Captioning extended enterprise training: channel partners, franchise networks, dealer academies, and the ADA obligation that follows when you assign training to people you don't employ

What "extended enterprise" training means and who it covers

"Extended enterprise" is the L&D industry term for training delivered to audiences outside the direct employment relationship — people who have a commercial or contractual relationship with the brand but are not on the brand's payroll. The term encompasses five distinct relationship categories, each with its own legal and operational characteristics:

Channel partners are independent businesses that sell, resell, or distribute the brand's products or services. Technology vendors train channel partners on product features, implementation methodologies, competitive positioning, and sales certification. A SaaS company's VAR (value-added reseller) network completing product certification training, a hardware manufacturer's distributor network completing installation training, and a financial services firm's broker-dealer network completing product suitability training are all channel partner training audiences. The channel partner's employees are completing the training; the brand is assigning the content.

Franchisees operate businesses under the brand's mark and business system, typically under a franchise agreement that specifies operational standards, brand compliance requirements, and mandatory training. The franchisee is an independent business owner; their employees are the franchisee's employees, not the franchisor's. But the franchisor typically controls the content and completion requirements of the training that franchisee employees must complete — creating the joint employer question that distinguishes franchise training from other extended enterprise categories.

Dealer networks are common in automotive, heavy equipment, agricultural equipment, and consumer electronics — industries where manufacturers sell through a network of independent retail dealers rather than through direct sales channels. Dealer training includes product knowledge, service procedure certification, warranty claim processing, and brand standards compliance. Automotive OEM dealer certification programmes (Ford Motor Company's FoRD Learning, Toyota's Toyota University, Stellantis's MOPAR training) are among the largest extended enterprise training deployments in the country, serving tens of thousands of dealer employees across dealer networks of hundreds or thousands of franchised retailers.

Contractor pools are third-party workers who perform services under the brand's direction but are employed (or self-employed) through staffing agencies, professional employer organisations (PEOs), or as independent contractors. Field service technicians deployed through a staffing agency to service branded equipment, retail merchandisers contracted through a field marketing agency to maintain in-store brand presence, and IT contractors engaged through a staffing agency to implement branded software are all contractor pool training audiences. The joint employer analysis for contractors is more developed and more legally charged than for other extended enterprise categories.

Reseller and certification programmes are training programmes that individuals or businesses complete to earn a certification, badge, or designation that authorises them to sell, implement, or support the brand's products. Technology certification programmes (Salesforce certifications, AWS certifications, Cisco CCNA/CCNP, Microsoft certifications) are the largest-scale examples, but the same structure applies to financial adviser product certifications, insurance agent carrier certifications, and professional service firm methodology certifications. Some of these programmes are openly accessible to any registrant — making them public accommodations under Title III. Others are restricted to existing business relationships. The accessibility obligation follows the access model.

The unifying characteristic across all five categories is that the brand controls or significantly influences the content, assigns the training, and derives business benefit from the completion — but does not control the employment relationship of the people completing it. This is the precise gap that the "not our employees" reasoning exploits, and it is the gap that the legal analysis below closes.

The ADA legal framework: why Title I doesn't apply and what does

ADA Title I prohibits discrimination against "qualified individuals with a disability" in the terms, conditions, and privileges of employment, including the failure to provide reasonable accommodations. The obligation runs from employer to employee — and the employment relationship is the statutory predicate. When a reseller's employee completes the brand's partner certification training, that employee's employer is the reseller, not the brand. The brand has no ADA Title I obligation to caption that content for the reseller's employee, because the brand is not the employer.

This does not mean the reseller's employee has no ADA claim. If the reseller's employee has a documented hearing impairment and requests a captioned version of the brand's certification training from the reseller, the reseller — as the employer — must evaluate whether providing captioned training content is a reasonable accommodation. But the reseller cannot caption content it does not control. The reseller's accommodation obligation runs upstream: the reseller must request captioned content from the brand, and if the brand refuses to provide it, the reseller must find an alternative accommodation (a sign language interpreter for a live training session, a human-captioned version of the recorded training, a text transcript). The brand's refusal to provide captioned content constrains the reseller's ability to accommodate its employees — creating a gap that the contractual framework must close.

