Yes, Your Municipality Is Required to Caption Video Content

Captioning video content often gets treated as a nice-to-have or something that only applies to broadcast media. However, the legal requirements say otherwise and have become more specific about what’s expected. 

This article breaks down the legal framework behind video accessibility, explains which types of content require captions, and walks through practical steps to get your municipality on track. 

What the Law Says About Video Accessibility 

Before making changes, it helps to understand where the requirements come from. Video accessibility for municipalities isn't based on a single rule. It sits at the intersection of a few key legal standards. 

ADA Title II Covers State and Local Government 

Title II of the Americans with Disabilities Act requires that all programs, services, and activities provided by state and local governments be accessible to people with disabilities. That language has always been broad, but digital content lived in a gray area for a long time. It doesn't anymore. 

Your website, your video library, your posted meeting recordings. These are all extensions of the services your municipality provides. If a resident can't access them because of a disability, that's a compliance issue. 

The 2024 Rule Update Made Digital Requirements Explicit 

In 2024, the Department of Justice updated its ADA Title II rule to specifically address web content and mobile applications. The update references WCAG 2.1 AA as the technical standard municipalities need to meet. Video content falls squarely within that scope. 

This matters because it removes ambiguity. Before the update, municipalities could argue that digital accessibility was implied but not clearly defined. That argument no longer holds. The expectation is now documented, specific, and enforceable. 

Section 508 Applies to Federally Funded Content 

If your municipality receives federal funding, Section 508 of the Rehabilitation Act also applies. Most do in some form.  

Section 508 includes specific requirements for synchronized captions on multimedia content. This adds another layer of obligation on top of ADA Title II, particularly for content tied to federally funded programs or initiatives. 

Types of Video Content That Require Captions 

One of the most common questions we hear is, "Does this apply to all of our videos?" The short answer is yes. If it's published by your municipality and available to the public, it needs to be accessible. Here's how that breaks down in practice:  

Public Meetings and Council Sessions 

Recorded council meetings, planning sessions, and public hearings posted online must include captions. These recordings are of how many residents stay informed about decisions that affect their daily lives. For residents who are deaf or hard of hearing, captions are the only way to participate. 

Informational and Educational Videos 

Videos explaining city services, permit processes, emergency procedures, or community programs all fall under accessibility requirements. These are the videos residents rely on when they need to understand how something works or what steps to take. If that information is only available through audio, you're leaving people out. 

Social Media and Promotional Content 

This is the one that catches a lot of municipalities off guard. Videos posted to Facebook, YouTube, Instagram, or any other platform are still municipal communications. The platform doesn't change the obligation.  

If your communications team posts a video about a new park opening or a winter weather advisory, it needs captions just like anything on your website. 

Live Streams and Real-Time Events 

Live broadcasts present a unique challenge, but the requirement still applies. Real-time captioning or CART (Communication Access Realtime Translation) services are needed to make live events accessible as they happen. Planning this ahead of time is the key to making it manageable. 

The Risks of Skipping Captions 

We understand that resources are tight. Municipal teams wear a lot of hats. Adding captioning to the workflow can feel like one more thing on an already full plate. But the risks of not addressing it are real, and they tend to grow over time. 

Complaints and DOJ Investigations 

Residents can file accessibility complaints directly with the Department of Justice. When investigations happen, they often result in settlement agreements that require remediation of existing content and ongoing monitoring and reporting. That's a significant commitment of time and resources that could have been avoided. 

Exclusion of Residents from Public Services 

This is the one that matters most. When video content isn't accessible, residents with hearing disabilities can't access the same information as everyone else. That's a legal problem and a trust problem. People need to know their local government is working for all of them. Accessibility gaps undermine civic participation and public confidence. 

Increased Remediation Costs Later 

Captioning videos as they're produced is significantly less expensive than going back to caption a backlog of existing content. The longer you wait, the larger the backlog grows. And the more it costs to catch up. Building captioning into your process now saves money and stress down the road.
 

How to Meet Video Accessibility Requirements 

The good news is that meeting these requirements doesn't require a massive overhaul all at once. It starts with understanding what good looks like and building it into how you already work. 

Use Accurate, Synchronized Captions 

Auto-generated captions are a starting point, but they are not sufficient on their own. Accuracy matters. Captions need to be properly timed with speaker identification and relevant non-speech audio like applause, background noise, or music cues. If your captions are full of errors, they don't serve the people who need them. 

Provide Transcripts for Audio-Only Content 

Captioning isn't the only requirement. Podcasts, audio announcements, and phone-based recordings need written transcripts.  

If your municipality produces any audio-only content, transcripts are the accessibility equivalent of captions. They should be published alongside the audio. 

Build Captioning into Your Workflow 

The most effective approach is to make captioning a standard step in your video production process. Not something you scramble to add after the fact.  

Budget for captioning services as part of every project. When it's built into the workflow, it stops feeling like an extra burden and becomes just how you do things. 

Audit Existing Content and Prioritize High-Traffic Videos 

You don't have to caption your entire video library overnight. Start with the content that gets the most views or serves the most critical functions. Council meeting recordings, emergency information, and service explainers are usually good starting points. From there, create a remediation plan that works through older content on a realistic timeline. 

Make Your Video Content Accessible with Legend 

We work with municipalities because we believe every resident deserves access to the information their local government provides. That's the reason we do this work. 

Our team understands ADA Title II requirements and walks alongside your organization through audits, remediation, and ongoing compliance.  

Ready to make your video content accessible and stay ahead of compliance requirements? Schedule a call with us today.