Writing a caption accessibility statement for live courses: CART procurement lead time, real-time accommodation requests, post-event transcript availability, and what to say when the feed fails

Why live courses need a different accessibility statement

The ILT and virtual classroom captioning playbook covers the full operational picture of live training caption delivery — CART provider selection, platform integration, pre-session setup, and post-event cleanup. This post focuses specifically on the communication layer: what the accessibility statement says, where it appears, and what operational infrastructure it presupposes.

For a recorded video library, the accessibility statement is retroactive: the caption file already exists, it was quality-reviewed before the content was published, and the statement simply tells the viewer it is there. The accessibility obligation was discharged at the point of caption production. For a live course, the accessibility obligation is prospective: the accessibility statement invites accommodation requests, promises a procurement process, commits to a real-time delivery, and anticipates a post-event follow-through. Every element of the statement describes something that has not yet happened but that the organisation is promising to make happen.

This distinction matters legally. Under ADA Title I (42 U.S.C. § 12112) and its implementing regulations at 29 CFR § 1630.9, an employer must provide reasonable accommodation in training programmes. Under Section 504 of the Rehabilitation Act and Section 508 (for federal agencies), the same obligation applies. An employer that publishes a live course in its LMS catalog without any accommodation information is arguably failing to give employees with disabilities the information they need to request an accommodation before the course is conducted. An employer that publishes accommodation information that is incomplete or inaccurate — wrong lead time, inaccessible request channel, no post-event option stated — may have created reliance and then failed to deliver. The EEOC’s enforcement guidance on reasonable accommodation (29 CFR Part 1630 App.) makes clear that the interactive process for accommodation begins when the employer learns of the need — and the need cannot be communicated before registration if the accessibility statement does not tell the employee what to communicate and to whom.

For universities and other public entities subject to ADA Title II after the April 2026 enforcement deadline, the obligation extends further: the ADA Title II captioning obligation requires that programmes and services, including live instructional offerings, be accessible to individuals with disabilities without requiring them to request a separate accommodation in every instance. Live course accessibility statements are part of the Title II programme accessibility infrastructure.

The accommodation request intake process

Before writing the accessibility statement, the organisation must design the accommodation request intake process that the statement will describe. There are four questions to answer first:

Who receives accommodation requests for live training?

The accessibility coordinator playbook covers the broader role of the accessibility coordinator in an L&D context. For live training specifically, someone must own accommodation requests: log them, communicate with the CART vendor, set up the integration, confirm the accommodation with the requestor before the event, and handle failure escalation during the session. In large organisations, this is the accessibility coordinator or the training operations team. In smaller organisations, it is the L&D manager or the individual course facilitator — and the accessibility statement must tell the employee which person or inbox to contact, so that requests do not go to a generic email address that nobody monitors before the event date.

What is the minimum advance request deadline?

This is the most operationally constrained element of the live course accessibility statement, and it must be set based on the actual lead time your CART vendor requires, not on what sounds reasonable or convenient.

Standard CART vendor lead times for scheduled live event captioning:

• Five to seven business days: Standard lead time for most professional CART providers. Within this window, the provider schedules a qualified captioner or steno court reporter, briefs the captioner on the subject matter and vocabulary, reviews any pre-read materials the organisation provides, and configures the integration with the organisation’s video platform. Requests that arrive within this window are typically accepted on a best-efforts basis, not guaranteed.
• Three business days: Rush availability at most providers, often at a 25–50% premium. Not all providers offer rush coverage; availability depends on captioner scheduling in the provider’s pool for the specific date and time. Cannot be relied on as a routine fallback.
• Same-day or next-day: Available from a small number of providers for high-volume clients or in markets with large steno-captioner pools (New York City, Chicago, Washington DC, Los Angeles). Not available in most markets or from most providers. Should not be stated as an available option unless the organisation has confirmed it with the specific vendor.
• On-demand (real-time, no advance notice): Available for ASR-based auto-captioning (built into Zoom, Teams, Webex, Google Meet), but not for professional CART services. Stating “CART available on request” without a lead time disclaimer implies on-demand availability that does not exist.

