CVAA

The Twenty-First Century Communications and Video Accessibility Act, commonly known
as the CVAA, is a United States federal law intended to improve access to modern
communications services, communications equipment and video programming for people
with disabilities.

The CVAA was signed into law in 2010 and is primarily implemented through rules
administered by the Federal Communications Commission.

It is not a general website-accessibility law applying to every website or digital
product. Its scope focuses on specific communications technologies, equipment,
internet browsers built into mobile phones and certain television programming
distributed over the internet.

What is the CVAA?

The CVAA updated United States communications law to address technologies that had
developed beyond traditional telephone and television services.

Its purpose is to help ensure that people with disabilities can access and use modern
communication services and have improved access to video programming.

The Act contains two principal titles:

• Title I addresses communications access, including advanced communications
  services, related equipment and certain mobile-phone browser requirements.
• Title II addresses video programming, including internet-delivered captioning,
  video-description rules and accessibility of certain video equipment and controls.

Who may be affected by the CVAA?

Depending on the product or service, CVAA requirements may affect:

• Providers of advanced communications services.
• Manufacturers of advanced communications equipment.
• Manufacturers of mobile phones containing internet browsers.
• Video programming owners.
• Video programming distributors.
• Online video programming distributors.
• Manufacturers of televisions and video-playing equipment.
• Developers of relevant communication software.
• Providers of interoperable video-conferencing services.

Applicability depends on the functionality, service type, distribution method and
relevant FCC rules. Operating an ordinary business website does not by itself make
an organisation subject to every CVAA requirement.

Title I: communications accessibility

Title I addresses access to advanced communications services and equipment.
Covered products and services must generally be accessible to and usable by people
with disabilities when achievable under the applicable legal standard.

What are advanced communications services?

Advanced communications services can include:

• Electronic messaging services.
• Text messaging.
• Instant messaging.
• Email.
• Interconnected Voice over Internet Protocol services.
• Non-interconnected Voice over Internet Protocol services.
• Interoperable video-conferencing services.

The precise legal definitions and exclusions should be reviewed against current FCC
rules when assessing a particular service.

Accessibility of communications services and equipment

Covered service providers and equipment manufacturers should consider whether people
with disabilities can access and use the product’s functions.

Accessibility may involve:

• Operating controls without sight.
• Receiving information through nonvisual methods.
• Using the service without hearing.
• Adjusting audio presentation.
• Operating controls with limited reach, strength or dexterity.
• Using assistive technologies.
• Understanding instructions and interface feedback.
• Accessing customer support and product documentation.

The relevant requirement is broader than the visual appearance of a website. It can
include hardware, software, communication functions, setup, documentation and support.

Internet browsers built into mobile phones

The CVAA led to accessibility requirements for internet browsers built into mobile
phones so that people who are blind or visually impaired can access the browser and
its functions.

Relevant considerations can include:

• Launching and navigating the browser.
• Entering and reviewing web addresses.
• Navigating browser menus and settings.
• Reading browser-generated messages.
• Using zoom, text enlargement or screen-reader support.
• Operating controls without relying exclusively on sight.

This requirement concerns the browser functionality supplied with the phone. It does
not mean that the manufacturer is responsible under the CVAA for correcting every
third-party website visited through the browser.

Title II: video programming accessibility

Title II includes requirements concerning closed captioning, video description,
emergency information and the accessibility of certain video-programming equipment
and controls.

For online services, one of the best-known CVAA requirements concerns television
programming that is later distributed through internet protocol.

When are captions required for internet video?

FCC internet-captioning rules generally apply when full-length video programming:

• Was shown on television in the United States.
• Was shown on television with captions.
• Is later distributed in the United States using internet protocol.

The rules also cover certain video clips taken from television programming and
distributed online, subject to the relevant dates, categories and exceptions.

The fact that a video is available online does not by itself establish that the
CVAA internet-captioning rules apply.

Full-length programming and video clips

FCC rules distinguish between different forms of programming, including:

• Full-length prerecorded programming.
• Live programming.
• Near-live programming.
• Programming edited for internet distribution.
• Straight-lift video clips.
• Montages containing multiple television clips.
• Clips from live and near-live television programming.

Each category may be subject to different timing, captioning and distribution
requirements. Organisations should review the current FCC rules for the specific
type of content they distribute.

What is a straight-lift clip?

A straight-lift clip is generally a single continuous excerpt taken from captioned
television programming with substantially the same audio and video presentation.

A montage combines multiple clips from one or more programs. Different FCC deadlines
and requirements historically applied to these categories.

