Digital documents used at U-M are required to meet recognized accessibility standards by the compliance date and after.
However, some digital documents that were created before that date, are not actively used, and meet certain requirements may be considered an exception, as described below.
Conventional Electronic Documents are defined in the Department of Justice's Title II regulations as “web content or content in mobile apps that is in the following electronic file formats: portable document formats, word processor file formats, presentation file formats, and spreadsheet file formats.” (Paragraph 263). These formats may include Word documents, PowerPoints, Google Documents, Google Sheets, and PDFs.
In general, the university is required to make Conventional Electronic Documents accessible if the documents are used as part of a program, service, or activity.
However, the new Title II regulations provide two exceptions related to Conventional Electronic Documents. Units that leverage these two exceptions may still be required to provide these documents in an accessible format upon request (Paragraph 805).
Conventional Electronic Documents should be made accessible according to the Web Content Accessibility Guidelines 2.1 (WCAG 2.1). Refer to how to make content accessible for tips and best practices for meeting WCAG 2.1 in documents.
Exception Requirements
Only Conventional Electronic Documents that meet specific exceptions, described below, are not required to be accessible.
Conventional Electronic Document Exception 1
The first exception is described in Section 35.201 b of the updated regulation. This exception is for Preexisting Conventional Electronic Documents.
Preexisting Conventional Electronic Documents are not required to be accessible if they meet ALL of the following requirements:
- The documents were created prior to the compliance date, AND
- The documents are not currently used to apply for, gain access to or participate in University of Michigan programs, services, or activities (Paragraph 34).
If documents are currently used as part of a program, service, activity then they should be made accessible.
Conventional Electronic Document Exception 2
The second exception is described in Section 35.201 d of the updated regulation. This exception is for Individualized, password-protected or otherwise secured conventional electronic documents.
Conventional Electronic Documents (even if created after the compliance date) are also not required to be accessible if the documents meet ALL of the following requirements:
- The documents are word processing, presentation, PDF, or spreadsheet files, AND
- The documents are about a specific person, property, or account, AND
- The documents are password-protected or otherwise secured.
This exception does not cover password-protected content in this category that is web content created in HTML.
Recommendations for Meeting Requirements
WCAG 2.1 AA contains recommended practices users may apply to document creation.
While there are some exceptions for Conventional Electronic Documents, they oftentimes must be provided in an accessible manner. Maintaining documents in their original or in more accessible formats generally will yield the highest accessibility. Oftentimes creating PDF documents in an accessible way may be challenging, especially if those documents are edited periodically. The Use of PDF guidance includes a decision tree for when to post as a PDF.
Accommodations & Requests
Even if certain documents meet an exception, they must still be made accessible when requested by a user who needs an accessible format. Units should be prepared to respond to requests by having a clear, actionable process in place to provide accessible versions of archived materials.
Examples
- A PDF accessed on a password-protected website which displays a bill for a specific user’s account may not need to be made accessible.
- A Word document posted to a password-protected website containing details about an individual’s selected time off may not need to be accessible.