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U.S. Communications Act (Section 255) and Digital Accessibility: What to know 

Section 255 of the U.S. Communications Act is a federal accessibility requirement focused on telecommunications. In plain terms: if you manufacture telecommunications equipment or provide telecommunications services, you are expected to make them accessible to and usable by people with disabilities—when doing so is “readily achievable” (i.e., accomplishable without much difficulty or expense). If full accessibility is not readily achievable, Section 255 emphasizes compatibility with commonly used assistive technologies and specialized customer premises equipment, where readily achievable. 

Note: This content is provided for general information only and does not constitute legal advice. If you need a formal interpretation of requirements for your organization, consult qualified legal counsel and your compliance team. 

Who Section 255 applies to

  • Manufacturers of telecommunications equipment and customer premises equipment (CPE). 

  • Providers of telecommunications services.

In practice, this is most relevant for organizations that sell or deliver telecom services, devices, and the supporting customer experience (including support channels tied to those services). 

What Section 255 requires (in plain language)

1. Make products and services accessible and usable (when readily achievable). 

“Accessible” generally means people with disabilities can perceive and operate the input/controls and outputs/displays. “Usable” includes being able to learn and operate the features effectively, and being able to access instructions, user guides, and support services (e.g., help lines, repair, billing) in a functionally equivalent way.

2. If full accessibility isn’t readily achievable, ensure compatibility (when readily achievable). 

Where you cannot make the equipment or service fully accessible, Section 255 requires compatibility with peripheral devices and specialized customer premises equipment commonly used by people with disabilities. 

3. Complaints and enforcement.

Section 255 complaints are handled through the FCC, which also publishes consumer guidance describing the expectations and examples. 

What’s typically in scope
(common examples)

  • Telecommunications equipment used at home or work (examples include telephones, wireless handsets, fax machines, answering machines, and pagers). 

  • Telecommunications services, including common calling features (e.g., call waiting, speed dialing, call forwarding, caller ID) and similar functions. 

  • Voicemail and interactive voice response (IVR) systems that provide menu-based choices to callers. 

What this means for “digital accessibility”
in practice 

While WCAG is the most common benchmark people think about for websites and apps, Section 255 is often experienced by customers through the end-to-end telecom journey—including devices, service flows, and the supporting “digital” touchpoints that enable access and use. Practically, organizations reduce risk when they treat accessibility as a lifecycle requirement across onboarding, billing, support channels and documentation, IVR/voicemail experiences, and compatibility with assistive technology. 

What you should do next (practical steps)

  1. Confirm applicability and scope: Identify whether you manufacture covered equipment/CPE or provide covered telecom services, and which products/services/features are in scope. 

  2. Identify high-risk customer journeys: Prioritize the journeys customers must complete independently (onboarding, billing, support, IVR/voicemail, and device setup). 

  3. Assess accessibility and usability: Test the real experience for users with different disability-related needs (not just a single channel). 

  4. Plan remediation and governance: Establish a repeatable process so accessibility is maintained as products and services evolve. 

  5. Document decisions and due diligence: Maintain evidence of your accessibility efforts and outcomes over time (especially important in regulated contexts). 

How 4Point can help

If your organization is impacted by Section 255 (or adjacent accessibility expectations), 4Point can help you:

Start with an accessibility audit. 4Point can run a practical audit to establish a baseline, identify the highest-risk barriers, and give you a prioritized remediation roadmap. 

  • Scoping session: confirm which forms are in scope, the number to be reviewed, and the accessibility standard(s) to assess against. 

  • Forms accessibility audit: review an agreed number of forms and document accessibility gaps. 

  • Conformance report and prioritization: provide conformance findings, severity ratings, and a recommended fix order. 

  • Recommendations and remediation plan: share recommendations for addressing identified gaps and provide a statement of work for remediation of the audited forms (remediation is not included in the audit engagement). 

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Ottawa, Ontario, Canada K2E7L6

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