Caption quality

Captions should not be treated as a simple technical attachment. They need to
communicate the programme’s meaningful spoken and non-spoken audio information.

Useful caption-quality considerations include:

• Accuracy.
• Synchronicity with the audio.
• Completeness.
• Readable placement.
• Identification of speakers where necessary.
• Communication of important sound effects and music.

Automatically generated captions should be reviewed before publication when errors
could change meaning, omit important information or make the programme difficult to
understand.

Shared responsibility for online captions

Responsibilities can be divided between the video programming owner and the online
video programming distributor.

Depending on the applicable rule:

• The programming owner may be responsible for providing caption files and required information.
• The distributor may be responsible for enabling captions in the online player.
• Both parties may need processes for communicating captioning status.
• The distributor should preserve the quality and completeness of supplied captions.

Contracts should clearly define ownership, delivery format, quality review,
correction and complaint responsibilities.

Does every online video require captions under the CVAA?

No. The CVAA does not automatically require captions for every video published on
every website.

Internet-only programming that was never shown on United States television may fall
outside the specific CVAA internet-captioning rule.

That does not necessarily mean the content has no accessibility obligations.
Other federal or state laws, contractual requirements, education rules, procurement
standards or organisational policies may still be relevant.

Providing accurate captions is also an important accessibility practice even when a
specific CVAA rule does not apply.

Consumer-generated video

User-generated videos are not automatically subject to CVAA internet-captioning
requirements merely because a user uploads them to a platform.

However, the platform may still have accessibility responsibilities relating to its
own controls, account functions, upload process, media player and communication
features under other applicable requirements.

Video-player accessibility

Providing a caption file is not sufficient when users cannot discover, activate or
configure captions.

An accessible video player should support:

• Keyboard operation.
• Visible keyboard focus.
• Programmatically identified controls.
• Meaningful control names.
• Caption activation without requiring a mouse.
• Clear indication of whether captions are enabled.
• Accessible playback and volume controls.
• Logical focus order.
• Compatibility with screen readers.

Captions must also remain readable when the player is resized or viewed on different
devices.

Video description

Video description, also called audio description, provides spoken descriptions of
important visual information during natural pauses in dialogue.

FCC rules require certain television stations and multichannel video programming
distributors to provide specified amounts of video-described programming.

The requirements depend on factors such as the network, market, programming and
distribution service. They do not mean that every online video must contain audio
description under the CVAA.

Emergency information

Video programming rules also address access to emergency information.

Important emergency information communicated through audio should be made accessible
to people who are deaf or hard of hearing. Important emergency information presented
visually may require an audible form for people who are blind or have low vision,
depending on the programming and applicable FCC requirements.

Emergency content should be presented without obscuring captions or other critical
information.

Accessible television and video equipment

The CVAA also addresses accessibility of certain devices used to receive, play or
navigate video programming.

Depending on the equipment and rules, requirements may involve:

• Accessible on-screen menus.
• Accessible programme guides.
• Audible presentation of certain visual information.
• Accessible playback controls.
• A simple method for activating closed captions.
• A simple method for activating video description.
• Accessible set-top box functions.

Communication-product documentation and support

Product accessibility can include more than the main user interface. Covered
manufacturers and service providers should also consider:

• Accessible user guides.
• Accessible online documentation.
• Accessible billing and account information.
• Accessible customer-support channels.
• Information about accessibility features.
• Support staff training.
• Compatibility information for assistive technologies.

Record-keeping responsibilities

Covered manufacturers and service providers may be required to maintain records of
their accessibility efforts.

Useful records can include:

• Accessibility evaluations.
• Consultations with people with disabilities.
• Accessibility features considered during development.
• Reasons a feature was or was not implemented.
• Compatibility testing.
• Customer-support processes.
• Complaints and responses.
• Remediation and verification evidence.

Common CVAA accessibility barriers

• Messaging controls without accessible names.
• Video-call buttons that cannot be operated by keyboard.
• Incoming-call notifications that rely only on sound.
• Mobile browser controls that are not announced by a screen reader.
• Television programming published online without required captions.
• Caption files that are incomplete or out of sync.
• Caption controls that cannot be found or activated without a mouse.
• Video-player controls with unclear labels.
• On-screen menus that are unavailable through nonvisual output.
• Customer-support information supplied only in an inaccessible format.

CVAA and WCAG

The CVAA does not simply adopt WCAG as the complete legal standard for every covered
communication product or video service.

WCAG can nevertheless help teams assess web-based interfaces used for:

• Messaging.
• Account management.
• Video playback.
• Caption controls.
• Customer support.
• Browser-based communication.
• Documentation.

