Digital Accessibility Exceptions at the University of Northern Iowa

Federal accessibility regulations recognize very limited exceptions to WCAG 2.1 AA requirements. These exceptions apply only in specific circumstances defined by law and do not remove the university’s responsibility to provide access or accommodations when needed.

Accessibility exceptions are permitted only in very limited circumstances:

• Exceptions are expected to be rare
• Most content does not qualify for an exception
• Exceptions do not eliminate the obligation to provide accommodations or alternative access
• Accessibility should be addressed through remediation whenever feasible

An exception may be considered only when full accessibility cannot be achieved due to an undue burden, would result in a fundamental alteration to the nature of a program, service, or activity, or when an accessible version of specific materials does not exist.

Exceptions will be documented and reviewed through a university process defined as part of UNI’s digital accessibility governance structure. Federal regulations also recognize limited exceptions for certain archived content that is not used for current instruction or communication. 

Units should focus on remediation first and consult IT via Service Hub in the unlikely event an exception is warranted. 

Archived Web Content

Federal accessibility regulations include a limited exception for archived web content.

Web content must meet all four of the following criteria to qualify as archived:

1. The content was created before April 24, 2026
2. The content is kept only for reference, research, or record-keeping purposes
   • If the content is used for a current university program, service, or activity, it does not qualify
3. The content is stored in a clearly identified archived location
4. The content has not been altered or updated since being archived

If all four criteria are met, the content does not require proactive remediation to WCAG 2.1 AA.

Examples

• A university website includes an article from 1997 in a clearly marked archive section. The article qualifies as archived content.
• A grant-funded project website that ended in 2025 and is clearly labeled as archived qualifies for the exception.
• Archived research data created before April 24, 2026 and stored in a designated archive qualifies for the exception.

If archived material is reused for a current course, event, or program, the archived exception no longer applies, and the material must be accessible.

Accommodation reminder

Even when content qualifies as archived, if someone with a disability requests access, the university must provide an accessible version or an equally effective alternative.

Conforming Alternate Versions

When it is not possible to make web content accessible due to technical or legal limitations, a public entity may provide a conforming alternate version of the web content.

• Technical limitations beyond the university’s control
• Legal restrictions that prevent modification

A conforming alternate version is a separate, accessible version of web content that is current and contains the same information and functionality as the inaccessible web content.

Conforming alternate versions should be used only when remediation is not possible, not as a substitute for building accessible content.

Examples

• A legally required document that must remain in a specific inaccessible format may require an accessible alternate version.
• A new technology that cannot yet be made accessible may require a temporary alternate version.

Lack of training, time, or awareness does not qualify as a technical limitation.

What to do if you think an exception may apply

Accessibility exceptions:

• Do not eliminate the obligation to provide accommodations
• Do not apply to new or actively used content
• Do not remove responsibility to improve accessibility when feasible

If you believe your content may qualify for an exception:

• Do not self-approve
• Focus on remediation first whenever possible
• Contact IT through Service Hub

Exceptions minimize remediation burden in limited situations. They do not remove UNI’s responsibility to provide equitable access to its programs and services.