Potential New Rules for Closed Captions

Guest Post: The following article was sent by Bob O’Brien, of Video Design Productions, Inc. I have not yet had time to verify all this information, but wanted to alert you to it; just in case. Please note that Bob’s article is AI generated, which means we need to read this with caution.

LARRY’S BIG NOTE: As you’ll read in the comments, not all of this information is accurate. As Tod writes: “Please do not trust this. It’s wrong in many ways typical of AI. WCAG 2.1 compliance has been in effect across federal agencies (since 2024). What changes next April 2026 is to whom this applies. As of next year, more smaller institutions will be covered, such as the college referenced above and local governments. WCAG isn’t changing.”

If you know of an accurate source for WCAG information, please add it in the comments.

I learned something from a client yesterday that, I think, is going to greatly affect video producers everywhere… and we need to start planning now.

A college wanting to show some of my client’s videos in classroom next year asked: “As you may know, new ADA compliance requirements will go into effect in April 2026. These new regulations require that all web content meet WCAG 2.1, Level AA requirements. Is your website, and are your videos compliant?”

So, as we do, I did an AI-assisted Google search. Here is the response.

What does a video producer need to do to make videos WCAG 2.1 Level AA compliant?

To create videos that are WCAG 2.1 Level AA compliant, a video producer must incorporate specific accessibility features into both pre-recorded and live content. This involves providing high-quality captions, audio descriptions, and accessible player controls to ensure all viewers, including those with hearing, visual, or cognitive disabilities, can understand and operate the video.

Captions and transcripts

Captions are a text alternative for the spoken words and relevant sounds in a video, while a transcript is a complete text version of the video’s audio.

Requirements for producers

• Captions: All pre-recorded and live videos must have accurate, synchronized captions.
• Transcript: For pre-recorded video or audio-only content, provide a downloadable, text-based transcript. For videos with significant visual information, a descriptive transcript is required.
• Quality: Do not rely solely on auto-generated captions, which can be inaccurate. Manually edit them or use a professional service to ensure at least 99% accuracy.
• Content: Captions must include all spoken dialogue and identify speakers. Important non-speech sounds like [music playing], [doorbell rings], or [applause] must also be included in brackets.
• Readability: Ensure captions are presented in a clear, sans-serif font with a high-contrast background. They should not obscure important visual content and must be readable when resized up to 200%.

Audio descriptions

Audio descriptions are narrative tracks that describe important visual details in a video for viewers who are blind or have low vision.

Requirements for producers

• Pre-recorded videos: An audio description must be provided for all pre-recorded video content.
• Descriptive script: A producer should review the video for crucial visual information not conveyed in the main audio track. This can include on-screen text, character actions, visual expressions, or changes in scene.
• Placement: Insert descriptions during natural pauses in the video’s dialogue or primary audio. If pauses are too short, create a version with “extended audio description” that briefly pauses the video to make room.
• Integrated audio: For new productions, incorporate descriptions directly into the main audio during the scripting phase. This avoids the need for a separate audio description track and creates a single, inclusive deliverable.

Accessible player and interface

The video player itself must be designed to be accessible to people who use assistive technologies like screen readers or rely on keyboard navigation.

Requirements for producers

• Keyboard accessible: All controls, including play, pause, volume, and captions, must be fully operable using only a keyboard (Tab, Enter, Space, arrow keys).
• No autoplay: Videos should not play automatically when a webpage loads, as this can interfere with screen readers or trigger adverse reactions in users with cognitive disabilities.
• Support for features: Ensure the player supports and correctly renders captions and audio description tracks. The platform hosting the video, such as YouTube or Vimeo, must have the necessary accessibility features enabled.

Visual and design considerations

Certain visual elements in a video can create accessibility barriers or health risks.

Requirements for producers

• Flashing content: Do not use content that flashes more than three times in a one-second period to prevent triggering seizures in people with photosensitive epilepsy.
• Text on screen: Any on-screen text, such as titles or lower-thirds, must have a color contrast ratio of at least 4.5:1 against its background. The text should also be large, legible, and displayed long enough for users to read comfortably.
• Color as meaning: Never rely on color alone to convey important information. For instance, do not use a green bar and a red bar to show “pass” or “fail” unless you also include text labels or other distinctions.

Pre-production planning and testing

Producers should incorporate accessibility into the video production workflow from the very beginning, rather than adding it on as an afterthought.

Requirements for producers

• Plan ahead: Make accessibility a part of the initial scripting, storyboarding, and budgeting. This prevents expensive and time-consuming fixes later.
• Test: Conduct manual testing to check the accuracy of captions and descriptions.
• Review the video with a screen reader and navigate the controls using only a keyboard to identify any issues.
• Consider your audience: For videos serving audiences that include Deaf individuals whose native language is a sign language (like ASL), consider providing sign language interpretation. (Note that while a AAA requirement, it is best practice for those specific audiences).

Bob continues: I thought our level of ADA compliance stopped at providing closed captions, but, if I’m reading this right, it sounds like we will also need to also provide a transcript, as well as a descriptive narrative track, among other things.

Maybe I’m blowing this out of proportion, but thought I’d reach out to you, in case you have answers (as you usually do).

Larry adds: I don’t have any answers and need to learn more about how this potentially affects us. The player requirements are especially tricky.