Accessibility laws · United States (telecoms)

Section 255 of the Communications Act

Make a phone, a headset, a router, a softphone, a voicemail system, or an interactive menu, and there is a 1996 accessibility law with your name on it. Section 255 of the Communications Act reaches manufacturers and service providers, not government agencies, which is what separates it from Section 508. The duty is to design, develop and fabricate the equipment to be accessible and usable by people with disabilities, if readily achievable. The technical detail lives in the Revised 255 Guidelines, which pull in WCAG 2.0 Level A and AA for content and software. And it has no deadline, because the trigger is your next release rather than a date on a calendar.

WCAG in the guidelines: 2.0 AA
Year the statute passed: 1996
Private lawsuits allowed: 0
Exclusive jurisdiction: FCC

What the law is

Section 255 arrived with the Telecommunications Act of 1996 and it is short. A manufacturer of telecommunications equipment or customer premises equipment has to make it accessible to and usable by people with disabilities, if readily achievable. A provider of telecommunications service has to do the same for the service. Where neither is readily achievable, both have to make the equipment or service compatible with the peripheral devices and specialized equipment people with disabilities already use, again if readily achievable. That phrase carries the whole weight of the statute, and it is borrowed rather than invented. Section 255 imports readily achievable straight from the ADA, so a Communications Act duty is limited by a test written for shops and restaurants.

The FCC turned that into rules, and its scope is wider than the 1996 wording suggests. Part 6 of the FCC's rules reaches five kinds of company. Three are the ones you would guess, being any provider of telecommunications service, any manufacturer of telecommunications equipment or customer premises equipment, and any telecommunications carrier. Two more arrived in 2007. They are any provider of interconnected VoIP service, and any manufacturer of equipment specially designed to provide interconnected VoIP and needed to use it. Part 7 adds a second population, covering voicemail and interactive menu services and the equipment that performs those functions. So the reader who owns a hosted phone system, an IVR, or a softphone is inside a rule written before any of those existed. There is also a duty aimed at the network itself. A telecommunications carrier must not install network features, functions or capabilities that fail the guidelines and standards under those parts.

Now the part that causes the confusion this page exists to clear up. The Access Board issued the Revised 255 Guidelines in the same January 2017 rulemaking that produced the refreshed Section 508 standards, and both now live in 36 CFR Part 1194. The 508 standards are Appendices A, C and D. The 255 Guidelines are Appendices B and C. Appendix C is in both lists, which means the two regimes literally share their technical chapters and differ only in the scoping chapter in front. Same building, two front doors. That is why a provision reserved in one is reserved in the other, and why somebody reading a technical requirement can genuinely lose track of which law they are under.

The reserved provision is worth naming, because the site already carries it on the 508 side. Provision 412.5, Real-Time Text Functionality, reads [Reserved] and has no content behind it. What fills the space around it is legacy TTY support at 412.8. That provision wants three things from the hardware. It wants a standard non-acoustic connection point for TTYs. It wants a microphone the user can switch on and off, so speech and TTY can be mixed inside one call. And it wants support for the commonly used non-proprietary TTY signaling protocols, wherever the system talks to the public switched telephone network. So a manufacturer is held to a TTY compatibility standard while the real-time text provision meant to succeed it sits empty. EN 301 549 has a real-time text clause at 6.2. The American guidelines have a blank.

This applies to you if…

You are a final assembler of telecommunications equipment or customer premises equipment that sells to the public or to vendors who sell to the public. That is the guidelines' own definition of manufacturer, and it excludes a component supplier who never ships a finished product.
You provide a telecommunications service, or an interconnected VoIP service, or you are a telecommunications carrier. All three are named separately in the FCC's rules and all three carry a duty.
You provide voicemail or interactive menu service, or you make the equipment that performs those functions. That is a separate rule with its own scope, and it is the one that catches an IVR vendor who does not think of themselves as a phone company.
You are shipping a new product, an upgrade, or a substantial change to an earlier version or model. That is the trigger. The guidelines apply when equipment is newly released, upgraded, or substantially changed from an earlier model. So a product you have not touched since 2016 sits in a different position from the one you are about to ship.
You sell to a federal agency, in which case this is the wrong page and Section 508 is the right one. The two are easy to confuse and they reach different people for different reasons. Nothing about Section 255 turns on who your customer is.

