Meeting (and Exceeding) Digital Accessibility Standards

Understanding WCAG 2.1 Level AA and the 2026 Deadline

By now, higher ed professionals are well aware of Web Content Accessibility Guidelines (WCAG), an internationally recognized set of standards published by the W3C . Version 2.1, Level AA, includes requirements across four core principles: Perceivable, Operable, Understandable, and Robust (POUR). Specifically, Level AA mandates:

• Text alternatives (e.g., alt text for images)
• Captions and transcripts for multimedia
• Navigable content (keyboard focus indicators, skip links)
• Consistent UI elements and clear labels
• Sufficient contrast ratios for text and interactive elements
• Responsive design to support zoom and screen readers

While various institutions have proactively embraced digital accessibility, many campuses still rely on a patchwork of PDFs, older HTML pages, and LMS course shells that predate modern accessibility considerations. In July 2023, the Department of Justice clarified that any public-sector entity—that means you, state colleges, community colleges, and public universities—must achieve WCAG 2.1 Level AA compliance by April 2026. That effectively leaves institutions with fewer than two calendar years to:

• Inventory every digital asset: websites, PDFs, Word docs, PowerPoints, and LMS courses
• Assess each asset’s current accessibility level
• Remediate or retire content that fails Level AA criteria
• Document processes and produce compliance evidence for potential audits

Without a strategic approach, this can balloon into a multiyear, multi-million-dollar project, putting a strain on already thin budgets and staff resources. But when prioritized intelligently, meeting accessibility standards becomes achievable, even within the timeline and budget constraints most campuses face.

The Challenge of Aging LMS Content

While public-facing websites garner significant attention, LMS environments often represent the most extensive body of instructional material. Instructors accumulate course shells semester after semester, all containing a seemingly endless number of:

• Syllabi, assignments, and quizzes in PDF or Word format (often not tagged for accessibility)
• Embedded images, videos, and external links—many lacking captions, alt text, or proper headings
• Discussion boards, group pages, and archived student work, some of which may include untagged PDFs or charts

For example, UC Riverside discovered that its Canvas instance contained thousands of course shells dating back five or more years. While many of those older courses were inactive, they still lived in the LMS—visible to assistive-technology users and subject to DOJ scrutiny and, therefore, posing a compliance risk. According to a March 2025 EDUCAUSE article, LMS Archiving: Fast-Tracking WCAG Compliance at UC Riverside , archiving outdated courses allowed them to reduce their remediation scope by over 60% in just a few months, freeing instructional designers to focus on updating active course content rather than performing costly retrofits on aging materials.

Similarly, the College of Southern Nevada (CSN) estimated that fully remediating every historical course in its LMS would have cost nearly $20 million in staff time and vendor fees. CSN’s decision to archive legacy courses saved $19.7 million, reduced its LMS footprint, and focused its accessibility team on current, high-enrollment courses—achieving compliant status in record time.

Archiving as a Strategic Compliance Accelerator

At its core, archiving course content is not a way to circumvent accessibility obligations but a strategic method to achieve compliance faster. Here’s how:

1. Triage Over Total Remediation
   Instead of allocating resources equally across every LMS shell—old and new—archiving allows you to “retire” low-engagement, outdated courses into a secure, WCAG-friendly archive. By doing so, you reduce the overall volume of content requiring remediation, concentrating your budget and staff on courses that impact current student learning.
2. Clarify Compliance Scope
   Once legacy courses are archived, you know exactly which courses remain active and in need of evaluation. This clarity helps you set realistic timelines, budget accurately, and report progress to leadership with concrete metrics (e.g., “X number of current courses reach Level AA, Y remaining on schedule”).
3. Preserve Institutional Memory
   Archived courses remain searchable and retrievable for faculty and accreditation purposes. They’re not deleted; they’re simply moved out of the live LMS environment and stored in a dedicated archive, a format that meets WCAG 2.1 standards—ensuring compliance while preserving content for legal, audit, or historical reference.
4. Reduce Ongoing Maintenance
   Decreasing the LMS footprint means fewer shells to update, fewer courses to monitor for new accessibility issues each semester, and overall streamlined operations for instructional designers and IT teams.

Simply put, leveraging data archiving properly allows you to both reallocate remediation dollars toward courses that impact today’s students and accelerate your timeline to meeting the 2026 deadline.

Building an Accessible Future: Beyond Compliance

While meeting the DOJ’s WCAG 2.1 Level AA deadline is critical, the ultimate goal should be exceeding minimum standards and fostering a culture of true digital inclusion. To achieve that, consider these next steps:

1. Train Faculty and Staff on Accessible Course Design: Host regular workshops on creating accessible documents (proper heading structures, descriptive link text, alt tags) and recording captioned videos. When faculty build accessible content from the start, you minimize remediation needs over time.
2. Implement Ongoing Audits: Even after the 2026 deadline, establish quarterly or biannual audits of active courses and web pages. Tools like automated accessibility scanners can flag new issues early, preventing backlogs.
3. Enrich Archival Metadata: Enhance archived course records with context—mapping archived materials to historical accreditation reviews, program evaluations, or digital preservation requirements. This adds long-term research value and institutional memory.
4. Integrate Accessibility into Change Management: Whenever you upgrade your LMS, switch to a new CMS, or roll out a new classroom technology, ensure accessibility checks are part of the project plan. Embedding these practices in standard IT workflows prevents compliance lapses.

The 2026 WCAG 2.1 Level AA deadline represents a pivotal moment for higher education. Rather than viewing it as a burdensome checkbox, campus leaders can see it as an opportunity to reimagine digital learning for all students. When you make data archiving a part of your broader accessibility strategy, you’re not just checking off a legal requirement—you’re creating an environment where all learners, regardless of ability, can engage, succeed, and thriving environments where every student, regardless of ability, can engage fully and succeed.

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Contact K16 Solutions today to see Scaffold Archiving in Action

Learn more about how we’re helping institutions solve their biggest challenges around migrating, archiving, and aggregating and analyzing their data by exploring our Resources library for case studies, best-practice guides, and recorded webinars.