Archiving Web Content

Public universities must ensure their web content and mobile applications are accessible to people with disabilities under updates to Title II of the Americans with Disabilities Act (ADA). These rules require most web content to meet WCAG 2.1 Level AA accessibility standards by April 24, 2026 for large public entities.

Because universities often maintain large amounts of legacy material, the regulation includes a limited exception for archived web content. This exception allows certain older content to remain online without full remediation if specific conditions are met.

What Is Considered 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 Archived Web Content Exception

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. Created before the compliance date
    The content must have been created before April 24, 2026.
  2. Retained only for reference, research, or recordkeeping
    It cannot be required to access services, programs, or activities.
  3. Stored in a clearly identified archive section
    The content must be placed in a dedicated archive location on the website.
  4. Not altered after being archived
    If the content is edited or updated, it loses the archive exception and must be made accessible.

If any of these conditions are not met, the content must comply with WCAG 2.1 Level AA accessibility standards.

Examples of Content That May Be Archived

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.

Examples of Content That Cannot Be Archived

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.

How to Create an ADA-Compliant Web Archive

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.

Best Practices for Universities

To prepare for the April 2026 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.

Key Takeaways

Archiving provides a limited exception under ADA Title II for legacy content, but it is only valid if the material is no longer used for programs or services, is stored in a clearly designated archive, and remains unchanged after being archived.