Archiving Web Content

Web content includes anything experienced on the web, such as:

• Web pages
• PDF documents
• Word, Excel, or PowerPoint files
• Videos and audio
• Images and graphics
• Web-based applications and tools

These materials must generally be accessible if they are used for university programs, services, or activities.

Examples of content that must be accessible include:

• Application forms or enrollment information
• Course schedules and syllabi
• Event announcements and calendars
• Program descriptions or admissions information
• Any document used to request or access services

If users rely on the content to participate in a university program or activity, it must meet accessibility requirements, regardless of when it was created.

The ADA Title II rule allows certain older content to remain inaccessible if it qualifies as archived web content. For the exception to apply, all four conditions must be met:

1. The content was created before the date the state or local government must comply with this rule, or reproduces paper documents or the contents of other physical media (audiotapes, film negatives, and CD-ROMs for example) that were created before the government must comply with this rule, AND
2. The content is kept only for reference, research, or recordkeeping, AND
3. The content is kept in a special area for archived content, AND
4. The content has not been changed since it was archived.

The exception does not apply unless all four points are present. If any point is missing, the content generally must meet WCAG 2.1, Level AA, unless another exception applies.

Examples of university content that could qualify for archiving include:

• Websites for events that occurred years ago
• Historical newsletters or publications
• Old research datasets or reports
• Past departmental websites no longer maintained
• Collections of legacy documents or media

These materials are typically preserved for historical reference or institutional recordkeeping rather than current use.

Content cannot be archived if it is still used to access university programs or services. Examples include:

• Admissions or financial aid forms
• Active course materials
• Current policy documents
• Program requirements for students
• Any information used to apply for or participate in university services

Even if these documents were created before the compliance deadline, they must still be accessible if they remain in use.

Universities should establish a structured archive process to ensure content qualifies for the exception.

1. Create a Dedicated Archive Area
   • Establish a clearly labeled archive section on the website (for example: /archive)
   • Store archived web pages and documents only in this location.
2. Move Legacy Content into the Archive
   • Identify outdated or inactive content.
   • Relocate that content into the archive section.
   • Clearly label items as “archival” or “archived.”
3. Prevent Updates to Archived Content
   Once archived, the content should not be modified. If changes are made, the content must be removed from the archive and made accessible.
4. Provide a Process for Accessibility Requests
   Even if content qualifies as archived, universities must still ensure effective communication. If someone with a disability requests access to archived materials, the institution must provide an accessible version in a timely manner.

To prepare for the April 2027 deadline, institutions should:

• Conduct a comprehensive audit of web content and documents
• Identify active vs. legacy content
• Remediate content required for programs and services
• Move unused legacy materials to a designated archive
• Establish governance policies for archiving and accessibility requests

Many universities are adopting these strategies to reduce the volume of content that must be fully remediated while preserving historically valuable materials online.