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For those who weren't able to attend the EDCUCAUSE webinar presented by the College of Southern Nevada (CSN), Instructure, and K16 Solutions, you can access the recording here.
CSN discusses how they are using Canvas Archiving powered by K16 Solutions to expedite WCAG 2.1 compliance by archiving 75% of its courses, dramatically reducing the number of courses needing remediation. According to their calculations, they expect to save $19.7M in labor costs.
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Visit k16solutions.com to learn more.
Thanks,
Jason Simmons
Wouldn't moving old courses to "Past Enrollments" also satisfy the exceptions for archived content, while allowing students to still look up their previous grades and work?
Great question @Gabriel33 - moving courses to “Past Enrollments” doesn’t meet WCAG 2.1 standards. That content remains live and accessible, which means your institution is still responsible for its accessibility — even if it’s no longer in active use. Most legacy content includes PDFs, videos, and materials that don’t meet WCAG guidelines, exposing you to legal risk.
“Past Enrollments” also lacks centralized oversight. There's no easy way for admins to search, manage, or ensure compliance across old content.
Canvas Archiving by K16 Solutions solves this by relocating content to a secure, searchable environment outside the LMS. This qualifies as true archival under DOJ rule, reducing compliance burdens while keeping data accessible for audits, records requests, or student inquiries. It’s not just a workaround — it’s a compliant, risk-reducing solution.
Here is a good article on this topic.
I hope that helps. Please reach out if you have any other questions!
Best,
Jason Simmons
K16 Solutions
That students should not have access to the data does not seem to be a requirement, as far as I can see. Indeed, students should still have the right to their records, which K16 doesn't seem to provide (and providing it to students one by one would then require more IT time).
The three exceptions listed in the presentation are:
All of those seem to be satisfied in the past enrollments, as faculty cannot make any edits to content there (at least in my university - I don't know if maybe that's not a default setting), so it is:
Maybe different institutions have different interpretations, and should ask their compliance office about it, but I'm not convinced yet.
Thanks for the thoughtful response — you're absolutely right that students should have access to their academic records, and any archiving solution, including K16’s, must support that. The key distinction here isn’t whether students can access records, but how that access is managed in a compliant, scalable, and low-risk way.
While "Past Enrollments" may seem to meet the spirit of the WCAG archive exceptions, there are a few important gaps:
Although students and faculty can’t edit past courses, the content is still served from the LMS, which is a production environment. WCAG 2.1 guidance — and related legal interpretations — tend to consider anything live in the LMS as "in active use," particularly because it’s hosted on a system designed for active learning. That opens the door to scrutiny over inaccessible materials, even if they're no longer taught.
K16’s Canvas Archiving, by contrast, moves content out of the LMS, clearly separating it from instructional environments. That separation is what makes the “dedicated area” argument bulletproof from a compliance standpoint.
K16’s solution allows institutions to respond to student requests for past grades or coursework without putting the institution at compliance risk by keeping inaccessible course content live in the LMS. Access can be granted securely, and at scale, using search and retrieval tools — far more efficient than navigating Canvas manually.
Even if “Past Enrollments” seems to work today, it scales poorly. There's no central admin visibility, no audit trail, and no ability to manage accessibility exceptions or requests across thousands of courses. K16’s archive is built for governance — searchable, reportable, and defensible.
Totally agree that each institution should consult their compliance office, but from what we’ve seen working with dozens of institutions and legal teams, moving content out of the LMS environment is what gives teams confidence they’re truly covered under the WCAG exception.
Happy to connect you with someone at a peer institution who's made this shift — they might share how it changed their posture around accessibility and governance.
Where in the WCAG 2.1 does it mention LMS or active use? I don't believe the WCAG differentiate between archival and live environments, or mentions exceptions to it applying.
I think you mean the new DoJ rule, which requires compliance with WCAG 2.1 AA, and that rule has some exceptions.
Still, I couldn't find anything there related to content being on the LMS or not, only that it should be labeled as an archive. If you have seen something different, please point me to it.
There's also an exception besides archival for "preexisting conventional electronic documents" (in my second link), which should cover things like PDF lecture slides in an old Canvas course page (you mentioned those in your earlier reply).
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