Accessible User Interfaces Deadline Approaching

In 2013, the Federal Communications Commission adopted rules requiring MVPDs to ensure, upon request of a subscriber, that navigation devices (set-top boxes) and pre-installed MVPD apps that provide on-screen text menus and video programming guides include audible versions of these interfaces for the blind or visually impaired. In addition, these rules oblige MVPDs to offer access to closed captioning capability through a single-step mechanism (such as a dedicated button or icon). A more detailed summary of these rules can be found in a previous DWT advisory.

Certain mid-sized MVPDs (400,000 or fewer subscribers as of year-end 2012) and small MVPDs (20,000 or fewer subscribers that are not affiliated with an operator serving more than 10 percent of all MVPD subscribers as of year-end 2012) are required to comply with these rules by December 20, 2018 (larger MVPDs were required to comply in 2016). The FCC published a guide to help small entities comply with the rules. Note, however, that on November 2, 2018, the FCC granted American Cable Association a limited waiver of these user interfaces requirements (1) for midsized or smaller systems that utilize quadrature amplified modulation (QAM), as they apply to the system’s two-way service offerings (e.g., video on demand), until 180 days after the release of an update or application that allows full compliance on a third-party device; and (2) for small cable systems that offer any video programming channels in only analog format or do not offer broadband Internet access service to their residential video subscribers, until such time as they transition to all digital or begin offering broadband Internet access service.