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Title II of the Americans with Disabilities (ADA) Act mandates that all public entities provide equal access to information, services and programs for individuals with disabilities. This requirement extends to digital communications — web and mobile applications — which must adhere to the Web Content Accessibility Guidelines (WCAG) Version 2.1, Level AA standards.

To uphold this commitment to digital accessibility, the University of California established the Information Management and Technology Policy 1300 (IMT-1300). The policy requires all UC institutions and programs to comply with the WCAG 2.1 AA accessibility standards across all information technologies, including, but not limited to, websites, videos, online course materials and documents, mobile applications and software systems.

While IMT-1300 has been in place for years, the University of California’s Office of the President is now taking additional measures to ensure all UC institutions and programs fully comply with the IMT-1300 policy by the United States Department of Justice’s ADA Title II compliance deadline of April 24, 2026.

The approaching deadline allows us to focus on fostering an equitable digital landscape that addresses our community's diverse needs and ensures unobstructed access to digital content and information technologies.

There are several ways to ensure that your content is accessible. Please refer to the guidelines and tips below as you work to adjust current digital content and create new content.

NOTE: If you are actively working with a vendor to build or manage your digital content (websites, videos, graphics), please share these guidelines with them so you can work together to reach compliance.

There are five exceptions to the ADA Title II requirements for web and mobile app accessibility. These exceptions apply to content that is no longer in active use, is non-public, or is managed by a third party.

1. Archived web content
This includes content that is no longer in use and is maintained strictly as a reference or historical record. 

2. Pre-existing electronic documents
This includes PDFs, word processing documents and presentation files that are already on the web. You are not required to remediate these documents for accessibility if they meet two primary conditions:

  • Not In Use: The document is no longer active, in use or necessary for the public to participate or benefit from the information.
  • Clearly Labeled: The document must be clearly labeled, grouped and categorized as archived content within a dedicated "Archive" section of your site to confirm it is not actively being used. 

Compliance is immediately triggered if the legacy content is touched or moved:

  • Modification: The document is changed or edited in any way after the accessibility compliance deadline.
  • Reorganization: The document is moved, relabeled or reorganized into a public-facing section that is not clearly designated as an archive.

Note: Once the compliance date has passed, all current in-use and new documents must meet WCAG 2.1, Level AA requirements.

See Action Step 6: Refresh your understanding of the rule's exceptions to learn more about what may qualify for an exception.

3. Third-Party Content (Independent)
This exception applies to content posted by a third party on a website or mobile application where that party is acting independently of the university. This means the content is not posted under a contractual or licensing agreement, and it does not provide direct information or access to university programs and services.

Example: A national news publication posts a story about a faculty member's research on its external website. Since this content is created and controlled entirely by the third party, it is excluded from the university's requirement to meet WCAG 2.1 standards.

4. Password-protected files
Documents must meet all three stipulations to be excluded:

  1. The documents are Word processing, presentation, PDF or spreadsheet files
  2. They are about a specific person, property or account
  3. The files are secured by password protection

5. Pre-existing social posts
Any content published before the April 24, 2026, compliance deadline is excluded.

Connect with Us

The UC Irvine School of Medicine Communications & Public Relations Office is here to support efforts to achieve digital accessibility compliance by the April 24, 2026 deadline. If you have any questions or concerns or need assistance, please email us at somweb@hs.uci.edu.

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