Archived web content
Recent updates to the Americans with Disabilities Act (ADA) require public institutions, including the University of Iowa, to make all digital content, with limited exceptions, conform to the Web Content Accessibility Guidelines (WCAG 2.1 AA) by April 24, 2026.
There is an exception to this requirement for “archived web content.” Web content must meet these four criteria to be considered archived web content.
Does my document need to meet WCAG 2.1AA requirements?
Was the web content created before April 24, 2026?
Is the web content kept only for reference, research, or record keeping? If the content is used to participate in a current UI service, program, or activity, then it does not qualify as archived web content.
Is the web content organized and stored in a dedicated area clearly identified as archived?
Was the web content not altered or updated since being archived?
If yes to all of the above, then the web content is “Archived Web Content” and does not need to meet the WCAG 2.1AA requirements.
Examples
A university website contains an article from 1997 of a faculty member’s ground-breaking research in the archived section of its website. This is article meets the definition of archived web content and does not need to meet the requirements of WCAG 2.1AA. However, if the university decides to create an online exhibition highlighting the 30-year anniversary of that researcher’s work from 1997, the exhibition will not meet the definition of archived web content as it is creating a new program.
Research data in a file that is created before April 24, 2026 and is stored in a clearly marked archive section of an online database meets the definition of archived web content and does not need to meet the requirements of WCAG 2.1AA. However, if the researcher adds new data to that file after April 24, 2026, the file no longer meets the definition of archived web content and must comply with WCAG 2.1AA.
A website from a grant-funded project that ended in 2025 and is clearly marked as archived meets the definition of archived web content and does not need to meet the requirements of WCAG 2.1AA.
A faculty member wishes to use a document from the library’s archives in a current course. Because the archived material is being used for a current university program, the archive exception does not apply, and the material must meet the requirements of WCAG 2.1AA.
Accommodation reminder
Even if web content meets the archived web content exception, if someone with a disability requests access to an archived web content, you must provide the requester with access to an accessible version of the web content.
Pre-existing conventional documents
Recent updates to the Americans with Disabilities Act (ADA) require public institutions, including the University of Iowa, to make all digital content, with limited exceptions, conform to the Web Content Accessibility Guidelines (WCAG 2.1 AA) by April 24, 2026.
There is an exception to this requirement for certain conventional documents that were created before the law goes into effect.
Does my document need to meet WCAG 2.1 AA requirements?
Is the document a word processing file (e.g. Microsoft Word), a presentation file (e.g. Apple Keynote or Microsoft PowerPoint), a PDF, or a spreadsheet file (e.g. Microsoft Excel)?
Was the document available on the university’s website or mobile app before April 24, 2026?
Is the document NOT currently used to apply for, gain access to, or participate in a service, program, or activity of the university?
If yes to all the above, then the document does not need to meet the WCAG 2.1AA requirements.
Examples
A lab website contains a PDF flyer from 2023 recruiting subjects for a now-closed study. This PDF does not need to meet the WCAG 2.1AA requirements, but the lab should consider removing the PDF if it is not necessary.
A lab website contains a PDF flyer from 2023 for a study that is still currently recruiting subjects. This PDF needs to meet the WCAG 2.1AA requirements, as it is being used for subjects to apply for a university program.
A researcher stores data from 2020 on an electronic database. The researcher cannot rely on the pre-existing conventional documents exception as the electronic database does not meet the necessary document format.
A faculty member gives a PowerPoint presentation on May 15, 2026, and wants to put this PowerPoint on the lab website. This presentation would need to comply with WCAG 2.1AA because it was posted after April 24, 2026.
Accommodation reminder
Even if web content meets the Pre-Existing Conventional Documents exception, if someone with a disability requests access to this content, you must provide the requester with access to an accessible version of the web content.
Individualized, password-protected conventional electronic documents
Recent updates to the Americans with Disabilities Act (ADA) require public institutions, including the University of Iowa, to make all digital content, with limited exceptions, conform to the Web Content Accessibility Guidelines (WCAG 2.1 AA) by April 24, 2026.