What it technically requires

Electronic content that is integral to using the equipment has to meet WCAG 2.0 Level A and Level AA success criteria and conformance requirements. So does the software, where software is integral to the telecommunications functions and has a user interface. Same version and level as Section 508, from the same rulemaking, and it has not moved since.
Four success criteria come off the list for non-web documents and non-web software, and knowing which four saves an argument. Bypass Blocks, Multiple Ways, Consistent Navigation, and Consistent Identification are all excepted, because each assumes a set of pages rather than one piece of software. Non-web software also drops the complete processes conformance requirement, though a separate provision puts an equivalent duty back for any activity that takes multiple steps.
Accessibility cannot go backwards. No change may be undertaken that decreases, or has the effect of decreasing, the net accessibility, usability, or compatibility of the equipment. The single exception is that you are still allowed to discontinue a product. Nothing else on this site carries a no-backsliding rule this plain, and it means a redesign that quietly drops a feature disabled users relied on is a violation on its own terms.
Your documentation and your support have to be accessible too, and the phrase to remember is at no additional charge. You have to describe the accessibility and compatibility features on request, in alternate formats or modes where needed. You have to provide end-user documentation in alternate formats or modes on request. You have to make the call centers and service centers that support the product usable. All three at no extra cost, and your general product information has to say how to ask.
You have to build the evaluation into the product process rather than bolt it on at the end. The FCC requires manufacturers and service providers to evaluate accessibility, usability and compatibility throughout design, development and fabrication, as early and as consistently as possible. Identifying barriers is part of that. Four factors then have to be considered, and two of them name disabled people directly. One covers including them in market research. The other covers including them in product testing, pilot demonstrations and trials.
Be careful how you read that last one, because vendors overstate it. The rule says a manufacturer shall consider those factors as the manufacturer deems appropriate. That is a factor, not a mandate. Compare the Air Carrier Access Act, where the regulation says the website must be tested in consultation with people with disabilities, full stop. Two federal regulators, the same idea, and only one of them made it a requirement.

All roads lead to WCAG. Start with Level AA, the legal standard or the full 55-rule library. Unfamiliar term along the way? The A to Z glossary decodes it.

How it is enforced

Section 255 is the one law on this site that bars a private lawsuit in its own text. Nothing in it authorizes any private right of action to enforce any requirement of the section or any regulation under it, and the FCC has exclusive jurisdiction over any complaint. So the lawsuit numbers that dominate the ADA page have no equivalent here. There is one door and the FCC is standing in it.

That cuts both ways for a manufacturer, and it is worth being clear-eyed about which way. There is no plaintiff's bar, no statutory damages, and no settlement industry attached to Section 255. There is also no way to settle a complaint quietly with an individual and move on, because the individual was never the one holding the enforcement power. What you get instead is a regulator with a docket, a record, and a long memory about your product line.

One thing this page cannot tell you, and we would rather say so than guess. The complaint procedure itself no longer sits in the FCC rule parts that carry the substantive duties, and the part that should hold it was unreachable every time we tried to read it. So we are not describing the form, the route, or any filing deadline. What is sourced and certain is the destination. Complaints under Section 255 go to the FCC and only to the FCC, and a lawyer who practices in front of it can tell you the rest.

Key dates

Feb 8, 1996Section 255 is enacted as part of the Telecommunications Act
Nov 19, 1999The FCC's Section 255 rules are published
Aug 6, 2007Interconnected VoIP providers and equipment makers are added to the FCC rules
Jan 18, 2017The Access Board publishes the Revised 255 Guidelines alongside the refreshed 508 standards, pulling in WCAG 2.0 AA
Next releaseThe guidelines apply when equipment is newly released, upgraded, or substantially changed. There is no calendar date to wait for

What to do about it

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Orientation only, current as of August 2026. Not legal advice, and no attorney-client relationship is created. For your specific situation, talk to your own lawyer.