Guidelines for When it is Acceptable to use the Americans with Disabilities Act’s Archival Exception for Inaccessible Digital Content Created Before April 24, 2026

I. What is Archived Web Content?

Archived web content is web content retained exclusively for reference, research or recordkeeping. Archived web content is one of the narrow exceptions to the Americans with Disabilities Act’s requirements for digital accessibility. Web content includes anything posted on a website or Canvas page, including electronic documents and videos.

II. When can Someone Label Web Content as Archived?

It is possible to label web content as archived only if all four of the following conditions are met:

  • The content was created before the compliance deadline (April 24, 2026)
  • It’s kept only for reference, research, or recordkeeping (not active use)
  • The content location is clearly identified as “archived”
  • It has not been modified since being archived

If any of these are untrue (for example: the content gets updated, is linked from primary pages in a way users depend on, or provides access to services), then the content must meet version 2.1 AA of the Web Content Accessibility Guidelines (WCAG) requirements.

III. What Does “Retained Exclusively for Reference, Research, or Recordkeeping” Mean?

Examples of content that fall under this definition include employee training videos, homework assignments, exams, and research projects created before April 24, 2026, and no longer in use. This term does not include any content in current use for a class, other active academic project, or employee activity.

IV. What Identification is Necessary to Designate Archived Web Content?

Use an identifier that allows people with disabilities to easily detect when there is inaccessible content. A plain text message at an archive’s entry point is usually sufficient. UCOP suggests using the following language:

  • This section contains archived content made available for reference, research, or recordkeeping purposes. These materials are not actively maintained and may not meet current accessibility standards, such as WCAG 2.1 Level AA. If you need assistance accessing this content or require an accessible format, please contact [insert contact information]. We are committed to ensuring access for all users and will provide accommodations promptly upon request.

V. How to Decide If Web Content Is Eligible for the Archived Web Content Exception Should Remain Online?

The following criteria will help evaluate the utility of web content eligible for archiving. These criteria do not come from any law or regulation, and are only offered as a helpful tool.

The first question to ask is if the content is still relevant and useful for learning or working. If not, the recommendation is to take the content offline.

If the answer to this question is “Yes,” the following questions may help decide if the information should remain online as archived web content:

  • Is it research that has educational value for students, employees, or members of the public?
  • Does it provide important historical context that explains the purpose, evolution, or significant achievement of a program, service, or activity?

A “Yes” to either question may justify keeping the content online. It is also important to consider that people with disabilities deserve the same level of access to the wealth of UC resources, whether or not the law requires it. Remediating archived web content as time and resources allow is highly recommended.

VI. What is the Process for Designating Web Content as Archived?

The recommended process is as follows:

  • Whenever technically feasible, place the UCOP language written in Question IV at the entry point to any archived web content. For example, if linking to an archived webpage, place the UCOP language so that it clearly identifies the link as the gateway to inaccessible content.
  • When using this language is not technically feasible, select a method that:
    • Allows people with disabilities to easily detect when there is inaccessible content; and
    • Prevents archived web content from causing accessibility barriers for content required to be compliant.
  • Standardize this conduct throughout your department by writing a formal process for identifying archived web content. Publicize and socialize this process.

UCOP’s Frequently Asked Questions about digital accessibility also addresses archived web content. Please contact the ADA Coordinator with any questions about archived web content exceptions.

Remember that any web content created and uploaded after April 24, 2026 must be compliant with WCAG 2.1 Level AA.