The minimum advance request deadline in the accessibility statement should be the organisation’s CART vendor’s standard lead time, plus two business days of organisational buffer for processing the request and confirming with the vendor. If the vendor requires five business days, the statement should specify seven business days as the request deadline. This buffer is not padding — it is the time required for the L&D team to receive the request, contact the vendor to confirm availability for that specific date and time, set up the integration (if remote), and confirm with the requestor that the accommodation is arranged.

What happens to late requests?

The accessibility statement should not promise that late requests will be fulfilled, because often they cannot be. But it should state what the organisation will do when a late request arrives: attempt to fulfil on a best-efforts basis with the vendor, offer the post-event accessible alternative, or, for mandatory compliance training, reschedule the session with the accommodation in place. The caption compliance programme design should specify the late-request escalation path in advance, so the decision is policy, not improvisation.

How will the accommodation be confirmed?

The requestor must receive a written confirmation that the accommodation has been arranged before the event. This confirmation should include: the name and contact of the CART provider or captioner assigned, the platform through which the CART output will be displayed, how to access the caption display during the session, and what to do if the caption display is not visible at session start. The confirmation is also the start of the written accommodation record that the organisation needs for any subsequent EEOC or OCR inquiry.

Template language for the LMS catalog listing

The LMS catalog listing is the first surface where the live course accessibility statement appears and the most important: it is the surface the employee reads before deciding whether to enrol and before deciding whether to request an accommodation. The statement must be complete enough to be actionable without being so long that it is buried in the course description.

The following template is designed for a general corporate or higher education LMS environment. Replace bracketed items with organisation-specific information.

Each element of this template corresponds to an operational commitment:

• “CART are available for participants who… require captions for any other reason” — the “any other reason” language matters. ADA accommodations are not limited to employees with formal disability designations. An employee who is a non-native English speaker may need captions. An employee in a noisy remote environment may need captions. The accommodation right extends beyond diagnosed disability, and the statement should not imply that captioning is available only for employees who have gone through a formal accommodation process with HR.
• “at least [X] business days” — fill this with the actual vendor lead time plus organisational buffer. The number must be accurate. Stating seven business days and then accepting requests at five creates confusion; stating seven and refusing a request at six creates legal exposure.
• “Requests received after this deadline will be fulfilled on a best-efforts basis” — this is honest and important. Do not promise fulfilment for late requests; do not refuse to try. “Best-efforts basis” is the accurate description of what the organisation can commit to when lead time is insufficient.
• “Auto-caption accuracy for [domain] vocabulary may be below the WCAG 2.1 AA standard” — this is the disclosure that separates compliant from non-compliant platform auto-caption usage. Platform auto-captions do not meet WCAG 2.1 AA for specialised content. Offering them as a “fallback” without this disclosure implies they meet the standard.
• “A [captioned recording / verbatim transcript]… within [X] business days” — the post-event commitment requires its own operational workflow. The X should reflect the actual time required: if the session is recorded and sent to a captioning vendor, standard turnaround is 24–48 hours for most vendors. If a verbatim transcript will be produced by the CART provider from the session text, it may be available the same day or within 24 hours. The statement should be accurate about the timeframe.

Template language for the registration confirmation email

The registration confirmation email is the second surface where the accessibility statement should appear. By the time the employee has enrolled in the course, the window for requesting CART may already be shortening. The confirmation email is an opportunity to remind newly enrolled participants of the accommodation request deadline and the contact to reach.

The key difference from the catalog listing language: the confirmation email should include a specific date (“by July 15”), not just a number of days (“7 business days before”). Employees who receive a confirmation email three days after enrolling in a course that starts in ten days need to calculate whether they are still within the request window. A specific date eliminates that calculation and the errors it can produce.

The registration confirmation email should be generated by the LMS system or by the training scheduling workflow, which means the specific deadline date needs to be dynamically inserted based on the session date minus the lead time. If the LMS cannot do this automatically, the template with the specific date should be manually prepared for each session and sent by the L&D team, not left to the generic LMS confirmation message.

