[games_access] CVAA compliance deadline set

Ian Hamilton i_h at hotmail.com
Fri Jan 12 12:21:41 MST 2018


It did have the small companies waiver in there initially, but as far as I remember only intended as an initial bit of extra implementation time rather than a permanent exemption. It expired a long time ago, games have now had a few extra years' r&d / implementation time on top of that initial extra year.

Personally I think there needs to be a permanent small companies exemption. Having to implement extra features, perform evaluations and file certification reports with the FCC isn't really compatible with, for example, a one-person self funded indie hoping to get the game launched in time to be able to make their mortgage payments.

The proposed European Accessibility act does have a small companies exemption, though it's only for micro business of ten people or less. There's also an exemption for having low annual revenue, I cant remember what it is off the top of my head but I think the revenue exemption is a bit more forgiving than the headcount exemption.

The people on EAA definitely get the issue though, they have a section in the copy saying that even just the reporting requirement alone is too much of a burden for small businesses, let alone implementation. They still encourage small businesses to implement whatever they are able to, but there's no requirement involved.

Ian

From: Thomas Westin
Sent: Friday, 12 January, 12:48
Subject: Re: [games_access] CVAA compliance deadline set
To: games_access at lists.igda.org


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://nam03.safelinks.protection.outlook.com/?url=https%3A%2F%2Fapps.fcc.gov%2Fedocs_public%2Fattachmatch%2FFCC-11-151A1.pdf&data=02%7C01%7C%7C43ccc710311743a4eec508d559bacd40%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636513581190704643&sdata=5YDd7CMzAxg6bsr6%2BzgqSldSf2EZMzDT7ecKYusep1E%3D&reserved=0>

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://nam03.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.engadget.com%2F2017%2F12%2F28%2Ffcc-extends-waiver-for-video-game-accessibility-for-the-last-tim%2F&data=02%7C01%7C%7C43ccc710311743a4eec508d559bacd40%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636513581190704643&sdata=HNbW1Fsnpdwd1ajoCLUIB2qo8bcR7UTMaL5lrQKp6dQ%3D&reserved=0>

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://nam03.safelinks.protection.outlook.com/?url=https%3A%2F%2Fdeveloper.paciellogroup.com%2Fblog%2F2014%2F04%2Fcvaa-fostering-innovation-change%2F&data=02%7C01%7C%7C43ccc710311743a4eec508d559bacd40%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636513581190704643&sdata=9BWMcpdoO%2B%2BawDpLkHHHsWbEGSB5vk%2BZHbOPfwwWISQ%3D&reserved=0>

Ian
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