If your streaming app carries programming that aired on US television with captions, the FCC requires you to caption it online too. The rules are narrower than many publishers assume in some places and stricter in others: they cover specific programming from specific dates, they split duties between the content owner and the distributor, and they require caption controls inside your player. This guide covers what the rules actually require, which caption formats each major streaming platform reads, and where the law stops.
Which programming the FCC's rules cover
The FCC's IP closed captioning rule (47 CFR 79.4), which implements the 21st Century Communications and Video Accessibility Act (CVAA), covers full-length video programming shown on US television with captions:
- Prerecorded programming not edited for internet distribution that aired with captions on or after 30 September 2012.
- Live and near-live programming that aired with captions on or after 30 March 2013.
- Prerecorded programming edited for internet distribution, on or after 30 September 2013.
A title already in your online library that later airs on TV with captions must be captioned online within 15 days. Clips are covered too, but narrowly: the rule applies when a distributor or provider posts, on its own website or app, a clip of programming that it showed on US television with captions. A service that carries the clip without having shown the programming on TV is not covered, and neither are clips added to the online library before the programming aired on TV with captions. The clip deadlines were 1 January 2016 for single excerpts, 1 January 2017 for montages, and 1 July 2017 for live and near-live clips, with 12- and 8-hour grace periods.
Programming that has never aired on US television, such as a streaming-only original, is outside this rule.
Who is responsible for what
- Programming owners must provide captions of at least the same quality as the television captions. Delivering them in SMPTE-TT format is a safe harbor.
- Distributors, including an OTT service that delivers the programming, must render or pass through those captions at that quality and publish a contact for caption complaints.
- If you provide the player app, it must give viewers caption controls under 47 CFR 79.103(c): character colour and opacity, sizes from 50% to 200%, fonts, edge styles, caption background colour and opacity, caption window colour and opacity, language selection, and a preview of the settings. It must keep the viewer's choices as the default until they change them, and display pop-on, roll-up and paint-on captions.
What caption quality means
The FCC's caption quality standards (47 CFR 79.1(j)) were written for television, and they reach online video through the same-quality duty above. They cover four things:
- Accuracy. Captions match the spoken words, identify speakers, and describe relevant sounds.
- Synchronicity. Captions coincide with the spoken words and sounds "to the greatest extent possible". There is no fixed millisecond tolerance.
- Completeness. Captions run from the beginning to the end of the programme.
- Placement. Captions do not block important visual content such as on-screen text or faces.
The FCC deliberately rejected a strict numeric accuracy standard when it adopted these rules (FCC 14-12). Near-perfect word accuracy is common industry practice, but it is not a number in the rule.
Caption formats by platform
Each platform documents different caption formats, so check this before you pick one for your whole library.
| Platform | Caption formats it documents | Worth knowing |
|---|---|---|
| Roku | Embedded CEA-608/708; WebVTT inside HLS or DASH; SMPTE-TT embedded or sidecar; SRT, TTML and DFXP sidecars | Certification requires captions wherever the law does. Captioned channels must follow the global caption settings and offer On, Off, On instant replay and On mute. |
| Fire TV (Fire OS) | Whatever your player supports; with Media3, the Android formats below | Apps must build their own caption customisation settings. |
| Fire TV (Vega OS) | Embedded CEA-608/708, parsed natively; sidecar TTML, WebVTT and SAMI | Applies to Fire TV devices running Vega OS rather than Android-based Fire OS. |
| Android TV, Google TV and Android phones | Media3: sidecar WebVTT, TTML, SubRip and SSA/ASS; CEA-608/708 and WebVTT in HLS; TTML, WebVTT and CEA-608/708 in DASH | These are Media3's documented formats; a different player may differ. |
| Apple TV and iPhone | CEA-608/708 carried in the video segments; WebVTT or IMSC1 subtitle tracks inside the HLS stream | AVPlayer applies the viewer's accessibility caption preferences by default. A standalone sidecar WebVTT file is not a documented option. |
| Samsung Tizen | SAMI, SubRip, SMPTE-TT and sidecar WebVTT; TTML and DFXP only with Smooth Streaming | Samsung also lists closed caption support without naming the formats. |
| LG webOS | WebVTT | The only subtitle format listed for webOS TV 26. |
| Web browsers | WebVTT through the HTML <track> element | Style captions to follow the viewer's choices. |
WebVTT is the one format every platform in the table reads in some form, and the only one LG lists, so it is the natural default for new content. For broadcast-origin programming, keep the embedded CEA-608/708 captions for the platforms that read them and deliver a WebVTT or SMPTE-TT version alongside.
Closed, open and burned-in captions
Closed captions can be switched on and off by the viewer; open captions are burned into the picture and cannot be (W3C). Embedded CEA-608 and 708 captions are closed captions. Burning captions into the video also removes the size, colour and font controls the FCC requires players to offer, so keep captions closed for any programming the rules cover.