Template language for the pre-session facilitator briefing

The facilitator — the instructor, trainer, or presenter who will run the live session — needs a pre-session briefing that covers the accessibility arrangements for that specific session. This briefing should be written, not verbal, so that the facilitator has a reference to consult if something goes wrong during the session. The briefing should include:

• Whether a CART accommodation has been arranged for a specific participant, and if so, which participant and how to confirm caption display at session start
• The CART provider’s name and direct contact (phone number, not just email) for escalation if the feed fails
• How the caption display will be visible to the participant (separate browser window URL, Zoom caption panel, dedicated display screen)
• Whether platform auto-captions will be active as a default or will be activated only if requested
• The feed-failure decision tree (see below) for this specific session
• Whether the session is being recorded and whether a post-event captioned recording will be produced
• The post-session transcript delivery timeline and who is responsible for it

The ILT captioning playbook covers the full pre-session checklist including platform integration setup, audio routing verification, and the pre-session CART test. The facilitator briefing is the simplified version of that checklist focused on what the facilitator needs to know and do, not the full technical setup.

CART procurement lead time in practice

The real-time CART captioning guide covers CART provider selection, quality benchmarks, and platform integration in detail. This section focuses specifically on what the lead time commitment means for the accessibility statement and for live training operations.

What happens during the lead time window

CART lead time is not administrative slack or bureaucratic delay. The following activities must happen within the lead time window for a professional CART deployment to succeed:

1. Captioner assignment: The CART provider assigns a qualified CART captioner (real-time steno court reporter or trained CART professional) to the event. If the event requires a captioner with specific subject-matter familiarity (technical, medical, legal), the assignment takes longer because captioner availability by specialty is constrained.
2. Pre-read material review: A professional CART captioner reviews provided materials — agenda, presentation slides, speaker names, topic vocabulary — before the session. This pre-read is what allows a captioner to be accurate on first occurrence of a technical term, proper noun, or acronym rather than having to adapt in real time. The pre-read requires the materials to exist and be shareable before the lead time window closes.
3. Glossary seeding: For complex technical, medical, or legal content, the CART provider enters high-frequency specialised vocabulary into the captioner’s steno dictionary before the event. This is particularly important for acronyms, product names, and regulatory identifiers that would not appear in a standard steno dictionary. Glossary seeding requires lead time to review the vocabulary list and load it correctly.
4. Platform integration setup: For remote or hybrid events, the CART output must be routed to a platform where participants can view it. This may be the platform’s built-in CART integration (Zoom’s manual caption API, Teams’ CART integration, Webex’s third-party caption provider integration), a separate browser-based caption display window, or a physical display setup for in-person events. The integration must be tested before the event begins, and testing requires the platform credentials and event details to be shared with the CART provider in advance.
5. Confirmation with the participant: The L&D team must confirm with the participant that the accommodation is arranged and provide the participant with the specific instructions for accessing the caption display on the day of the event. This confirmation must happen before the event date.

None of these activities can be compressed below the minimum lead time without degrading the quality or reliability of the accommodation. An organisation that tries to arrange CART on 48 hours’ notice will receive a less-prepared captioner, no pre-read review, no glossary seeding, and a platform integration that may not be tested before the session begins.

What to include in the CART vendor contract

The caption vendor SLA contract review checklist covers the full set of terms to review for captioning vendor agreements. For live CART services specifically, the following terms are critical:

• Minimum lead time guarantee: The vendor’s standard lead time commitment stated in the contract (typically five to seven business days), and what the vendor commits to do if an accommodation request arrives with less than the minimum lead time.
• Captioner qualifications: Whether the vendor uses steno court reporters, trained CART professionals, or ASR-assisted CART (where a human editor reviews AI-generated captions in near-real-time). Each has different accuracy profiles for specialised vocabulary.
• Subject-matter pre-read commitment: Whether the vendor guarantees pre-read review of provided materials before each event, and how far in advance materials must be submitted.
• Feed failure escalation protocol: The vendor’s committed response time when a feed failure is reported during a live event, and what remedies the vendor provides (replacement captioner, backup connection, post-event transcript delivery).
• Post-event transcript delivery: Whether the vendor delivers a verbatim transcript of the session after the event, within what timeframe, and in what format (Word, PDF, accessible HTML).
• Accuracy guarantee: The accuracy standard the vendor commits to for live CART output. WCAG 2.1 AA applies to pre-recorded captions; for live captions, the standard is 98% or higher for real-time human CART delivery, per the DCMP protocol. This is different from the 99%+ standard for edited post-event captions.

