On February 26, 2024, the FCC released a Public Notice reminding service providers (and equipment manufacturers) that are subject to the accessibility requirements of sections 255, 716, or 718 of the Communications Act, of their obligation to file their annual recordkeeping compliance certifications and required contact information no later than April 1, 2024 in the Recordkeeping Compliance Certification and Contact Information Registry (“RCCCI Registry”).
As you may recall, covered service providers must certify that, as of January 1, 2023 and until December 31, 2023, they have established operating procedures that are adequate to ensure compliance with the CVAA recordkeeping rules and that they have kept records accordingly. The certificate must be supported by a declaration under penalty of perjury, signed and dated by an authorized officer of the company with personal knowledge of the representations provided in the company’s certification, verifying the truth and accuracy of the information therein. This filing must also include the current contact information for consumers and a current U.S. agent for service contact information.
Section 718 requires providers of mobile service to ensure that the functions of the Internet browser that they include or arrange to be included in such telephones are accessible to and useable by individuals who are blind or have a visual impairment, unless doing so is not achievable. In order to comply with Section 718, service providers that arrange for Internet browsers on their mobile phones must:
- Consider performance objectives and accessibility issues early in the browser design stage;
- Identify barriers to browser accessibility and usability as part of their evaluation when considering accessibility performance objectives;
- Ensure that if the chosen browser supports a specific web standard, approved standards recommendations, or technology that supports accessibility features and capabilities, the browser uses those capabilities, unless doing so is not achievable; and
- Provide accessible information and documentation to customers.
A covered service provider must maintain records of its efforts to implement Section 718. Such records include:
- Information on its efforts to consult with individuals with disabilities;
- Descriptions of the accessibility features of its products and services; and
- Information about the compatibility of its products and services with peripheral devices or specialized customer premise equipment that is commonly used by individuals with disabilities to achieve access.
Additional guidance for filers can be found at https://www.fcc.gov/rccci-filing-instructions.
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