ADA Title III operates on a different axis. Title III prohibits discrimination on the basis of disability by "any person who owns, leases (or leases to), or operates a place of public accommodation." The ADA defines twelve categories of public accommodations, including "sales or rental establishments," "service establishments," and "places of education." Courts and the DOJ have applied Title III to websites and digital platforms where those platforms are the entity's primary public-facing interface — a training portal that any member of the public can register to access is a public accommodation in the same way that a physical training facility is a public accommodation.

The DOJ's March 2022 guidance on web accessibility (ADA.gov/resources/web-guidance/) confirmed that web accessibility is required under Title III and that websites that are inaccessible to people with disabilities violate the ADA where the website is the entity's means of providing goods or services to the public. For openly accessible certification programmes (any individual can register, complete training, and earn a certification), this guidance applies directly — the training portal is the place of public accommodation, the video training content is the good or service being provided, and accessibility of that content (including captions) is required.

For authenticated partner portals restricted to existing channel partners, the Title III analysis is less settled. Courts have varied on whether a portal that requires a pre-existing business relationship — and that is not accessible to the general public — qualifies as a place of public accommodation. Some circuits have applied a "nexus to a physical place" requirement that limits Title III to digital services connected to a physical location; others have applied Title III to purely digital services without requiring a physical nexus. The Ninth Circuit (California) and First Circuit (Massachusetts, Maine, New Hampshire, Rhode Island, Puerto Rico) have applied Title III more broadly; the Sixth Circuit (Michigan, Ohio, Kentucky, Tennessee) has applied a physical-nexus requirement that provides more protection to purely digital services. L&D teams operating in California are in the broadest Title III jurisdiction in the country; teams operating in the Sixth Circuit have a stronger argument that a purely digital partner portal is not a public accommodation.

The uncertainty in the Title III analysis for authenticated portals is precisely why the contractual enforcement theory matters. The contract resolves the compliance obligation regardless of how courts ultimately resolve the Title III question for restricted portals.

ADA Title III, contractual enforcement, and the franchise joint-employer theory

The contractual enforcement theory for extended enterprise caption compliance works as follows: when the brand requires training completion as a condition of the channel partner agreement, franchise agreement, dealer agreement, or reseller certification programme, the brand is the party who controls whether accessible training content is available to the non-employee learners. If those learners include individuals with hearing impairments who cannot access uncaptioned training, the brand's refusal or failure to provide captioned content creates a gap that — regardless of the Title III analysis — the brand is operationally positioned to close. The contractual theory turns that operational control into a legal obligation.

The mechanism works in both directions. From the brand's perspective, the channel partner agreement can specify that the brand will provide captioned training content meeting WCAG 2.1 AA, and that the partner must deliver that content through an LMS or platform that supports caption display. This makes caption quality a brand commitment and caption delivery a partner responsibility. From the partner's perspective, the agreement gives the partner an enforceable right to receive accessible content — which the partner can use to argue that the brand has failed its contractual obligations if uncaptioned content is assigned. Either way, the contractual framework creates enforcement pathways that the statutory framework (Title III) may not clearly provide for restricted portals.

The franchise joint employer theory adds a layer of legal exposure in states with broad joint employer doctrine. The joint employer doctrine applies when two separate entities both exercise meaningful control over the terms and conditions of a worker's employment. In franchise relationships, courts have applied joint employer analysis where the franchisor: (1) controls the content of mandatory training that franchisee employees must complete; (2) sets the schedule and completion requirements for that training; (3) ties franchise compliance or renewal to franchisee employee training completion; and (4) directly instructs franchisee employees through the training content. If all four factors are present, some courts — particularly in California under the PAGA framework and in New York under the broader New York Labor Law joint employer definition — have found that the franchisor shares employer status with the franchisee for purposes of the obligations controlled by the franchisor's training mandate.

The practical consequence of a joint employer finding in a captioning context: the franchisee employee's ADA Title I accommodation request — for captioned training video — runs against both the franchisee (as the direct employer) and the franchisor (as the joint employer who controls the training content). The franchisor cannot defeat a caption accommodation request by pointing to the franchisee as the responsible party if the franchisor is the party who determines what training content the franchisee employee must complete.