Audio description: a TV rule, not a streaming one
The FCC's audio description rules (47 CFR 79.3) apply to two groups, each at 87.5 hours a quarter: broadcast stations affiliated with ABC, CBS, Fox and NBC in the top 120 markets (adding 10 markets a year through 2035), and cable and satellite systems with 50,000 or more subscribers, for each of the top five cable networks. The underlying statute limits these rules to programming transmitted for display on television, so streaming distribution is not covered. Roku's certification criteria do require audio description wherever the law requires it.
The 2024 rule on caption settings
In July 2024 the FCC ordered that caption display settings be "readily accessible" (FCC order), judged on proximity, discoverability, previewability, and consistency and persistence. It applies from 17 August 2026 to devices with next-generation operating systems deployed after that date, and it binds device manufacturers and cable and satellite providers, not apps that viewers install. It still matters to app makers: the consistency factor includes letting apps read the operating system's caption settings through APIs, so players that use those settings match what viewers choose once for the whole device.
Enforcement and penalties
Viewers can complain to the FCC or to the distributor, which must publish a contact for caption complaints. Fines are capped by the FCC's forfeiture rules (47 CFR 1.80). For entities that are not broadcast licensees or cable operators, which likely includes most OTT distributors, the maximum is $25,132 per violation or per day of a continuing violation, up to $188,491 for one continuing violation, and a non-licensee must first receive a citation. The FCC cancelled its 2026 inflation adjustment, so these 2025 amounts still apply (Federal Register).
Streaming-only originals and the ADA
The FCC's rules do not reach programming that never aired on US television, and whether the Americans with Disabilities Act does is unsettled. The Justice Department has no web accessibility regulation for private businesses, although its 2022 guidance says the ADA covers their online services (ADA.gov). Courts are split. In NAD v. Netflix (2012), a federal court in Massachusetts let an ADA captioning claim go forward, and Netflix settled by committing to caption its whole catalogue within two years (DREDF). In Cullen v. Netflix (2015), the Ninth Circuit held in an unpublished decision that Netflix is not subject to the ADA because it is not a physical place (decision). Captioning everything is the lower-risk choice.
The bottom line
If your programming aired on US television with captions, caption it online at the same quality, give viewers the caption controls the FCC requires, and deliver formats every platform you ship can read. OTTEngine takes WebVTT or SRT caption files with each video, and an optional AI add-on translates them into other languages. Start a free trial to try it with your own caption files.
Frequently Asked Questions
Are closed captions legally required for streaming?
Yes, for full-length programming shown on US television with captions after the FCC's 2012 and 2013 start dates, and for clips of it that the same distributor or provider posts on its own site or app, unless the clip was already online before the programming aired. Streaming-only programming that never aired on TV is not covered by the FCC's rules.
What is the difference between CEA-608 and WebVTT?
CEA-608, and its successor CEA-708, are broadcast caption formats carried inside the video stream. WebVTT is a text caption format used on the web and inside HLS and DASH streams. Both are closed captions that viewers can switch off. Every major streaming platform reads WebVTT in some form, and many also read embedded 608/708.
Does the FCC's captioning rule apply to streaming-only originals?
No. It covers programming shown on US television with captions. Whether the ADA requires captions for streaming-only content is unsettled, and courts have disagreed, so captioning everything is the lower-risk choice.
Can I auto-generate captions with AI?
Yes, as a starting point. Captions for covered programming must match the quality of the TV captions, so review machine output for accuracy, speaker identification and sound descriptions before you publish.
Is there a numeric accuracy or timing requirement?
No. The FCC's standards require captions to be accurate, synchronous, complete and properly placed, and to coincide with the audio "to the greatest extent possible", but the FCC declined to set a percentage or millisecond threshold.
Do the FCC's audio description rules apply to streaming apps?
No. They apply to broadcast stations and to cable and satellite systems, and the statute limits them to programming transmitted for display on television.
What caption format should I use for streaming?
WebVTT is the safest default for new content, because every major platform reads it in some form and it is the only format LG lists. For programming that aired on TV, keep the embedded CEA-608/708 captions for the platforms that read them and deliver WebVTT or SMPTE-TT alongside; SMPTE-TT is also the FCC's safe harbor format for content owners.
Who is responsible for captions, the content owner or the streaming service?
Both have duties. The programming owner must provide captions of at least TV quality, and the distributor must render or pass them through at that quality, publish a contact for caption complaints and, if it provides the player, offer the required caption controls.
What caption settings must my player offer?
If you provide the player app, the FCC's rules require controls for character colour and opacity, sizes from 50% to 200%, fonts, edge styles, caption background colour and opacity, caption window colour and opacity, language selection and a preview of the settings, and the player must keep the viewer's choices as the default until they change them. On Roku, captioned channels must also follow the global caption settings and offer On, Off, On instant replay and On mute.