept 300 PPI in our test, convert a color scan to grayscale outside Smol (which kept 300 PPI and cut our test scan 65.7%), or rescan in bitonal.
You are cleaning one document and confidentiality is the point. exiftool -all= followed by qpdf --linearize is free and rewrites the file; the restore attempt we ran against it found nothing to restore. On Smol’s strip-metadata output, one command from a free command-line tool restored the cleared properties in our test (method here).
Your PDFs are text-only. Our presets work on embedded images. Ghostscript reached 56,321 bytes on the text-only contract where Smol reached 74,731.
You need an audit trail. If you need a hash log or a documented procedure, a drop target will not give you one. Some PDFs, from generators such as ReportLab, also compress by almost nothing under Smol’s presets, so measure rather than assume.
You need to split, merge or sign. Smol does none of them. And it runs on macOS only, so in a mixed office it covers the Macs and nothing else.
You are filing one document, once. Preview is free. Run it, then check the output for the lost-text trap in the comparison table above. If the result searches and fits, keep your money.
Frequently asked questions
What is the file size limit for e-filing a PDF?
There is no single limit, because each court sets its own. Among courts we read at their own pages: the U.S. Supreme Court, W.D. Wash. and NYSCEF allow 100 MB, N.D. Cal. rejects 50 MB and over, San Diego allows 35 MB per document, and Illinois trial courts allow 25 MB inside a 50 MB envelope. The Second Circuit’s own pages disagree, so ask the clerk or your filing provider.
How do I reduce the size of a scanned PDF for court without losing searchable text?
Run OCR first, then compress. In our test, a three-page, 1,405-word scan kept all 1,405 searchable words at every Smol preset because the text layer is text, not pixels. Without OCR first, re-OCR accuracy fell to 1.42% at 55 PPI. Always search a word in the output before filing.
Does Smol make PDFs PDF/A or add bookmarks and Bates numbers?
No. Smol compresses and converts files. It does not OCR, create a text layer, produce or validate PDF/A, add bookmarks, redact, Bates-stamp, split, merge or sign PDFs. We have not tested whether PDF/A status or bookmarks survive compression, so verify both after compressing if your court requires them.
Does compressing a PDF remove metadata or redact it?
Neither. Compressing a 162,058-byte test contract to 57,377 bytes at the Tiny preset left every Document Info key and XMP tag in place. Smol’s strip-metadata operation is separate, and on our test file one command from a free command-line tool restored the cleared properties, so do not treat it as permanent. Redaction is a different job that Smol does not do.
Is it safe to use an online PDF compressor for client documents?
That depends on your engagement terms and jurisdiction, and we do not give legal advice. As a fact, an online compressor transmits the document to a server. Smallpdf’s privacy notice says it deletes user files within one hour for account users unless they are saved to file storage. A local app such as Smol processes on your Mac and uploads nothing.
What can I do if the PDF is still too large after compressing?
Split it into labeled parts, each under the cap, such as Exhibit 1 Part 1 and Part 2, as W.D. Wash. describes. Mind the envelope cap too, and check shared images first: splitting a twelve-page, 34.8 MB layout file grew the total to 91.5 MB. Smol does not split PDFs; use Acrobat or another editor.
Keep reading
Smol for other teams
