Title II Update
In April 2024, the U.S. Department of Justice finalized updates to Title II of the Americans with Disabilities Act (ADA). These updates require state and local government entities to ensure their web content and mobile applications meet Web Content Accessibility Guidelines (WCAG) 2.1, Level AA.
These requirements apply to all web-hosted content and mobile applications used to deliver programs, services and activities.
For institutions within the California State University system, including Cal State Monterey Bay, the original deadline set by the Department of Justice was April 24, 2026. Recently, the compliance deadline has been extended to April 26, 2027.
This extension does not change Cal State Monterey Bay's accessibility responsibilities or internal deadlines. Our institution will proceed with digital accessibility efforts as planned. The extension means that we have time to strengthen the quality, consistency and sustainability of the work that is already underway.
Learn More:
What This Means
The updated rule requires accessibility for all digital content used to deliver university programs, services and activities, including:
- Websites and web applications, including posted documents
- Mobile apps, including content accessed on phones, tablets and other devices
- Digital course materials, such as videos, online textbooks and learning management systems
- Social media content, including attached documents (but not the platforms themselves)
Key Definitions
- Web Content
All information presented online, including text, images, audio, video, animations and interactive elements.
- Electronic Documents
Common file types such as PDFs (.pdf), Word documents (.docx), presentations (.pptx) and spreadsheets (.xlsx).
- Mobile Applications
Software designed for mobile devices, including apps accessed through app stores or web browsers.
Exceptions
Some content may be exempt from these requirements under specific conditions.
- Archived Web Content
Content that is at least three years old, clearly labeled as archived, and maintained only for reference or record-keeping. Archived content must be stored in a designated section and not modified.
- Archived Documents
Older PDFs and files that are no longer needed to access current programs, services or activities. If a document still supports active services, instruction or engagement, it must be accessible.
- Third-Party Content
Content created and posted by external users without a formal agreement with the university (such as public comment areas).
- Password-Protected Documents
Files intended for individual access only, such as billing statements or transcripts.
- Existing Social Media Posts
Posts published before April 24, 2026, do not need to be updated.
Note: For full details on exceptions, refer to the Department of Justice Title II Fact Sheet.
Archived Content Guidelines
Files and web pages created before April 24, 2027 may be archived for historical reference. Some archived content does not need to meet WCAG 2.1. AA guidelines. In order to qualify for this exemption, archived documents must meet ALL of the following four criteria:
- The content was created before the date the state or local government must comply with this rule, or reproduces paper documents or the contents of other physical media (audiotapes, film negatives, and CD-ROMs for example) that were created before the government must comply with this rule, AND
- The content is kept only for reference, research, or recordkeeping, AND
- The content is kept in a special area for archived content, AND
- The content has not been changed since it was archived.
-Source: Title II Fact Sheet, ada.gov
*Note: The exemption generally does not apply to documents or information that is current.
Examples of Content that meets the exemption:
- Meeting minutes posted before April 24, 2027
- Copies of newsletters preserved from the past 50 years.
- Tax documents from previous years required to be posted to the website, that do not carry current data from the institution.
Examples of content that does NOT meet the exemption:
- A campus map has been created prior to the April 24th, 2027 deadline and has not been edited since. However, it is the most recent campus map and carries current information required by students, faculty, staff, and visitors to access the campus.
- Archived newsletters that were posted prior to April 24, 2027 deadline are refreshed to better reflect campus branding. The new versions would need to meet accessibility guidelines despite being placed back in the archive.
Labeling Archived Content
Archived content should be labeled clearly and accurately.
For a single document:
- Include “Archive” in the file link/name, or in the name of the Page.
For a large group of documents:
- Create a page with “Archive” in the title that houses all archived documents, OR
- Place archived documents under a separate section on the page, including “Archive” in the heading text.
Accessible Copies By Request
The institution is still required to provide equitable access to documents that are archived upon request. Determine an appropriate contact for accessibility requests regarding the information on your page. Then, post the following notice to any of your archive sections or pages:
“Files [on this page/in this section] are for historic reference. If you need an accessible version, please contact [contact information]”