Real-time auto-caption fallbacks and their limitations

Platform auto-captions — Zoom, Teams, Webex, Google Meet — are available without advance notice, without vendor procurement, and without integration setup. This makes them attractive as a live caption solution and as a fallback when CART is not available. Their limitations as an accessibility accommodation for instructional training content require honest disclosure.

What platform auto-captions do well

• General conversational English at moderate speaking speed with clear audio in a quiet environment
• Common business vocabulary, standard meeting terminology, names from high-frequency business contexts
• Speaker transitions in small-group discussions where Zoom or Teams has clean audio isolation
• Live transcription as a real-time note-taking aid for participants who can follow speech but benefit from a simultaneous text reference

Where platform auto-captions consistently fail in instructional training content

The platform auto-caption accuracy analysis documents the failure patterns in detail. For live instructional training, the most significant failure categories are:

• Technical and regulatory acronyms: OSHA (survives, high-frequency), MSDS (survives), CAPA → “capper” or “KAPA”, SBAR → “S-bar” or “esbar”, FMEA → “FME-A” or “FMA”, qSOFA → “cue-sofa”, CLABSI → “CLASBI”, MRSA → “marsa”. In compliance training, these acronyms are the instructional content. Misrendering them is not a minor inaccuracy — it is a comprehension failure in the specific vocabulary the employee is being trained on.
• Product names and software interfaces: Proprietary software names, platform names, module names, and version identifiers that are unique to the organisation’s technology environment fail consistently because they do not appear in ASR training corpora. Epic module names (SmartPhrase, In Basket, LDA), Salesforce feature names (Opportunity, Account, Chatter), ServiceNow workflow names → rendered phonetically and often unrecognisably.
• Multi-accent audio environments: In a live training with five presenters who have different regional accents, foreign-language accents, or non-standard speech patterns, real-time ASR accuracy degrades significantly. Platform auto-captions are calibrated on a distribution of recorded speech that overrepresents standard American or British English. Regional US accents (Southern, Boston, New York), non-native English accents, and rapid speech in non-standard patterns all reduce accuracy.
• Specialised proper nouns: Case names, legislation titles, compound regulatory identifiers, foreign-origin surnames, clinical condition names. Twombly → “Tumbly”, McDonnell Douglas → “McDonald Douglas”, Clostridioides difficile → “C. difficult” or “see difficult.”
• Definitions and distinctions: When a trainer says “The key difference between an OOS result and an OOT result is…”, platform auto-captions that render OOS as “oose” and OOT as “oat” make the sentence incomprehensible, even though they have rendered 90% of the words correctly.

The practical implication for the accessibility statement: platform auto-captions may be offered as a convenience for participants who benefit from a text reference but do not need WCAG-compliant captioning. They should not be offered as the primary or sole captioning accommodation for participants who are deaf or hard of hearing and are relying on captions as their primary comprehension channel. The accessibility statement should distinguish between these two use cases explicitly.

ASR-assisted CART as a middle option

Some CART providers offer a hybrid model: AI-generated live captions that are reviewed and corrected in near-real-time by a human editor. This model offers better accuracy than raw platform auto-captions (the human editor catches the most obvious failures) while costing less than fully human steno CART. The accuracy on specialised vocabulary depends on whether the provider has glossary-seeded the AI model before the event. For organisations that run frequent live training with moderate specialised vocabulary, ASR-assisted CART with pre-event glossary seeding may be an appropriate middle-tier option. It still requires lead time — the glossary seeding and human editor scheduling must happen before the event — so it does not eliminate the lead time commitment in the accessibility statement.

What to say when the CART feed fails mid-session

CART feed failures in live training events are not common, but they are not rare enough to be treated as hypothetical. Remote CART deployments depend on multiple technology layers: the video platform’s audio routing, the CART provider’s integration, the captioner’s internet connection, the participant’s browser and display. Any of these can fail. The question is not whether to plan for failure but what the plan is.

