There is an FCC-required captioning update to share that affects online video clips – As of January 1, 2017, if a prerecorded video of ANY length has been televised with captions, then it is required to have captions online. See further clarification below.
If you have any questions please reach out to your program manager.
- As of January 1, 2017, when is an online video required to have captions?
If a prerecorded video of ANY length has been televised with captions, then it is required to have captions online. This is the only criterion.
- What about live broadcasts?
Starting on July 1, 2017, online video that was broadcast live must have captions in place within 12 hours of the broadcast conclusion. Online video that was broadcast near-live (meaning broadcast less than 24 hours from performance and recording time) must be captioned within 8 hours of the broadcast conclusion.
- Are online montages required to have captions?
Yes, if they contain material that has been broadcast with captions. Online montages are not required to have captions if comprised solely of yet-to-be-aired material (e.g., previews) or material exempt from broadcast captioning rules (e.g., interstitials).
- Are previews required to have captions?
Yes. Generally, most 30 second previews are part of the nationally fed package for stations and therefore captioned on TV and therefore need to be captioned online.
- What if an uncaptioned preview of yet-to-be-aired footage remains online when the footage is televised? Must it then be captioned?
The FCC has not yet resolved this question. Assuming the preview was posted well prior to the airing, the FCC would hopefully accept it remaining uncaptioned. However, it would be most prudent to either remove the preview given its limited shelf life or add captions online once the content is broadcast if it continues to have value remaining online.
- Is it OK to refer to montages and previews as “promotional”?
Yes. The FCC is not concerned with such nomenclature in determining online video captioning requirements.
- Does digital-only material need to have captions?
If it is never broadcast, then it is not required to have captions online.
- What about clips containing a mix of aired and digital-only footage?
The FCC has not yet resolved the question of whether a “mash-up” clip containing televised and digital-only material must be captioned. For the time being, it seems acceptable to leave captions off of such “mash-up” clips. However, if the full clip itself is ever aired by any station with captions, then it requires captions online. If the full clip itself is aired without captions (because it may be eligible for a broadcast exemption as an interstitial), then it would not require captions online.