Annual Accessibility Recordkeeping and Contact Information Update Due April 1 at the FCC

Davis Wright Tremaine LLP

By no later than April 1, 2016, entities providing telecommunications (now including broadband Internet access service), VoIP, advanced communications services (email, text), or mobile phone Internet browsers must certify to the Federal Communications Commission (FCC) to their compliance in 2015 with the FCC’s accessibility recordkeeping requirements.

The FCC rules require these covered entities to maintain contemporaneous records of their efforts to comply with FCC rules requiring voice, advanced services, Internet access and Internet browsers to be accessible, including (1) efforts to consult with persons with disabilities in the product/service development process, (2) the accessible features of the entity’s products and/or services, and (3) information about the compatibility of the entity’s services and/or products with devices or software used by persons with disabilities to achieve access. An officer of the company must sign and file the annual compliance certificate. The entity must also submit or update contact information for persons designated by the entity to address accessibility complaints.

As a reminder, this year, broadband Internet access service was classified as a telecommunications service for purposes of the FCC’s accessibility rules. Accordingly, some companies that were not previously subject to this filing requirement may now be covered.

Accordingly, now is a good time to ensure that your company has been maintaining all of the records required by the FCC. If you are unsure or would like guidance as to what is required, please contact one of the persons listed here.

To submit annual recordkeeping certifications or to enter or update contact information go to

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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