What is the CVAA

Don't Panic is hand written in black ink

Let’s start with some simple facts. The CVAA does not require you to make your games fully accessible. While AbleGamers would love for you to make your games and content fully accessible so that players with disabilities all over the world can enjoy the amazing worlds, and stories you create for a living, the CVAA has a very narrow focus. If someone is telling you otherwise, they are simply using this law, and people’s ignorance of it, to forward an agenda that may lead to content makers eliminating features, or in the extreme, creating a hostel environment for players with disabilities when CVAA is used as an excuse for a company not doing something.

With that out of the way, keep reading and we will tell you what you do have to do, how to find a trusted partner to help you comply with the law, and, because you know us, how to go beyond what the CVAA requires and make a more accessible game than ever before.

CVAA @ GDC 2018

Title slide of GDC talk with date and time on it. Quite ugly.

What is the CVAA?

AbleGamers wants to start by saying DON’T PANIC. The requirements laid out are not hard to comply with. 21st Century Communication and Video Accessibility Act (CVAA) covers Advanced Communications Services (ACS). As of Jan 1, 2019, this included any ACS in video games.

The CVAA has two main “Titles” and for most game makers, you will want to focus on Title 1 (below). Title II is largely focused on equipment makers, so the console manufactures should also look at that.

What is ACS?

ACS stands for “Advanced Communications Services”.  This is technology that foster TWO WAY COMMUNICATION in the internet age. VOIP, text chat, video conferencing, and things like that.

How the CVAA Law Impacts the Gaming Industry

Manufacturers of game consoles, interactive games and entertainment software doing business in the United States, are subject to compliance with regulatory requirements of the Twenty-First Century Communications and Video Accessibility Act of 2010 (“CVAA”).

Title I of the CVAA includes accessibility rules for product manufacturers and service providers who offer advanced communication services (ACS). ACS includes functionality such as two-way, human-to-human, real-time or near real-time VOIP communication, text communication (e.g., e-mail, instant message, chat), video conferencing, as well as browsers (including mobile browsers). In gaming, ACS functionality could be enabled by console hardware or accessories, game title software, or other technology products or services (e.g. app that supports gamer-to-gamer communications using text, voice or video).

Title II of the CVAA includes accessibility rules for devices, such as game consoles, that offer a way to playback or record full-length video programming content provided over the internet. Playback requirements include: proper display of captions, video description information and access to emergency information. Devices that can record full-length video program content must properly store and playback accessibility information (e.g. captions, video description). Also, a simple means of activating the accessibility features of device must be provided.

What Gaming Industry Companies Should Do

AbleGamers encourages producers of video games and consoles to assess how the 21st Century Communications and Video Accessibility Act (CVAA) affects them.  Compliance with the law requires a level over oversight that AbleGamers is not able support, and for most video game developers, does make economic sense to develop in-house.  To provide this level of oversight, we have partnered with Level Access to implement APX in the mainstream. With the help of Level Access companies can;

Investigate

Determine which of their products are in-scope for CVAA compliance (i.e. “covered products”) and evaluate the relative priority of each of them

Train People

Train and educate designated employees on CVAA and accessibility requirements

Document

Develop policies and procedures to help ensure that covered products can meet relevant CVAA Requirements

Test

Verify conformance to CVAA obligations and performance standards, and verify compatibility with assistive technologies or accessibility features of platforms your products are deployed on (consoles, web, desktop, mobile)

Share

Provide information about product accessibility features in product documentation

Support

Provide accessible customer support mechanisms (e.g. web, phone, chat, etc.)

File

Keep records related to CVAA compliance

Contacts

If you would like to explore how CVAA affects your company’s products, please contact our partner, Level Access, a leading digital accessibility program consultant and solution provider who has experience working with gaming industry clients. You can reach Kenneth Tang, Enterprise Account Manager, by email at [email protected] or by phone at 415-802-1728 direct.