CVAA: Communications and Video Accessibility Act Explained

The CVAA is arguably one of the most important accessibility laws to date.

It’s thanks to this law that the over 70 million people(opens in a new tab) living with a disability in the U.S. can participate in critical, even life-saving, programming and digital communication.

While landline phones and analog television were once the height of technology, mobile phones, video content, emails, and other internet-based communications have long since taken their place, but for many people, this modern technology remained out of reach for years.

It wasn’t until the creation of the CVAA in 2010 that many digital products and services were required to become accessible to individuals with vision, hearing, and/or cognitive disabilities. 

So what is the CVAA? We’ll discuss the act in more detail below, as well as its requirements and how your organization can comply with the guidelines.

The act amends the Communications Act of 1934, extending accessibility requirements to: 

• Broadband

• Mobile devices

• Digital video

• internet-based services

The law was a direct response to a documented gap. 

Oversight and enforcement are the FCC's responsibility, and by 2010, FCC research(opens in a new tab) showed that people with disabilities were significantly less likely to use internet-based communications than the general population. 

The CVAA was designed to close that gap by imposing legal obligations on companies that build and distribute those technologies. Now, organizations that fail to comply can face fines, sanctions, and formal enforcement actions initiated by the FCC.

The CVAA’s Two Titles: What Each One Covers

The CVAA is organized into two titles, each addressing a different category of communications technology:

Title I: Advanced Communication Services 

Title I requires that advanced communication services and the devices used to access them be accessible to people with disabilities. The FCC defines advanced communication services as:

• Interconnected VoIP services: Services that allow calls to and from the public telephone network, like smartphones.

• Non-interconnected VoIP services: Platforms that allow communication within the same service, such as WhatsApp and Skype.

• Electronic messaging services: This includes email, instant messaging, and text messaging.

• Interoperable video conferencing services: Video calling tools that connect users across different platforms.

Title I also extended hearing aid compatibility requirements to VoIP devices and directed the FCC to ensure that next-generation 9-1-1 services are accessible to people with disabilities. This includes enabling 9-1-1 access via text messaging and captioned calls, an access gap addressed further by the Next Generation 9-1-1 Advancement Act of 2012.

Additionally, under Title I, mobile web browsers must be accessible to people who are blind or visually impaired, and any “telephone-like” equipment designed for use with ACS must support hearing aid compatibility, where achievable.

Title II: Video Programming Accessibility

Title II focuses on video content and the devices used to display it. It requires that:

• Video programming originally captioned for broadcast television must include closed captions when distributed online.

• Devices capable of displaying video content, including screens smaller than 13 inches, such as smartphones, tablets, and laptops, must support closed captioning and audio descriptions.

• Set-top boxes and televisions must provide accessible on-screen menus and program guides for people who are blind or visually impaired.

• Devices designed to record television programming must be able to pass through closed captions and audio descriptions during playback, where achievable.

• Cables and interconnection mechanisms must carry the data needed to display captions and transmit accessible emergency information

Title II also restored FCC authority over audio description, or in other words, audio narration that describes the key visual elements of video programming for people who are blind or have low vision. 

It’s thanks to the CVAA that major broadcast networks and cable channels are required to include audio descriptions for a portion of their prime-time and children’s programming.

Who Does the CVAA Apply To?

The CVAA applies to organizations that manufacture or provide covered communications products and services for the U.S. market. That includes:

• Telecommunications and VoIP providers: Companies that provide interconnected or non-interconnected VoIP services, electronic messaging, or interoperable video conferencing to the general public.

• Device manufacturers: Companies that build smartphones, tablets, laptops, smart TVs, set-top boxes, and other devices capable of accessing advanced communication services or displaying video content.

• Video programmers and distributors: Organizations that distribute video programming over the internet that was originally captioned for broadcast television, or programming that is “generally comparable” to broadcast television.

• Software and app developers: Developers building applications that provide advanced communication services, including messaging, calling, and video conferencing, must ensure those features meet CVAA accessibility requirements.

An important note: the CVAA does not apply to user-generated content. For example, Videos uploaded to platforms like YouTube by individual users are not covered, nor is content that does not meet the definition of “video programming” under the act.

The law also carves out exemptions for certain organizations and sectors. The FCC initially granted waivers to certain sectors where compliance would be technically or financially difficult, including communication features in online games. However, those waivers have since expired, and games released after December 31, 2018, must ensure their communication features and user interfaces are accessible to those with disabilities. Some exemptions do still apply, including for small businesses and custom-built equipment not available to the general public.

