ARTICLE
10 March 2026

Upcoming RCCCI CVAA Filing Deadline – April 1, 2026

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On February 25, 2025 the Federal Communications Commission (FCC) issued a  Public Notice  reminding service providers...
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On February 25, 2025 the Federal Communications Commission (FCC) issued a  Public Notice  reminding service providers and equipment manufacturers that  April 1, 2026, and annually thereafter, is the deadline for certain entities to file their annual recordkeeping compliance certifications and contact information in the Recordkeeping Compliance Certification and Contact Information (RCCCI) Registry. This includes Communications and Video Accessibility Act (CVAA) certifications for interoperable video conferencing services (IVCS) and incarcerated people's communications services (IPCS).

IVCS is defined broadly as "a service that provides real-time video communications, including audio, to enable users to share information of the user's choosing." IPCS, on the other hand, refers to "any audio or video communications service used by inmates for the purpose of communicating with individuals outside the correctional institution where the inmate is held, regardless of technology used."

As outlined in our previous client advisory, the FCC requires telecommunications and customer premises equipment manufacturers, advanced communication services (ACS) providers, and equipment manufacturers to submit accessibility recordkeeping compliance certifications and contact information to the RCCCI. These requirements ensure that communications services and equipment are accessible to and usable by individuals with disabilities. Despite these requirements, telecommunications equipment, customer premises equipment, and telecommunications services need not be made accessible or usable where compliance is not "readily achievable." Likewise, advanced communications services and related equipment is exempt where compliance is not "achievable."

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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