California's Private Attorneys General Act (PAGA) amplifies this exposure. PAGA allows employees to bring representative actions for California Labor Code violations on behalf of all similarly situated employees — effectively a private attorney general mechanism for employment law enforcement. If a franchisor is found to be a joint employer of franchisee employees in California, a PAGA action brought by a single franchisee employee could cover every franchisee employee in California who was assigned uncaptioned training content. The statutory damages structure in PAGA — not linked to actual harm — makes this a material exposure for franchise networks with California locations.

The conservative compliance position for any brand operating a franchise network with California locations: treat all franchise training content as subject to FEHA accommodation obligations (5-employee threshold in California, which most franchise locations meet), provide WCAG 2.1 AA-captioned content for all mandatory franchise training modules, and include caption quality specifications in the franchise disclosure document's training description (Item 11 of the FDD under FTC Franchise Rule requirements covers training — accessibility of training content is a material term that should be disclosed).

Five categories of extended enterprise content and their compliance implications

Channel partner product training

Channel partner product training covers product features, competitive positioning, pricing and quoting, implementation methodology, and sales certification. The content is typically produced by the brand's product marketing or revenue enablement team and assigned through a partner portal. The vocabulary problem is the most acute for product training: SKU codes, configuration parameters, pricing tier names, and integration terminology appear in certification assessments that the partner must pass to earn sales authorization. A caption error on a SKU code or product tier name in a certification video is not a minor inaccuracy — it is a curriculum flaw that causes the partner to carry wrong information into sales calls.

The compliance implication: channel partner product training is the highest-volume category and the highest-vocabulary-risk category simultaneously. Every product training video assigned to channel partners should be captioned with a channel-partner-specific glossary that includes all SKU codes, tier names, pricing structures, and integration terminology. The sales enablement captioning guide covers the SKU-name vocabulary architecture in detail; the same glossary logic applies to channel partner product training, with the additional requirement that the partner-facing glossary may need to include competitor product names that internal content might reference but that the brand would not include in an internal glossary.

Franchise training

Franchise training covers brand standards, operational procedures, food safety (for restaurant franchises), service quality protocols, compliance requirements, and employee management standards. The brand controls the content and typically assigns specific modules with completion deadlines tied to franchise operational milestones (pre-opening training, first-year compliance, renewal qualification). The vocabulary is operational: brand-specific procedure names, proprietary product names, food preparation terminology (for restaurants), service protocol labels, and compliance checklist items. Franchise training often covers legally sensitive topics — food safety, workplace safety, harassment prevention — where caption accuracy is a compliance obligation in its own right (OSHA training requirements, for example, are not satisfied by video training with inaccurate captions).

The compliance implication: franchise training carries joint employer risk (in California, New York, Illinois), statutory compliance overlap (OSHA training requirements, food safety certification), and FDD disclosure obligations. Every mandatory franchise training module should be captioned at WCAG 2.1 AA, and the FDD Item 11 training description should specify caption quality as part of the training programme description.

Dealer certification programmes

Dealer certification covers product knowledge, service procedures, warranty processing, and technical training for the equipment or vehicles the dealer sells and services. Automotive OEM dealer training programmes are the largest scale example — Ford Motor Company's FoRD Learning platform, Toyota's dealership training portal, Stellantis's dealer training system, and BMW's dealer academy all serve tens of thousands of dealer employees across national dealer networks. Service procedure training is particularly vocabulary-intensive: torque specifications, part numbers, diagnostic codes, and service bulletin identifiers must be rendered with exact precision, because a technician who misreads a torque specification from a poorly captioned training video may cause a safety-critical error.

The compliance implication: dealer certification programmes that are openly accessible — any authorised dealer employee can register — may qualify as places of public accommodation under Title III for the purposes of the training portal access model. Even where Title III is uncertain, the OEM's service training content is typically required for warranty claim authorisation, creating a direct commercial consequence for incorrect information. Dealer training video content should be captioned with service-procedure-specific vocabulary (part numbers, diagnostic codes, torque specifications, proprietary system names) and the OEM should maintain caption quality as a component of dealer certification standards.

Contractor pool training

Contractor pool training covers onboarding, safety, operational procedures, and brand standards for workers who are not direct employees but who perform services under the brand's operational control. Field service technicians deployed through a staffing agency, retail merchandisers contracted through a field marketing firm, and IT contractors engaged through a professional employer organisation all represent contractor pool training audiences. The joint employer analysis for contractor pools is the most developed in employment law — the NLRB joint employer rule (periodically revised), the DOL's economic reality test for independent contractor classification, and the ABC test (used in California under AB 5) all determine whether the brand is a joint employer of the contractor pool workers.

