Accessibility - Conforming Alternate Versions (CAV)

An ADA Title II Digital Accessibility Fact Sheet

Target audience: Faculty; Instructional Designers

Purpose: This resource provides best practices when determining whether a Conforming Alternate Version (CAV) is an appropriate alternative to digital resources that may not meet accessibility standards required under Title II of the ADA. The goal is to ensure access for all students, including those with disabilities.

Disclaimer: This guidance does not constitute formal legal advice. Rather, it is intended to support faculty and staff in aligning their practices with the requirements of ADA Title II compliance.

Legal context

Under the updated Title II regulations of the Americans with Disabilities Act (ADA), digital content must be accessible to all users, including those with disabilities. If the original resource cannot be made accessible due to technical or legal limitations, a conforming alternate version (CAV) may be provided.

Definition

A conforming alternate version (CAV) is an accessible equivalent of digital content—such as a document, webpage, or online form—that meets all the requirements of the WCAG 2.1 Level AA guidelines, contains the same information and functionality as the inaccessible digital content, and can be reached via a conforming page or an accessibility-supported mechanism. For more information see Understanding Conforming Alternate Versions.

You can look at a CAV as a backup version of digital content—like a webpage, document, or online form—that’s fully accessible to people with disabilities. It includes the same information and features as the original, but it’s designed to meet accessibility standards. People can easily find and use it through a link or button that works with assistive technology like screen readers.

Risks and responsibilities

According to the Department of Justice (DOJ), CAVs should be used only when it is truly not possible to make the original content accessible due to technical or legal limitations.

A technical limitation refers to a situation where the technology used to create or deliver content inherently lacks the capability to meet accessibility standards (such as WCAG 2.1 Level AA). Legal limitations may include digitally signed legal documents, scanned legal records or court documents, redacted documents, official forms with legal formatting requirements, and some tax forms and financial disclosures.

CAVs should not be used:

• as a shortcut, to circumvent accessibility compliance,
• to cover for lack of knowledge or training in making content accessible,
• for budget constraints or time limitations, or
• for aesthetic reasons, such as preferring the appearance of the original version over the accessible one.

Use the CAV Decision Tree to help determine if a CAV can be provided and to mitigate compliance risks. Further guidance on using CAVs is provided below.

Requirements and best practices

Requirements of using a CAV

• When using a CAV, you must ensure that individuals with disabilities receive the same benefits and experience, to the maximum extent possible, as those who use the original digital version.

• Ensure the CAV is equivalent in content and functionality to the original digital version. Omitting information or features present in the original digital version can result in students with disabilities receiving an inferior educational experience.
• Clearly link the CAV or make it discoverable from the original digital version so users know the CAV is available and can easily access it. Access to the CAV and the student’s experience while using the CAV should be as similar, to the maximum extent possible, to the experience of a student using the original digital version.
• Make the CAV available at the same time as the original so all students have equivalent access.
• Maintain and update the CAV alongside the original digital content. If the original digital content is changed, the CAV must also reflect those changes.

Best practices when using a CAV

• Design for accessibility first. A CAV should be a last resort, not a shortcut.
• Document the reasons for using a CAV, including limitations of the original resource as well as how you arrived at the determination that a CAV was appropriate. Lack of documentation can create compliance risks.

• Choose a format for the CAV that is compatible with assistive technology. HTML is preferred for accessibility as it is generally more flexible and screen-reader friendly than most common document types.

Examples and limitations

CAVs are permitted only for:

• technical limitations (e.g., a software that is not yet capable of being made accessible, a technology does not yet exist to make it accessible, etc.), or
• legal limitations (e.g., copyright or licensing restrictions, contractual obligations, privacy/security concerns, etc.). Below are some examples of when a CAV could be appropriate.

Examples of appropriate CAVs are shown in the table that follows.

CAV decision tree

There is no internal approval process for using a CAV, Instead, faculty and instructional designers should use the key questions outlined below to help them determine if posting a CAV is reasonable and to help mitigate their risk of noncompliance with federal regulations. Justification or supporting evidence must be documented as outlined in the Best Practices section.

Step 1: Is the original digital content accessible?

✅ Yes; Use the original digital version.
❌ No; Proceed to Step 2.

Step 2: Are there legal or licensing constraints preventing modification of the original digital content?

✅ Yes; Cannot create a CAV; look for an accessible alternative source or provide an equivalent experience by another means.
❌ No; Proceed to Step 3.

Step 3: Is it technically feasible to make the original digital content accessible?

✅ Yes; Remediate the original digital version.
❌ No; Proceed to Step 4.

Step 4: Does the CAV meet WCAG 2.1 Level AA standards?

✅ Yes; Proceed to Step 5.
❌ No; Cannot use the CAV as is; make it accessible or seek other accessible solutions.

Step 5: Will individuals with disabilities receive the same benefits and experience, to the maximum extent possible, as those who use the original digital version.

✅ Yes; Proceed to Step 6.
❌ No; Cannot use the CAV; seek other accessible solutions.

Step 6: Can the CAV be delivered at the same time as the original version?

✅ Yes; Proceed to Step 7.
❌ No; Cannot use the CAV; seek other accessible solutions.

Step 7: Is the CAV equivalent in content and functionality to the original digital version?

✅ Yes; Proceed to Step 8.
❌ No; Cannot use the CAV; seek other accessible solutions.

Step 8: Can the CAV be clearly linked in the same location or be discoverable from the original digital version?

✅ Yes; Proceed to Step 9.
❌ No; Cannot use the CAV; seek other accessible solutions.

Step 9: Can you maintain and update the CAV at the same time as the original digital content?

✅ Yes; CAV seems reasonable to use. Be sure to document your reasons for using a CAV and be sure to use a format that is compatible with assistive technology.
❌ No; Cannot use the CAV; seek other accessible solutions.

Recommended contacts

• For compliance questions: IT Accessibility team
• For remediation assistance: Digital and Distance Learning
• For training and resources: Center for Teaching Excellence

References

1. WC3 WAI: Understanding Conformance
2. ADA: Requirements for web and mobile accessibility
3. Department of Justice 28 CFR Part 35: Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities