On March 3, 2025, the Federal Communications Commission (FCC) issued a Public Notice reminding service providers and equipment manufacturers that April 1, 2025, and annually thereafter, is the deadline for certain entities to file their annual recordkeeping compliance certifications and contact information in the Recordkeeping Compliance Certification and Contact Information (RCCCI) Registry. This includes Communications and Video Accessibility Act (CVAA) certifications for interoperable video conferencing services (IVCS) and, for the first time, incarcerated people’s communications services (IPCS).
IVCS is defined broadly as “a service that provides real-time video communications, including audio, to enable users to share information of the user’s choosing.” IPCS, on the other hand, refers to “any audio or video communications service used by inmates for the purpose of communicating with individuals outside the correctional institution where the inmate is held, regardless of technology used.”
As outlined in our previous client advisory, the FCC requires telecommunications and customer premises equipment manufacturers, advanced communication services (ACS) providers, and equipment manufacturers to submit accessibility recordkeeping compliance certifications and contact information to the RCCCI. These requirements ensure that communications services and equipment are accessible to and usable by individuals with disabilities. Despite these requirements, telecommunications equipment, customer premises equipment, and telecommunications services need not be made accessible or usable where compliance is not “readily achievable.” Likewise, advanced communications services and related equipment is exempt where compliance is not “achievable.”
The CommLaw Group Can Help!
For assistance with filing obligations or compliance with accessibility requirements, please contact:
Michal Nowicki at 703-714-1311 or mjn@commlawgroup.com. To schedule a consultation, please use my public calendar.
Michael Donahue at 703-714-1319 or mpd@commlawgroup.com.