WCAG testing should be combined with the product-specific and service-specific
requirements found in FCC rules.

Learn more about the
Web Content Accessibility Guidelines.

CVAA, ADA and Section 508

The CVAA, Americans with Disabilities Act and Section 508 are different legal
frameworks.

An organisation or product may be affected by more than one legal framework.
Applicability should be assessed separately rather than assuming that compliance
with one law establishes compliance with all others.

Read more about the
Americans with Disabilities Act
and
Section 508.

How to assess a communication service

1. Identify the service:
   determine whether it includes messaging, VoIP, interoperable video conferencing
   or another covered communication function.
2. Identify users and disabilities:
   consider visual, hearing, speech, mobility, dexterity and cognitive access.
3. Map essential functions:
   include account creation, contacts, messages, calls, notifications, settings and
   customer support.
4. Review relevant FCC rules:
   determine which statutory definitions, exceptions and accessibility standards
   apply.
5. Test the product:
   combine keyboard, screen-reader, visual, auditory and functional testing.
6. Document barriers:
   record user impact, affected functionality and supporting evidence.
7. Assign remediation:
   route issues to product, design, engineering, content or support.
8. Verify corrections:
   retest the affected communication journey.

How to assess internet video captioning

1. Confirm the programming history:
   determine whether the programme appeared on United States television.
2. Confirm television captions:
   determine whether it was captioned when shown on television.
3. Classify the online content:
   identify whether it is full-length, live, near-live, edited or a video clip.
4. Identify responsible parties:
   establish the roles of the programming owner and online distributor.
5. Review caption quality:
   check accuracy, timing, completeness and placement.
6. Test the player:
   confirm that caption controls are accessible by keyboard and assistive technology.
7. Document exceptions:
   preserve the basis for any conclusion that the rule does not apply.
8. Correct and verify:
   resolve caption or player barriers and retest before publication.

Testing methods

Automated testing

Automated tools can identify technical issues in web-based communication and media
interfaces, including missing names, invalid attributes, contrast failures and
structural problems.

Keyboard testing

Test whether users can operate messaging, calls, menus, caption controls, playback
and account settings without a mouse.

Screen-reader testing

Confirm that controls, notifications, participant information, incoming messages
and call states are announced accurately.

Caption review

Review captions against the programme audio instead of relying only on the presence
of a caption file.

User testing

Testing with people with disabilities can reveal barriers involving communication
speed, comprehension, notifications and complex interaction sequences.

FCC complaints and dispute assistance

Consumers experiencing an accessibility problem involving covered communications
services or equipment may contact the provider or manufacturer and may be able to
request assistance or file a complaint through the FCC.

Complaint categories may include:

• Advanced communications services and equipment.
• Internet browsers built into mobile phones.
• Closed captioning on television.
• Closed captioning of internet-delivered programming.
• Video-description issues.
• Accessibility of video-programming controls and guides.

The applicable complaint process, deadlines and preliminary dispute-assistance
requirements depend on the type of accessibility issue.

How Pluro supports communications and video accessibility

Pluro is an accessibility workflow platform that helps teams manage digital
accessibility findings from detection through verified remediation.

Teams can use Pluro to organise automated and manual findings affecting web-based
communication interfaces, media players, caption controls, account journeys and
customer-support experiences.

Findings can include behavioural evidence, reproduction steps, responsible owners,
remediation guidance and verification history.

Pluro does not determine whether a particular product is legally subject to the
CVAA, and it does not replace caption-quality review, product-specific testing or
qualified legal advice.

CVAA accessibility checklist

• Determine whether the product or service falls within CVAA scope.
• Identify the relevant FCC rules and definitions.
• Assess advanced communications functions.
• Test hardware, software, documentation and support.
• Review mobile-browser accessibility where applicable.
• Confirm the broadcast history of internet video programming.
• Provide required captions and preserve their quality.
• Make caption and playback controls keyboard accessible.
• Assess relevant video-description and equipment requirements.
• Document accessibility efforts and known limitations.
• Provide a process for addressing user complaints.
• Verify remediation after product or content changes.

Important notice

This page provides general information and does not constitute legal advice. CVAA
applicability depends on the service, equipment, programming, distribution method,
organisation and current FCC rules. Review official FCC guidance and obtain qualified
United States legal advice for specific compliance decisions.

Read the official

FCC information about the CVAA
.

Review the official

FCC guidance on internet video captioning
.

See how Pluro manages accessibility workflows
or
start a 14-day free trial
with no credit card required.