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Conforming Alternate Versions

A “conforming alternate version” is a second, accessible version of otherwise inaccessible content, such as a text-only version of an inaccessible web page or a transcript of an inaccessible multimedia presentation. The W3C Web Content Accessibility Guidelines (WCAG) include the concept of conforming alternate versions, but the Department of Justice (DOJ) rule about the accessibility of government web sites adds a significant limitation to their use:

§ 35.202 Conforming alternate versions.
(a) A public entity may use conforming alternate versions of web content, as defined by WCAG 2.1, to comply with § 35.200 only where it is not possible to make web content directly accessible due to technical or legal limitations.

The DOJ rule states that a “technical limitation” applies only when “a technology is not capable of being made accessible”, and clarifies that lack of knowledge or training would not be considered a technical limitation. 

As a result, many previous uses of conforming alternate versions are no longer acceptable.


The DOJ cites several reasons that led to the intentional and careful addition of this new limitation, including concerns that conforming alternate version are likely to:

  • result in segregated access that is inconsistent with the ADA's core principles,
  • provide information that is outdated or conflicting due to the burden of maintaining multiple versions,
  • present a fragmented, separate, or less interactive experience for people with disabilities.

Because of this, DOJ indicates that conforming alternate versions should be used rarely -- only when it is truly not possible to make content accessible.

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