[games_access] CVAA compliance deadline set

[Thomas Westin]

I did some more searching now, and the FCC text, in the Waiver section says,

Paragraph: "206. We temporarily exempt entities that manufacture ACS equipment or provide ACS that, along with any affiliates, meet the criteria for a small business concern for their primary industry under SBA’s rules and size standards.556 A small business concern, as defined by the SBA, is an “entity organized for profit, with a place of business located in the United States, and which operates primarily within the United States or which makes a significant contribution to the U.S. economy through payment of taxes or use of American products, materials or labor.”

Paragraph 207 lists "Software Publishers" (of services) to be classifed as small businesses if the have ”$25 million or less in annual receipts”. Quite a different definition than 30 employees or more, but maybe something equivalent? …someone with better understanding of business and economics could perhaps judge that.

An interesting thing to note is that the exemption - as I understand the above - only applies to small businesses located in the US; so essentially all non-US small business are not exempted.

Best,
Thomas


> 12jan. 2018 kl. 13:47 skrev Thomas Westin <thomas at westin.nu>:
> 
> Great summary Ian.
> 
> Maybe it can be worth adding that communication functionality, or “advanced communications services” mean: "(A) interconnected VoIP service; (B) non-interconnected VoIP service; (C) electronic messaging service; and (D) interoperable video conferencing service.” Cited from paragraph 30 in
> https://apps.fcc.gov/edocs_public/attachmatch/FCC-11-151A1.pdf <https://apps.fcc.gov/edocs_public/attachmatch/FCC-11-151A1.pdf>
> 
> I was surprised that ”there is currently no exemption for small companies” - I could have sworn I have read somewhere in the FCC docs that it concerned only companies larger than 30 employees, but it seems I have mixed something up previously as I can’t find that now… 
> 
> Best,
> Thomas
> 
>> 11jan. 2018 kl. 20:11 skrev Ian Hamilton <i_h at hotmail.com <mailto:i_h at hotmail.com>>:
>> 
>> 
>> A final waiver has been grated, with compliance date now fixed at 1st Jan 2019. Any game released on or after this date that has internal communications functionality is covered, meaning obligations in five areas: 
>> 
>> 1. Accessibility of the functionality itself
>> 2. Accessibility of navigating to and operating the functionality
>> 3. If any is present, accessibility of instructions on how to use the functionality
>> 4. Testing with people with disabilities in the design process of the functionality
>> 5. Producing and filing compliance reports with the FCC
>> 
>> Being reported to the FCC for non-compliance means an initial negotiation period with the FCC, if not resolved through that it can then be followed by $100k/day fines, up to a total maximum of $1m.
>> 
>> Most of it is pretty straightforward, but the two things that jump out are firstly the requirement for being navigate to and operate comms functionality if you are blind, essentially meaning text to speech for in-game UI, and secondly that unlike most other US accessibility legislation there is currently no exemption for small companies (things like ADA have a blanket exemption based on a number of employees or revenue threshold).
>> 
>> CVAA does include a concession to assess your game and prove that certain requirements would not be reasonable for you to implement, but the final decision on that is made by the FCC. And you still must actually carry out the assessment and report to the FCC about it, all of which obviously entails cost in itself.
>> 
>> https://www.engadget.com/2017/12/28/fcc-extends-waiver-for-video-game-accessibility-for-the-last-tim/ <https://www.engadget.com/2017/12/28/fcc-extends-waiver-for-video-game-accessibility-for-the-last-tim/>
>> 
>> The CVAA legislation itself is a huge tome of legalese, but the appendix on this article contains a summary of requirements: 
>> 
>> https://developer.paciellogroup.com/blog/2014/04/cvaa-fostering-innovation-change/ <https://developer.paciellogroup.com/blog/2014/04/cvaa-fostering-innovation-change/>
>> 
>> Ian
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