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Accessibility Compliance Recordkeeping Certificates Due Wednesday, April 1, 2015

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Accessibility Compliance Recordkeeping Certificates Due Wednesday, April 1, 2015

Telecommunications carriers, equipment manufacturers, interconnected Voice over Internet Protocol (VoIP) providers, non-interconnected VoIP providers, wireless carriers, and advanced communications service providers are required to file a certificate annually with the Federal Communications Commission (FCC), confirming pursuant to Sections 255, 716, and 718 of the Communications Act of 1934, as amended (the Act) that the company maintains records of any and all efforts undertaken to ensure its products and services are accessible to those with disabilities.

Specifically, companies must maintain records of:

  • Their efforts to consult with individuals with disabilities;
  • Descriptions of the accessibility features of its products and services; and
  • Information about the compatibility of these products and services with peripheral devices or other equipment typically used to gain access to the company’s services, such as hearing aids.

The certificate must identify both a contact within the company who is authorized to resolve accessibility complaints and an agent to receive any informal complaints from the FCC alleging the company has violated the FCC’s accessibility rules. Finally, the certificate must be supported by a declaration or affidavit signed under the penalty of perjury by an officer of the company who has personal knowledge of the company’s recordkeeping policies and procedures.

The deadline for filing the certificate is Wednesday, April 1, 2015.

The FCC has established a filing portal for this certificate which can be found here. More information about this filing can be found in the Public Notice found here. (DA 15-274)

For further information, please contact Katherine Barker Marshall or the Arent Fox professional who handles your matters.

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