There is an exception to this requirement for conventional documents that are created for a specific person.
Does my document need to meet WCAG 2.1 AA requirements?
Is the document a word processing file (e.g. Microsoft Word), a presentation file (e.g. Apple Keynote or Microsoft PowerPoint), a PDF, or a spreadsheet file (e.g. Microsoft Excel)?
Is the document about a specific person, property, or account?
Is the document password-protected or otherwise secured?
If yes to all the above, then the document does not need to meet the WCAG 2.1AA requirements.
Examples
A study team has a secure online system that requires study subjects use a password to access the system and then generate a PDF containing their study data. The PDF does not need to meet the WCAG 2.1AA requirements, unless the study subject requests that the PDF be provided in an accessible format.
A PDF version of a student’s or alumni’s transcript on a password-protected website does not need to meet the WCAG 2.1AA requirements, unless an accessible document is requested.
Third-party content
Recent updates to the Americans with Disabilities Act (ADA) require public institutions, including the University of Iowa, to make all digital content, with limited exceptions, conform to the Web Content Accessibility Guidelines (WCAG 2.1 AA) by April 24, 2026.
There is an exception for some content that is created by individuals outside of the University of Iowa.
Does web content created by someone else need to meet WCAG 2.1 AA requirements?
Was the web content posted by a third-party on a university website or mobile app?
Was the web content not posted due to a contractual, licensing, or other arrangement with the university?
If yes to all the above, then the web content created by the third party does not need to meet the WCAG 2.1AA requirements.
Contractual, licensing or other arrangements
Third-party digital content and digital services that are provided or made available through contractual, licensing, or other arrangements with the university must meet WCAG 2.1AA requirements, just as it would if the university created the content or services. The university may not delegate away its obligations under the ADA. If the university relies on a contractor or another third party to post content on the public entity’s behalf, the public entity retains responsibility for ensuring the accessibility of that content.
Examples
A department creates an accessible post on social media highlighting a faculty member’s recent award. The department’s post must comply with WCAG 2.1AA, but comments made by members of the public in response to the university’s post are not required to comply with WCAG 2.1AA.
A department hires a web designer to develop and maintain its website. The content created by that the hired web designer would not fall under this exception and must comply with WCAG 2.1AA.
A study team uses a third-party website to conduct surveys for a research study. That website would be a service that the public entity provides through arrangements with a third party, and the website would need to comply with WCAG 2.1AA.
A faculty member’s website includes a link to a journal website that contains their publication. The faculty member must ensure that the link itself is accessible because the link is part of the university’s web content. However, because the journal website is not being provided due to a contractual, licensing, or other arrangement, the faculty member is not responsible for ensuring the journal’s website complies with WCAG 2.1AA.
Accommodation reminder
Even if web content meets the third-party content exception, if someone with a disability requests access to the third party content to access a program, service or activity of the university, the content should be made accessible for the requester.
Conforming alternate version
When it is not possible to make web content accessible due to technical or legal limitations, a public entity may provide a conforming alternate version of the web content.
Technical limitations (e.g., technology is not yet capable of being made accessible).
Legal limitations (e.g., web content that cannot be changed due to legal reasons).
A conforming alternate version is a separate, accessible version of web content that is current and contains the same information and functionality as the inaccessible web content.
Conforming alternate versions should be used rarely—when it is truly not possible to make the content accessible for reasons beyond the public entity’s control.
Examples
A conforming alternate version would not be permissible just because a college’s web developer lacked the knowledge or training needed to make content accessible; this does not meet the definition of a technical limitation.
A researcher could use a conforming alternate version if its web content included a new type of technology that it is not yet possible to make accessible, such as a specific kind of immersive virtual reality environment.
A university unit that is legally required to maintain documents in a specific inaccessible format could claim a legal limitation and the original document would not be required to comply with WCAG 2.1AA. However, the unit would still be required to provide users with a conforming alternate version of the document.