Annual Recordkeeping Certification for Products Including Games with Communications Features Due to the FCC by April 1st (No Joke)

By Jonathan Avila

If you provide advanced communication services (ACS) such as text chat, voice chat, email, and other two-way voice communications, you need to get started now to meet the Federal Communication Commission’s April 1, 2019 deadline for annual recordkeeping certification.  

Under the Twentieth Century Communication and Video Accessibility Act (CVAA), advanced communication servicesregardless of whether they’re in a mobile app, website, console, mobile, or desktop game, or through hardwarehave to be accessible to people with disabilities.  Furthermore, mobile phones and browsers need to be accessible to people who are blind or visually impaired under the CVAA. 

Under FCC regulations, all service providers who include advanced communication services in their content (including those game developers who have released games with these features after January 1stof this year) must file an annual recordkeeping certification and, as needed, to file or update their contact information by April 1, 2019. Annual certifications must be entered in the FCC’s Recordkeeping Compliance Certification and Contact Information Registry at https://apps.fcc.gov/rccci-registry/. But, organizations don’t need to actually submit the records at thisinstead they certify that they are keeping records in accordance with the CVAA requirements;the FCC may later request these records if a complaint is made by a consumer.  Potential fines of up to $100,000 per day per incident are possible for ACS that is not in conformance with the requirements. 

If you need assistance in determining which records to keep or need guidance on developing a plan to implement accessibility into the design of your product or services, we can help!  Level Access works with providers including game developers, those creating augmentative and virtual reality, mobile phone manufacturers, and communications providers to make their products inclusive to people of all abilities. Reach out to us today!