Categorising the failure

The appropriate response depends on what has failed:

• Caption display not visible to participant (but feed may still be running): First step is to help the participant access the caption display through an alternative path. Provide the direct URL for the browser-based caption window, switch from the in-platform caption panel to an external display, or have the participant join from a different browser. This resolves the most common “failure” — a display-side configuration issue that does not require escalation to the CART provider.
• CART feed has stopped and the captioner is not producing output: Escalate to the CART provider using the direct phone contact from the facilitator briefing. Most CART providers can reconnect a dropped session within 5–10 minutes if the captioner’s connection is restored. Brief the participant that you are working to restore the feed.
• CART feed is producing output but with high error rates due to audio quality: Address the audio source first. Switch the presenter to a different microphone, reduce background noise, or adjust the audio routing in the platform. High error rates in live CART output are almost always an audio quality problem, not a captioner performance problem.
• CART provider is unreachable and the session cannot be restored: Decision point. Options are: (a) Pause the session, note where the disruption began, and reschedule the remainder with CART in place; (b) Continue the session with platform auto-captions as a temporary fallback, and provide a captioned recording or verbatim transcript within 24–48 hours after the event for any content the participant was unable to follow; (c) If the session is short (under 30 minutes) and the remaining content is low-vocabulary-difficulty, continue with the participant’s explicit agreement and provide the post-event transcript as a follow-up. Option (a) is the most protective from a legal standpoint for mandatory compliance training where accurate comprehension is the point. Options (b) and (c) may be appropriate for lower-stakes instructional content where the post-event alternative fully addresses the comprehension gap.

What to say to the participant when the feed fails

The facilitator should not leave a participant with a disabled caption feed to figure out what is happening and whether it will be resolved. The following is template language for the facilitator to use in the chat or verbally:

The important principle in these templates: the participant is the authority on whether the accommodation was adequate. The L&D team’s job is not to decide that the auto-caption fallback was good enough — it is to give the participant the options and the information to make that determination, and to provide a post-event alternative that is reliably accessible.

Documenting the failure

Any CART feed failure during a live training session must be documented in the accommodation request log, not just noted informally. The documentation should include: the session date and duration, the time the failure began and was resolved or the session was suspended, what fallback was offered, what the participant chose, and what post-event alternative was provided and when. This documentation is the evidence that the organisation responded appropriately to the disruption. Without it, a subsequent EEOC charge or OCR complaint that involves the same participant and the same session has no contemporaneous record of the organisation’s response.

Post-event accessible alternatives

The post-event transcript and captioned recording are the accessibility backstop for live training. They serve four populations:

1. Participants who attended with CART and want a verbatim reference to review after the session
2. Participants who attended but experienced a CART or auto-caption disruption and need access to the content they missed
3. Participants who were registered but could not attend the specific session date and need to complete the training in an accessible format
4. Participants who attended a future makeup session after a missed or incomplete live session and need the original session content for reference

The accessibility statement should specify which post-event options the organisation provides and the timeline for each. Not specifying leaves these populations without a clear path to exercise their accommodation right.

Captioned recording

A captioned recording of the live session (typically produced by exporting the session recording from Zoom or Teams and sending it to a captioning vendor for SRT production) provides a complete accessible alternative for the session content. Standard captioning vendor turnaround for post-event captioning is 24–48 hours from submission. The captioned recording should be produced for every live session that had CART in place — not only when a participant requests it after the fact, because the participant who was not present may not know the recording exists or that it can be captioned.

The captioned recording produced for a live session replaces the real-time CART transcript as the long-form reference for participants who want to review. It should be hosted in the LMS or in the organisation’s accessible video library, linked from the course record, and noted as available to all enrolled participants regardless of whether they attended the live session. This is consistent with the programme accessibility obligation that applies under ADA Title II and Section 504 — the post-event captioned recording is part of the accessible programme, not an individual accommodation.

Verbatim transcript

CART providers typically offer to deliver a verbatim transcript of the session — the raw text output from the CART session, edited for minor errors — within a few hours of the session end or by the next business day. This transcript is different from a post-event caption file (which is synchronised to a recording) but serves the same function as a text reference. For organisations that do not always record live sessions, the verbatim transcript is the only post-event accessible alternative. The caption programme governance policy should specify whether live sessions are routinely recorded and captioned post-event, whether verbatim transcripts are the standard alternative, or both.

