Overview
Remove unused content whenever possible—archiving only when truly necessary helps reduce accessibility risk and compliance burden.
As the University of California prepares to meet new federal accessibility requirements, many site owners are asking what they can do with older or outdated digital content. One option that often comes up is archiving, but what does that actually mean, and when is it appropriate?
What Archive Means under the ADA Title II Ruling
Archiving web content means moving older or inactive materials to a designated area of your website for long-term storage and reference. Archived content is not actively updated or maintained, and typically includes documents, reports, videos, or web pages that are still relevant to services, programs, and activities that UCSF offers online and through mobile apps.
Consider Removal Before Keeping as Archive Content
If content is no longer in use, removing it is often the best option. Deleting outdated or redundant material reduces accessibility risk, simplifies site maintenance, and improves the user experience.
Archiving should only be considered if the content is still relevant to services, programs, and activities that UCSF offers online and through mobile apps. Anything that remains live and public, even if infrequently accessed, must still meet accessibility standards unless it fully qualifies for the archive exception.
When Archived Content Is Exempt from Accessibility Requirements
Under the ADA’s new web accessibility rule, archived web content may be exempt from WCAG 2.1 Level A and AA compliance, but only if it meets all four conditions below:
- Created before April 24, 2026, or reproduces materials created before that date (such as scanned paper documents or media like audiotapes or film);
- Kept only for reference, research, or recordkeeping;
- Organized and stored in a clearly defined “archive” section of the website; and
- Not modified or updated after the date of archiving.
If any of these conditions are not met, the content must comply with WCAG 2.1 Level A and AA standards unless another exception applies.
Example: A 2001 annual report stored in a dedicated “Archive” section that has not been updated would generally meet the exception. But if that same report has been modified, it would likely need to meet accessibility requirements.
Accessibility Obligations Still Apply
Even when content qualifies for the archive exception, the ADA still requires effective communication for individuals with disabilities. If someone requests access to archived content, the university must provide it in an accessible format.
Example: If a user requests an archived video, one way to provide equal access might be to add captions and share the captioned version with that person.
Get Guidance Before You Archive
Questions about whether specific content can be considered archive material should be directed to Deborah Ohiomoba, Associate Director & ADA/504 Coordinator, Office for the Prevention of Harassment and Discrimination, [email protected]. The rules can be narrow, nuanced, and the Archive Exception may not always be appropriate.
You can also join UCOP's Legal Office Hours to discuss the new federal rules and their legal implications.