CVAA Compliance: Accessible Video and Communications Technology

What the CVAA actually is

The 21st Century Communications and Video Accessibility Act (CVAA) is a US federal law signed in 2010 and enforced by the Federal Communications Commission (FCC). It updates earlier communications accessibility laws to cover modern technologies — smartphones, apps, streaming video, VoIP, and video conferencing — that did not exist when the original rules were written.

The CVAA operates separately from the ADA and WCAG. It is a specialized regulatory framework for communications and video technology, with its own rules, deadlines, and enforcement mechanisms.

Title I: Communications access

Title I of the CVAA covers advanced communications services (ACS) and the hardware and software used to access them. Covered services include:

• VoIP (Voice over Internet Protocol)
• Text messaging and SMS
• Video conferencing and collaboration tools
• Email services
• Interoperable video conferencing

Requirements under Title I include:

• ACS must be accessible to people with disabilities where achievable
• Compatibility with assistive technology is required
• User interfaces and any menus must be operable by people with visual, hearing, motor, and cognitive disabilities
• Documentation and technical support must be accessible

Title II: Video programming

Title II covers the accessibility of video programming — television and streaming video content distributed to US consumers. Requirements include:

• Closed captions: Video programming that was captioned on broadcast TV must be captioned when delivered via IP (internet protocol). This covers streaming services and app-based video players.
• Audio description: Certain broadcast and cable programming must include audio description tracks for blind and low-vision users.
• Accessible user interfaces: Navigation menus and controls on video devices and players must be accessible.
• Caption controls: Users must be able to find and control caption settings easily (“readily accessible” standard).

Key 2026–2027 deadlines

Penalties and recordkeeping

The FCC has authority to enforce the CVAA through formal complaint proceedings and forfeitures:

• Base penalty: approximately $144,000 per violation (inflation-adjusted)
• Cap for continuing violations: approximately $1.4 million
• The FCC has issued multi-million dollar forfeitures against broadcasters, cable companies, and app developers

Covered entities must also maintain records of their accessibility efforts — including the number and nature of complaints received and how they were resolved — and certify these records to the FCC by April 1 each year. Failure to certify is a separate, sanctionable violation.

How the CVAA relates to WCAG

WCAG and the CVAA address different problems and should not be confused:

• WCAG addresses web and digital content accessibility — visual, motor, cognitive, and auditory access to websites and apps
• CVAA addresses communications technology and video programming specifically — captioning, audio description, accessible controls, ACS compatibility

A streaming app can be fully WCAG 2.2 AA compliant and still violate the CVAA if its captioning is not accessible or its video controls are not operable. Both frameworks must be addressed independently.

Exceptions

The CVAA includes several important exceptions:

• Not achievable: If compliance is not technically and economically achievable, a covered entity may be exempt. This is a narrow standard requiring documentation.
• User-generated content: Video posted by users (YouTube uploads, social media clips) is generally not subject to the captioning requirements. The obligation falls on programmers and distributors, not individual users.
• Live programming: Some live programming has longer timelines for captioning compliance due to the technical complexity of real-time captioning.
• Archived content: Older content that was never captioned on broadcast may have reduced obligations for IP delivery, depending on when it originally aired.