Delivery timeframe commitments

The accessibility statement should state a specific post-event delivery timeframe, not an open-ended commitment. Reasonable timeframes:

• Verbatim transcript from CART provider: same business day to next business day
• Captioned recording from captioning vendor (standard turnaround): 24–48 business hours from recording submission
• Captioned recording from captioning vendor (rush turnaround): 4–8 business hours for sessions up to 90 minutes

If the organisation cannot commit to these timeframes because the internal workflow for recording submission or transcript collection has not been established, the accessibility statement should not promise them. The statement should reflect what the organisation can actually deliver, not what sounds like a reasonable commitment.

Section 508 considerations for federal employees and agencies

For federal agencies and federal contractors covered by Section 508 (29 U.S.C. § 794d) and the Revised 508 Standards (36 CFR Part 1194), the live course accessibility obligations are more prescriptive than the general ADA/Section 504 framework. The Revised 508 Standards at 36 CFR § 1194.22 apply to real-time communications and synchronous webinars and require that they include caption delivery mechanisms that are equivalent to the communication experience of non-disabled participants.

The Revised 508 Standards incorporate WCAG 2.0 Level AA as the technical standard. For live audio content in synchronised webinars, WCAG 2.0 Success Criterion 1.2.4 (Captions Live) requires that live captions be provided. The 2.0 and 2.1 standards do not specify a numerical accuracy threshold for live captions (unlike the 99% standard that applies to pre-recorded content under SC 1.2.2), but the DCMP Captioning Key is the accepted professional benchmark, and a target of 98% is widely used for professional CART delivery. Platform auto-captions that fall below 95% accuracy on specialised vocabulary do not satisfy this standard for participants who rely on captions as their primary channel.

The caption compliance matrix covers the full interaction between Section 508, ADA, and WCAG requirements. For Section 508-covered organisations, the live course accessibility statement should reference Section 508 compliance explicitly and should be reviewed against the agency’s Section 508 programme office requirements before publication in the LMS catalog.

Higher education and ADA Title II after April 2026

Public universities, community colleges, and state-operated educational institutions are covered by ADA Title II (42 U.S.C. § 12132) and by Section 504. The April 2026 enforcement deadline for web content and digital accessibility under ADA Title II brought increased scrutiny on all digital programme content — including live instructional offerings delivered through LMS platforms.

For higher education L&D teams running internal staff training, the Title II obligation applies in the same way it applies to public sector employers generally. For higher education instructional teams running academic courses or continuing education offerings, the Title II obligation extends to all programme participants, including students. The live course accessibility statement for a university continuing education programme is not just an employee accommodation process — it is a programme accessibility disclosure that affects enrolment decisions for programme participants with disabilities.

The ADA Title II caption requirements for public entities specify that the standard is programme accessibility, not just individual accommodation. A university continuing education programme that offers an accessibility statement but requires participants to request CART for every single session, with no provision for series-level accommodation, may not meet the programme accessibility standard if it is placing an undue burden on participants to request accommodation repeatedly for content that should be proactively accessible.

Where the accessibility statement should appear

A single location is not enough. The live course accessibility statement should appear in at minimum four places, with appropriate length and detail at each:

1. LMS catalog listing (full statement): The most important surface. Accommodation request deadline, contact information, auto-caption disclosure, post-event alternatives. Length: three to five short paragraphs or equivalent structured content. This is where the employee reads it before deciding whether to enrol and whether to request an accommodation.
2. Registration confirmation email (summary statement with specific deadline date): Includes the specific accommodation request deadline date (calculated from the session date), contact information, and what to do if the employee is within the lead-time window already.
3. Pre-session reminder email (one or two days before the session): Brief reminder of the caption arrangement (if one has been made), how to access the caption display, and the contact for last-minute issues. This is also the opportunity to confirm with any participant who requested CART that the arrangement is in place.
4. Session materials or course introduction slide: A brief slide in the facilitator’s opening deck that tells all participants how to enable auto-captions, where the CART display is visible (if CART has been arranged), and who to contact if they have a caption issue during the session. This ensures that participants who have not seen the catalog statement or who have forgotten the details have the information in front of them when the session begins.

The EU accessibility statement template for digital products covers the separate but related requirement for published web content accessibility statements under the European Accessibility Act (EAA) and Web Accessibility Directive. For organisations operating in both the US and EU, the live course accessibility statement addresses the US ADA/Section 504/Section 508 requirements; the published accessibility statement addresses the EAA/WAD requirements for the digital product (LMS platform). These are different documents with different audiences and different requirements.

