Frequently Asked Questions

Archive Policy

What is a Legacy Archive under ADA Title II?

Under ADA Title II (updated April 2024), archived content is exempt from WCAG 2.1 AA requirements if all of the following conditions are met:

  1. Content was archived before April 24, 2026
  2. Content is kept only for Reference, Research, or Recordkeeping
  3. Content is kept in a special archive area (/archive-registry subdirectory)
  4. Content has not been changed since archived

If a Legacy Archive is modified after the deadline, the ADA exemption is automatically voided.

The Digital Asset Inventory enforces these conditions:

  • The archive date is recorded and immutable once set
  • Archive reason must be Reference, Research, or Recordkeeping (or a custom reason documented for audit)
  • Archived content is served through the /archive-registry path
  • File integrity is verified via SHA-256 checksum; any modification triggers automatic voiding
  • Edited manual entries (pages/URLs) are automatically voided when saved

Content archived after the deadline is classified as a General Archive and does not claim an ADA exemption.

What is a General Archive?

Content archived after April 24, 2026 is classified as a General Archive:

  • Retained for Reference, Research, or Recordkeeping purposes
  • Does not claim ADA Title II accessibility exemption
  • Available in the public Archive Registry for reference
  • If modified after archiving, removed from public view and flagged for audit

Important: If someone requests that an archived document be made accessible, it must be remediated promptly. Archiving removes the obligation to fix everything in advance, but it does not remove the responsibility to accommodate users with disabilities upon request.

See What's the difference between Legacy and General Archive? for a side-by-side comparison.

Does "old" automatically mean "archived"?

No.

A file is only archived when it is intentionally archived and removed from active use.

If a document is still linked from a current page, it is considered active and must meet accessibility requirements.

Can I move non-compliant PDFs into an "Archive" folder to avoid fixing them?

No.

A file is only considered archived when:

  • It is no longer linked from active pages
  • It is recorded in the Archive Registry
  • It is kept only for reference or recordkeeping

Simply placing a file in a folder called "archive" does not qualify.

If I fix a typo in an archived document, do I have to make it accessible?

Yes.

Any change means the document is no longer an untouched historical record and must meet current accessibility standards.

What happens if someone with a disability requests access to an archived document?

You must provide an accessible or alternative format upon request.

Archiving removes the need to fix everything in advance, but it does not remove the responsibility to accommodate users.

Does the archive interface itself need to be WCAG compliant?

Yes.

Archive pages, lists, filters, and navigation must meet accessibility standards. Only the archived documents themselves may be exempt.

What is "zombie content" and why is it a problem?

Zombie content is archived material that becomes active again.

This happens when an archived file is linked from a current page. Once linked, it must meet accessibility requirements.

Is a file behind a login exempt from accessibility requirements?

No.

Login protection does not remove accessibility obligations. If people rely on the content for work, training, or services, it must be accessible.