CVAA Compliance Requirements

One of the first steps towards CVAA compliance is knowing whether or not you need to comply and understanding which accessibility requirements you need to follow. The specific requirements depend on what your organization makes or distributes, but the core obligations include:

• Closed captioning for online video: Video programming that was captioned when originally broadcast on television must include captions when distributed online. Captions must be accurate, synchronized with the audio, and not obscure important visual content.

• Audio descriptions for video content: Where required, video programming must include an audio description track that narrates key visual elements of the program for viewers who are blind or have low vision.

• Accessible user interfaces: The controls and interfaces of devices and software used to access ACS must be accessible to people with vision, hearing, motor, and cognitive disabilities.

• Compatibility with assistive technologies: Products covered by the CVAA must be usable with common assistive technologies, including screen readers, hearing aids, cochlear implants, and alternative input devices.

• Accessible emergency communications: Covered entities must ensure that emergency alerts and information are accessible through visual, audio, and text-based means.

• Real-time text (RTT) support: Where applicable, platforms must support real-time text communication for people who cannot use standard voice calling.

• Accessible customer support: Customer service channels must be accessible to people with disabilities.

A complete list of CVAA requirements is available on the FCC’s CVAA page(opens in a new tab). 

To ensure your business is compliant, continuously monitor FCC rulemakings and biennial reports to Congress, which update and clarify compliance obligations as technology evolves.

Penalties for CVAA Non-Compliance

Not only does failing to comply with the CVAA limit your market reach, but it can also lead to legal repercussions.

The FCC has the authority to investigate complaints, issue citations, and impose fines on organizations that fail to meet CVAA requirements. Penalties can include:

• Monetary fines, which can reach tens of thousands of dollars per violation per day.

• Formal consent decrees requiring specific remediation steps and ongoing compliance monitoring.

• Reputational damage and erosion of consumer trust, particularly among the disability community.

For example, in 2021, the FCC entered into a settlement agreement with a major telecommunications company(opens in a new tab) over its failure to provide closed captions on video content. The company was required to pay a significant fine and implement a corrective action plan. The outcome of this case highlights that the CVAA is not a seldom-enforced law; instead, the FCC has proven that it is actively enforcing closed captioning and other accessibility requirements.

Beyond FCC enforcement, CVAA noncompliance can also expose organizations to litigation under the Americans with Disabilities Act (ADA) when the same content or service is covered by both laws.

How the CVAA Relates to Other Accessibility Laws

The CVAA exists alongside additional U.S. accessibility laws. Understanding where it sits helps organizations avoid compliance gaps.

The chart below provides a quick overview of the scope and context of other U.S. accessibility laws your business may need to comply with.

Put simply, organizations subject to the CVAA are often also subject to the ADA and, if they work with federal agencies, Section 508. It’s important to note that meeting CVAA obligations does not automatically mean your business is compliant with ADA or Section 508 requirements, and vice versa. 

Why the CVAA & Compliance Matters

The CVAA matters because communications technology is no longer optional infrastructure. Instead, it is the primary channel through which people work, learn, access health care, contact emergency services, and participate in public life.

For the more than 70 million adults in the U.S. living with a disability, inaccessible communications technology isn't an inconvenience — it's exclusion from the tools everyone else uses to work, connect, and stay informed.

The CVAA's requirements address this directly. Closed captions, for example, are essential for the 48 million Americans with hearing loss, but they also benefit anyone watching video in a noisy environment, learning English as a second language, or simply trying to retain information better. Audio descriptions serve the 20 million Americans with vision impairment, and extend naturally to anyone who can't look at a screen while consuming content.

This is the broader pattern with accessibility: features built for people with disabilities usually make the experience better for everyone.

For businesses, CVAA compliance is both a risk-management decision and a market-access decision. The disability community represents a significant and underserved audience. Companies that meet the standard aren't just avoiding enforcement. They're reaching people that non-compliant competitors are actively leaving out.

Ensuring CVAA Compliance With AudioEye

CVAA compliance is not a one-time fix. As your communications products and video content evolve, so do your compliance obligations. At AudioEye, we help organizations identify accessibility barriers, fix them, and monitor for new issues over time.

We start with a free accessibility scan to surface the most common issues, then provide expert guidance for the barriers that automated tools cannot resolve. Our team of certified accessibility experts and members of the disability community further audits your digital content to find and fix accessibility issues that automation alone can’t detect. The result: digital content that’s compliant, accessible, and user-friendly.