Eight failure modes in live course caption accessibility

The following failure modes are the most common sources of ADA findings, OCR complaint findings, and accommodation breakdowns in live training programmes:

1. Accessibility statement states a deadline that is shorter than the actual CART vendor lead time. An organisation that has a contract with a CART provider requiring seven business days’ notice, but whose accessibility statement says “five business days”, creates a gap where the organisation has accepted an accommodation request it cannot fulfil. The vendor will decline coverage for the session date; the organisation has promised it. The resolution is either to accept the request and attempt to find a provider on shorter notice (at premium cost, with degraded preparation), or to tell the participant the accommodation cannot be arranged — which, for mandatory compliance training, may constitute a failure of the reasonable accommodation process.
2. No named contact for accommodation requests. An accessibility statement that says “contact L&D for accommodations” or “email training@company.com to request captions” without a named individual or a monitored inbox is not operationally functional. Accommodation requests that go to unmonitored inboxes, generic aliases, or the wrong person are not received in time. A named individual — or a monitored alias with a stated response-time commitment — is the minimum for an operationally credible accessibility statement.
3. Auto-captions offered without accuracy disclosure. An LMS catalog listing that says “live captions available via Zoom” without specifying that these are platform auto-captions with variable accuracy on specialised vocabulary implies WCAG 2.1 AA compliance that does not exist. A participant with a hearing disability who relies on this statement and attends a session with Zoom auto-captions that render 20% of the specialised training vocabulary incorrectly has received an accommodation that does not meet the standard. The disclosure is both legally important and operationally important: it tells the participant that if they need WCAG-compliant captioning, they should request CART.
4. No feed-failure protocol established before the session. When a CART feed fails during a session and the facilitator has no protocol, the most common response is to either continue the session without captions (leaving the participant with a disability without their accommodation) or to immediately suspend and reschedule without consulting the participant (appropriate for some situations but not all). A pre-session feed-failure protocol gives the facilitator a decision tree to follow, a direct contact for the CART provider, and template language for communicating with the participant. Its absence is a training and programme design gap, not just a technology problem.
5. Post-event transcripts not produced or not delivered within the committed timeframe. The post-event accessible alternative is often the first commitment to fail when programme staff are under time pressure after a session. The CART provider may produce a verbatim transcript automatically, but nobody on the L&D team follows up to collect and deliver it. The session recording may exist but is never sent for captioning. The participant who was absent or who experienced a caption disruption receives no follow-up. This failure is invisible unless the participant asks and is told the post-event alternative is not available — at which point it has become a documentation of a failed accommodation commitment.
6. Accommodation request log not maintained for live training sessions. Many organisations that maintain accommodation request logs for recorded video content (because the video catalogue requires a formal review process) do not maintain equivalent logs for live training sessions because the sessions feel transient. An EEOC charge or OCR complaint that involves a live training session requires contemporaneous records of: the accommodation request, the response, the CART arrangement, the session outcome, and any post-event alternatives provided. Without the log, the organisation is relying on email chains and facilitator memories to reconstruct the accommodation process. The caption compliance programme design should include live training accommodation requests in the same logging system as recorded video accommodation requests.
7. Mandatory compliance training rescheduled for caption failure without completing the accommodation cycle. When a live mandatory compliance training session is suspended due to a CART feed failure, the session must be rescheduled — but the rescheduling is not the end of the accommodation cycle. The participant must receive a specific offer for the rescheduled session with a confirmed CART arrangement, the participant must be given priority scheduling for the makeup session, and the organisation must ensure the participant completes the training within the same compliance window as non-disabled employees. An organisation that suspends a HIPAA training session due to a caption failure but then places the participant at the back of the queue for the next session may have created a compliance gap that affects both the ADA accommodation right and the HIPAA training mandate.
8. Accessibility statement not updated when CART vendor or procurement process changes. An organisation that changes CART vendors, changes the video platform (and therefore the integration method), or changes the accommodation request contact must update the accessibility statement in every LMS catalog listing where it appears. Stale accessibility statements — with incorrect lead times, defunct email addresses, or references to platforms that are no longer used — are worse than no statement because they actively mislead employees about the accommodation process. The caption programme annual review should include a systematic check of all live course accessibility statements for accuracy and currency.

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