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The final deadline of the FCC’s Twenty-First Century Communications and Video Accessibility Act (CVAA) pertaining to online videos is quickly approaching. On July 1, 2017, video clips (both straight-lift and montage clips) of live and near-live television programming (such as news or sporting events) will need to observe the following turnaround times for posting online with captions:

• For clips of live programming, up to a 12-hour delay is permitted in posting a captioned clip after the programming has been shown on TV.
• For clips of near-live programming, up to an 8-hour delay is permitted in posting a captioned clip after the programming has been shown on TV.

Live & Near-live Programming

Live programming is defined as programming shown on TV substantially simultaneously with its performance. When the Commission evaluates the compliance of captioning standards on live programming, there’s an understanding that live programming cannot be perfect since there’s a human element to live captioning and no opportunity to review and edit captions in a live setting. Therefore, there’s a little bit of leeway provided given the nature of live programming.

Near-live programming, which is programming that is performed and recorded within 24 hours prior to when it is first aired on television, is evaluated under the same standards applied to live programming. Although the FCC encourages measures to be taken prior to the program’s airing to improve its captioning quality, it’s understood that the window of time to make those corrections is very limited.

Revisiting the Internet Captioning Rules

The rules of the CVAA require video programming distributors that show programming on TV to post captioned clips of their programming on their own websites or applications ("apps").  Currently, the video clips rules do not apply to third-party websites or apps.

• The Internet closed captioning rules only apply if the video programming was shown on TV in the U.S. with captions.
• "Full-length video programming" is video programming that is shown on TV and is distributed to end-users in its entirety.
• Excerpts of full-length video programming (with the same video and audio) captioned for television and posted online are denoted as video clips, or “straight-lift clips”, and require captioning as of January 1, 2016. The timeline for posting captions on videos online is within 15 days after the date of its initial broadcast.
• On January 1, 2017, the law extended to “montages,” or edits composed of multiple single excerpts (“straight-lift clips”). For example, an hour-long talk show that aired on television may appear as multiple segments on the web afterward – say, abridged interviews of each of the guests. Those clips, all stemming from the original full-length program, are required to be captioned.
• As of July 1, 2017, live and near-live programming will have to follow the turnaround times noted at the beginning of this post.

It’s also important to remember that consumer-generated media (e.g., home videos) shown on the Internet are not required to be captioned unless they were shown on TV with captions.

Further reading from the FCC: Captioning of Internet Video Programming & Twenty-First Century Communications and Video Accessibility Act (CVAA).

Repurposing caption files for the web can be as simple as reformatting and a quick file conversion. After all, the videos have already been transcribed. It’s just a matter of matching your video player’s specifications for web play-out. To learn more about getting your Internet clips compliant, please contact us.