In April 2024, ADA Title II was updated with new guidelines for archiving older web content. To be considered archived, content must meet certain requirements. Archived content does not have to follow accessibility standards. Learn more: ADA Fact Sheet: Archived Web Content
What is considered “web content”?
Web content is defined as anything you can experience on the web. This includes web pages, videos, documents, images, audio files, and apps.
What must be accessible?
Any web content people use to apply for, gain access to, or take part in your services, programs, or activities must be accessible and meet WCAG 2.1 AA standards by April 24, 2026. This applies to all content, no matter when it was made.
Examples of items that must be accessible:
- Forms that are used to request services or fulfill requirements.
- Web page describing an upcoming event.
- Class schedule.
- Course syllabus or assignments.
- A calendar of important upcoming dates.
- Website that provides information about an academic program for prospective students.
- A PDF that describes the steps to apply for a degree program.
What can be archived?
If someone requests that a document be made accessible for their use, it must be remediated promptly.
You don’t have to fix web content that has been archived. But for your content to count as ‘archived,’ the Department of Justice says it must meet four conditions:
- The content was created before April 24, 2026, AND
- The content is kept only for reference, research, or recordkeeping, AND
- The content is kept in a special area for archived content, AND
- The content has not been changed since it was archived.
If any one of these conditions are not met, the content must meet WCAG 2.1 AA requirements.
Examples of items that might be able to be archieved:
- A website for an event that happened in 2017
- A collection of data spreadsheets from sampling that occurred in 2010-2020.
- A collection of PDF newsletters that were emailed before 2026.
- A website about a specialty topic that was launched in 2001 and is no longer updated or maintained, and is not currently used for program access or participation.
How do I set up an archive?
Websites and HTML content
You must create a sub-directory on your site called "archive" and store all of your archived content in that sub-directory.
An example of an archive sub-directory might look like this:
→ example.berkeley.edu/archive
If you alter or update your archived content, it can no longer remain in the archive sub-directory and must be made fully accessible. Content that is not archived must be made accessible.
PDFs and other digital documents
PDFs and other digital documents can either be archived in a subdirectory, the same as websites and HTML content, or can be archived using Box.
Learn more about using Box to archive digital documents.
Historic physical media
Historic physical media (like paper documents or floppy disks) that were created before April 24, 2026 may be converted to a modern file type after April 24, 2026 and archived based on their original creation date.
The modern file type must be made accessible if it is used to apply for, access, or participate in a service, program, or activity. If they are edited or updated, they must be made fully accessible.
FAQs
Can I edit documents or web pages in the archive?
Yes, but once you edit and post a web page or document, it must be accessible.
If you need to update the information, that usually means it’s still important for people to access your program. When you edit something, it’s treated like a new document, starting a new date of creation if done after April 24, 2026.
Updating metadata or removing personal information from archived content isn’t considered editing in this context. These changes are allowed for archived content.
Do my personalized documents need to be accessible?
Individualized, password-protected documents are not required to be accessible. This might include student transcripts, personal Google docs, or student billing statements.
What if someone asks for an archived document to be made accessible?
It must be fixed promptly. Regardless of how long the archived content has been stored, the age of the archived content, or how complex the document is, if someone makes a request to your department or unit for a document to be remediated, you MUST make the document accessible as soon as possible. There are some edge cases, so if you have questions about your content, please email improving-accessibility@berkeley.edu.
If I put a new document straight into the web archive, do I have to make it accessible?
If it was created after April 24, 2026, yes. All new documents must be accessible, even if you put them directly into the archive section of your website.
If I edit a document in the archive and make it accessible, is it OK if it still lives in the archive?
Yes. However, we strongly recommend that you change the file name and add a notation to the footer or metadata to note that it is accessible. This lets everyone know that the document has been remediated.
Can I start the archiving process while we are still in the Consent Decree?
Yes. Putting these practices in place as early as possible will help meet the new ADA law requirements by the April 24, 2026 deadline and make the transition easier.