As we outlined in our previous client advisory, on June 12, 2023, the FCC issued a Report and Order (“R&O”), Notice of Proposed Rulemaking (“NPRM”), and Order finding that the existing accessibility requirements for advanced communications services (ACS) apply to commonly used video customer-facing and enterprise video conferencing services.
Compliance Deadlines
On August 7, 2023, the FCC released a Public Notice announcing the comment due dates and compliance dates for this proceeding. Providers of interoperable video conferencing services must comply with the accessibility rules no later than September 3, 2024.
In the Order, the FCC waived for one year, subject to conditions, a Telecommunications Relay Service (TRS) rule that restricts Video Relay Service users’ ability to turn off their video cameras when not actively participating in a video conference. This TRS waiver will end August 1, 2024.
If your company’s video conferencing services cannot yet be used by people with disabilities, the time to change this is now. And if your video conferencing service offers chat functionalities, as nearly all such services do, those functionalities must already accommodate a wide range of disabilities.
NPRM Comment Due Dates
The FCC now seeks comment on proposals in its NPRM, including:
- Specific performance objectives for improving the accessibility of video conferencing services, such as for speech-to-text (captioning) capabilities; text-to-speech capabilities; and enabling the use of sign language interpreting.
- Whether additional performance objectives are needed (for example, to support individuals with other types of disabilities or to enable users to control the activation and appearance of accessibility features);
- Rules for integration of Telecommunications Relay Services (TRS) with video conferencing without a dial-up telephone connection; and
- When multiple communications assistants may be assigned to relay service calls that involve users of different forms of TRS.
Comments and reply comments on the NPRM are due on September 6, 2023, and October 6, 2023, respectively.
The CommLaw Group Can Help!
If you have any questions about your new obligations as a video conferencing service provider, or a maker of hardware or software used to access these services, please contact our digital accessibility expert, Michal J. Nowicki, Esq., at (703) 714-1311 or mjn@commlawgroup.com
