Reminder: TV Stations Must Caption IP Video Clips as of January 1, 2016

In July 2014, the FCC adopted new rules that require video clips delivered by Internet Protocol (IP) to be captioned if the clip is from video programming that was shown with captions on television. The rules and standards for captioning such IP clips are the same as those for regular, full-length programming if the clip is posted to a station’s website or app after it was shown on television with captions.

The FCC established January 1, 2016, as the deadline for compliance with this new obligation. Accordingly, all television stations must caption all “straight-lift” video clips, or clips that contain a single excerpt of a captioned television program with the same video and audio that was presented on television. Certain exemptions apply, including when the video clip is posted to a third-party website or app (i.e., one that is not owned or operated by the programming producer or distributor). In addition, the rules apply only to IP clips posted online after January 1, 2016. Also, the new captioning requirements do not apply to IP clips in which the audio is substantially different from the audio that accompanied the televised video.

Different deadlines apply to other types of captioned video:

(1) January 1, 2017: deadline for captioning of montages or a video clip created from multiple straight-lift clips.
(2) July 1, 2017: deadline for captioning of live programming (video clip posted online at or around the same time the program airs on television with captions) and near-live programming (video clip created and posted online within 24 hours of when the program first airs on television with captions).