If My Website Isn't Hosted by UCSF, Do I Still Have to Make it Digitally Accessible?

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Overview

UCSF website owners and content managers sometimes assume that moving a website off UCSF infrastructure—or hosting it on an independently owned domain—removes institutional accessibility requirements. This is not the case.

Introduction

A website must meet accessibility requirements if it is connected to, supports, or represents UCSF programs, services, or activities. This applies regardless of whether the site is:

  • Hosted on UCSF servers
  • Managed by a third party
  • Published under a non-UCSF domain

When Accessibility Requirements Still Apply

A website is considered part of UCSF’s programmatic activity if it includes indicators such as:

  • References to UCSF programs, departments, or initiatives
  • Identification of individuals in their current UCSF roles
  • Content presenting or supporting UCSF research, education, clinical care, or public service
  • Use of UCSF branding or implied institutional affiliation

If any of these are present, the site is likely subject to ADA Title II accessibility requirements.

Common Misconceptions

If I move my site off UCSF infrastructure, accessibility rules no longer apply.
Not correct. Hosting location does not determine compliance obligations. According to the IT Operating Model, website hosting services fall under Model 1: Core Systems, Shared IT Environments, IT Infrastructure and Associated Services.

If the domain is privately owned, it’s not a UCSF site.
Not necessarily. If the content supports UCSF activities, accessibility requirements still apply.

Redirecting from a UCSF website removes responsibility.
No. Redirecting users from UCSF domains to external, non-compliant content may increase institutional risk, as UCSF is still directing users to that content.

Exceptions and Limitations

There are limited, narrow exceptions under the ADA Title II Ruling. 

  • Exceptions are evaluated and granted by Deborah Ohiomoba, Associate Director & ADA/504 Coordinator, Office for the Prevention of Harassment and Discrimination, [email protected]. This is your contact for inquiries if content meets an exception.

Does an approved exception expire?

  • Yes. Initial exceptions are approved for a two-year duration. Renewals for exceptions are required every two years thereafter. Throughout the initial two-year exception period, the individual(s) responsible for Exceptions Coordination, or their Designee, must regularly communicate with the department that was granted an exception to ensure there is meaningful progress toward making the excepted IT Accessible via a remediation plan, as described in the Policy, Section V.C.4.c.
  • Source: UCOP's Accessibility Frequently Asked Questions #13.

Recommended Next Steps

If you manage or are planning to move a UCSF-related website:

  1. Evaluate affiliation.
Determine whether the site supports or represents UCSF activities.
  2. Ensure the site meets accessibility standards (e.g., WCAG compliance).
  3. Do not assume linking to external content removes responsibility.
  4. Reach out for consultation if you believe specific content may qualify for limited exceptions.

Moving a website off UCSF infrastructure does not remove ADA Title II accessibility obligations if the site continues to support UCSF programs or activities. Accessibility requirements are based on function and affiliation, not hosting location.

When in doubt, treat the site as subject to UCSF accessibility standards and seek guidance early.

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