Archiving options to meet ADA digital accessibility requirements | College of Health

There are many ways to consider content "archived" in order to meet ADA Digital Accessibility rules.

**Archived Web Content: Four-Part Compliance Checklist** All four criteria must be met simultaneously for web content to qualify for the archived content exception under the ADA Title II web accessibility rule (28 CFR Part 35, Subpart H). If any single criterion is missing, the content must generally meet WCAG 2.1 Level AA.
Criterion	Required?	Common Pitfall
Created before your compliance deadline	Yes	New documents moved into an archive section after your deadline do not qualify, even if labeled "archived."
Kept solely for reference, research, or recordkeeping	Yes	Active service documents — including current policies, laws, or anything the public relies on for ongoing guidance — cannot use this exception.
Not altered or updated after archiving	Yes	Any edit made after content is archived removes the exemption. The document must then meet WCAG 2.1 Level AA.
Stored in a clearly labeled, dedicated archive area	Yes	Mixing archived content with live content — or using a vague label — invalidates the exception. The archive designation must be clear to all users, including those using assistive technology.

**Archived Web Content: Four-Part Compliance Checklist for College Websites** All four criteria must be met simultaneously for web content to qualify for the archived content exception under the ADA Title II web accessibility rule (28 CFR Part 35, Subpart H). This college's compliance deadline is April 24, 2026. If any single criterion is missing, the content must generally meet WCAG 2.1 Level AA by that date.
Criterion	Required?	College Example — Exception Applies	College Example — Exception Does Not Apply
Content was created before April 24, 2026	Yes — all four criteria required	A PDF of a 2019 research symposium program scanned from a printed booklet and posted to a clearly labeled archive section after April 24, 2026. Because the underlying physical document was created before the deadline, it qualifies.	Meeting minutes from a faculty governance committee meeting held in May 2026, even if moved to an "archive" folder on the college website. The content was created after the deadline and must meet WCAG 2.1 Level AA.
Kept solely for reference, research, or recordkeeping	Yes — all four criteria required	A 2017 annual report PDF stored in a labeled archive section that the college no longer distributes or references in active communications. It exists only as a historical record of that year's activities.	A PDF describing current graduate program admission requirements that was first posted in 2022 and is still linked from the program's active admissions page. Prospective students rely on it to apply — it is an active service document and must meet WCAG 2.1 Level AA.
Not altered or updated after being archived	Yes — all four criteria required	A 2018 research center newsletter PDF posted to the archive in 2019 and never subsequently edited. Redacting a student's personal information before archiving is permitted and does not disqualify the document.	A 2021 faculty directory PDF originally posted before April 24, 2026 that is later updated after that date to reflect faculty departures and new hires. The update removes the exemption — the revised document must meet WCAG 2.1 Level AA.
Stored in a clearly labeled, dedicated archive area	Yes — all four criteria required	Historical course catalogs from 2010–2022 organized in a section of the college website explicitly titled "Archived Course Catalogs," separate from the current catalog, with a visible notice that archived content may not meet current accessibility standards.	A 2020 research grant report PDF stored in the same folder as current grant reports, with no distinction between active and archived content. Without a clearly identified, separate archive area, the exception does not apply and the document must meet WCAG 2.1 Level AA.