Video accessibility is a checklist, not a vibe: captions that match the dialogue word for word, readable contrast on every burned-in and overlay text, a described version where the visuals carry meaning alone, and caption files that travel with the delivery. This post is that checklist in four phases — contract, edit, review rounds, delivery — plus the current legal facts for US public-sector work, date-stamped November 2026 because this area moved twice this year.
The legal facts, date-stamped (Nov 2026)
The US Department of Justice's ADA Title II web rule (published April 2024) sets WCAG 2.1 Level AA as the technical standard for state and local government web content and mobile apps. Two things happened since, and both matter for anyone producing video for public entities:
- The deadlines moved. DOJ's own Interim Final Rule (April 20, 2026) extended compliance one year: April 26, 2027 for public entities serving 50,000+ people, April 26, 2028 for smaller entities and special district governments.
- The rule still stands. No court vacated it — a 2025 "the rule was struck down" story that circulates is wrong. What did happen: the National Federation of the Blind sued DOJ in May 2026 over the extensions, and the underlying Title II effective-communication obligation (captions as auxiliary aids, 28 CFR 35.160) applies to government video now, deadline or no deadline.
Practical read: treat WCAG 2.1 AA as the working standard for any public-sector deliverable regardless of the calendar, because complaints and lawsuits never waited for deadlines. Outside government, the FCC's caption rules apply only to programming that first aired on captioned US television; for everything else, accessibility is a client-policy and quality question — which is exactly what a review checklist is for.
Phase A — Contract (decide scope before the edit)
- Write the caption spec into the proposal: burned-in, sidecar SRT/VTT, or both; language(s); who drafts the transcript and who proofreads it.
- Decide audio description scope: needed when visuals carry meaning the audio doesn't (on-screen text, data, actions). WCAG 2.1 AA criterion 1.2.5 requires it for prerecorded media in covered contexts; a text alternative (1.2.3) is the A-level fallback.
- Agree a deadline for remediated re-exports (contrast fixes, caption timing) so the accessibility pass is scheduled, not squeezed into delivery week.
Phase B — Edit-time items (cheapest to fix here)
- Burned-in text contrast: 4.5:1 for normal text, 3:1 for large text (WCAG 1.4.3); UI graphics and meaningful shapes at 3:1 (1.4.11). White captions over a bright sky fail this constantly — check against the lightest and darkest frame in the shot.
- Safe margins for captions and overlay text on every aspect variant, not just the 16:9 master.
- No meaning conveyed by color alone (differences in charts, labels, team lanes — pair color with a label or shape).
- Flashing content avoided (three flashes threshold, 2.3.1 territory) — relevant for stylized cuts and social variants.
Phase C — The accessibility review round
Make accessibility a named pass inside the review round instead of a silent hope. On the review link:
- Watch captions against audio line by line — the full method lives in the caption review workflow; the accessibility bar is stricter: accuracy, synchronicity, completeness, and placement all checked, not just spelling.
- Play one segment muted — can a viewer follow the story from captions plus visuals alone? Note where on-screen text is spoken too late or never.
- Check contrast on the actual frames where text sits over footage, and on the vertical cut (mobile viewers get smaller text and brighter screens).
- Log findings as review comments on the exact timestamp, not as a summary email — the fix list and the video stay in one place.
| WCAG criterion | What it means for video | Where it fails most |
|---|---|---|
| 1.2.2 Captions (Prerecorded) — A | Captions for all prerecorded audio+video | Auto-captions shipped without a proofread pass |
| 1.2.5 Audio Description (Prerecorded) — AA | Described version when visuals carry meaning | On-screen stats and titles never voiced or described |
| 1.4.3 Contrast (Minimum) — AA | 4.5:1 text / 3:1 large text | White burned-in captions over bright footage |
| 1.4.11 Non-text Contrast — AA | 3:1 for meaningful graphics/UI | Progress bars, logo lockups, chart segments |
| 1.4.2 Audio Control — A | Pause/stop for auto-playing audio over 3s | Autoplay embeds on client landing pages |
Phase D — Delivery
- Ship the caption files with the master — SRT/VTT sidecars named to match (the naming conventions pattern), not "captions_final(3)".
- State what the player does: if the deliverable is a hosted page, confirm captions toggle on by default or per user, and the player is keyboard-operable for reviewers and viewers who navigate by keyboard.
- Archive the described version with the master so next year's re-cut doesn't start the accessibility work from zero — the delivery checklist archive phase is where it lives.
- Keep the export honest: captions verified on the delivery master, not only on the review export — the two files differ on purpose (review export vs delivery master).
FAQ
Do client videos legally need captions in the US?
Depends on who is publishing. Programming that first aired on captioned US television is FCC-caption-mandated online. State and local government content must communicate effectively under ADA Title II regardless of deadlines. For everyone else, captions are driven by client policy, platform policy, and the growing habit of treating WCAG 2.1 AA as the standard — the checklist above is how you prove it was done.
What are the current ADA Title II web accessibility deadlines?
As of November 2026: April 26, 2027 for public entities serving 50,000+ people and April 26, 2028 for smaller entities and special districts — extended one year by DOJ's April 2026 Interim Final Rule. The rule itself remains in force; a court did not strike it down. Re-check before relying on the dates: litigation over the extensions was pending as of this writing.
Which WCAG criteria apply to video review work?
The core set: 1.2.2 prerecorded captions, 1.2.5 audio description for AA-level scope (1.2.3 media alternative at A), 1.4.3 text contrast (4.5:1), 1.4.11 non-text contrast (3:1), and 1.4.2 audio control for autoplay. Everything else in WCAG mostly targets the page around the player — which your client's web team owns.
Who should run the accessibility pass during review?
Whoever proofs captions in the normal round — usually the editor plus one fresh pair of eyes — with the client's brand/compliance reviewer confirming scope on round one. The pass is one extra watch-through with the mute button and a contrast check; folding it into the existing review round keeps it from becoming a separate unpaid phase.