What Counts as Archived Content Under the ADA Web Rule?

The Department of Justice's 2024 ADA Title II web accessibility rule introduced several exceptions to its WCAG 2.1 AA compliance requirements. One of the most commonly misunderstood exceptions is for archived web content.

Many institutions wrongly assume that labeling content as "archived" will automatically exempt it from accessibility requirements. Unfortunately, that is not the case, making it important to understand what falls under the exception and what does not.

What Is Archived Content?

According to the ADA web rule, content must meet certain criteria to qualify as archived web content. Simply labeling a webpage, PDF, or catalog as "archived" does not make it exempt.

To qualify, archived content must:

• Have been created before your institution's ADA compliance deadline
• Be kept only for reference, research, or recordkeeping purposes
• Be kept in a dedicated archive area
• Not be altered or updated after it is archived

If any of these conditions are not met, the content may still be subject to the ADA's accessibility requirements.

What Does Not Count as Archived Content?

A common misconception is that older content automatically becomes archived content. However, the DOJ has emphasized that content does not qualify simply because it is labeled "archived." For example, the following content likely will not qualify for the archived content exception:

• A course catalog from a previous academic year that students still regularly reference
• Archived policies that still impact current policies
• Catalog pages that are still updated with new information

In these cases, institutions should not assume the content is exempt from WCAG accessibility standards. Older content may still need to remain accessible if it is actively used, has been updated after archiving, or is not stored in a true archive area.

Why This Matters for Higher Education

For colleges and universities, determining what qualifies as archived content can be challenging. Institutions often keep years of catalogs, handbooks, policies, and curriculum documents online. Some of these materials are purely for recordkeeping, while others remain active resources for current students, faculty, and staff.

Since the archived content exception is so specific, institutions should carefully evaluate whether older content truly meets the criteria before assuming it is exempt from ADA requirements. Now is a great time to review old catalog content, determine what truly qualifies as archived, and develop a plan for ensuring current content remains accessible to all users.

This process is also a great opportunity for institutions to better organize their online publications. With Clean Catalog software, institutions can create dedicated archival sections within their course catalog, handbook, or curriculum site to keep old content separate from active content. By clearly separating archived records from current information, schools can improve the student experience, simplify content management for staff, and better support compliance with ADA regulations.

If you are reviewing old catalogs or planning how to structure historical publications, our post on archiving previous course catalogs offers more background on how Clean Catalog helps institutions keep past catalog versions organized and easy to reference.