The compliance implication: contractor pool training carries the highest joint employer risk of any extended enterprise category. Where a brand exercises meaningful control over the terms and conditions of a contractor's work — including by requiring specific training completion, setting training schedules, and directing how the contractor performs the trained activities — courts applying joint employer doctrine in California (AB 5), Massachusetts (ABC test), and other states with broad independent contractor classification tests may find the brand to be a joint employer with accommodation obligations. Caption all contractor pool training content at WCAG 2.1 AA, and include caption quality specifications in the staffing agency master service agreement.

Reseller and technology certification programmes

Technology certification programmes — Salesforce Administrator, AWS Solutions Architect, Google Cloud Professional, Cisco CCNA — are among the most widely taken professional certifications in the technology industry, and they are almost universally delivered as digital training content through certification portals that are accessible to any registrant. These programmes are public accommodations under Title III by the clearest definition: any individual can register, pay the certification fee, access the training content, and take the certification exam. The training portal is the place of public accommodation; the video training content is the good being provided; accessibility of that content is required under Title III with no contested-authentication-portal analysis required.

The compliance implication: any brand operating a publicly accessible certification programme — technology certifications, financial product certifications, professional methodology certifications — has a clear Title III obligation to provide WCAG 2.1 AA-compliant captions on all training video content in the programme. The fact that the programme is a revenue-generating business (certification fees, exam fees) does not reduce the obligation; it is not a charity or a government programme — it is a place of public accommodation subject to Title III's full requirements.

Platform-by-platform caption workflows

Cornerstone Extended Enterprise

Cornerstone OnDemand's Extended Enterprise module provides a separate LMS tenant — with its own branding, URL, and user base — for external partners, customers, or certification programme participants. The external tenant operates independently of the internal employee LMS, with its own catalogue, user management, and reporting configuration. Caption management in Cornerstone Extended Enterprise follows the same LMS-level mechanics as the core platform: captions are managed at the learning object (course) level, and video content can be delivered via direct upload to Cornerstone's video hosting, via external video platform integration (Vimeo, Wistia, YouTube), or packaged within SCORM or xAPI content objects.

For direct video uploads to Cornerstone Extended Enterprise, upload the SRT or VTT caption file as a sidecar to the video asset in the content management interface. Cornerstone's video player supports SRT and VTT caption display and renders captions through the player's native caption toggle. Verify that the caption track label is set correctly (English, or the appropriate language) and that the caption track is set to "visible by default" for accessibility compliance — a caption track that requires the learner to manually enable it satisfies a different standard from one that displays automatically.

For SCORM-packaged content in Cornerstone Extended Enterprise, the caption delivery model depends on the authoring tool used to build the SCORM package. Articulate Storyline SCORM packages support SRT import if the narration is a standalone video slide rather than a synchronized timeline; Rise 360 SCORM packages deliver video via the video host (captions managed at the host level, not in Rise) rather than through internal captioning. Adobe Captivate SCORM packages support closed caption text tracks that follow the narration timeline. The Articulate and Captivate caption workflow guide covers SCORM caption mechanics in detail — the same analysis applies when that SCORM content is deployed to a Cornerstone Extended Enterprise tenant rather than the core LMS.

Cornerstone's reporting capabilities in Extended Enterprise cover completion rates, assessment scores, and learning path progress by external organisation. Caption compliance cannot be directly measured through Cornerstone's standard reporting — you cannot extract a report of "which content items have a caption track attached." Caption quality audits for Cornerstone Extended Enterprise require manual spot-checking of the content library: pull the list of all course items in the external tenant, check each video asset for caption track presence and format, and sample-check caption accuracy against the DCMP protocol. The Cornerstone caption workflow guide covers LMS-level caption management for the core platform; the Extended Enterprise tenant follows the same mechanics with a separate content library scope.

Docebo

Docebo's Extended Enterprise feature provides multi-tenant LMS architecture — separate portals for different partner organisations, each with its own branding, user base, catalogue, and reporting. Each portal (called a "branch" in Docebo's terminology for the extended enterprise configuration) can have its own subdomain, making it easy to deliver branded training portals to specific channel partners or distributor groups. Caption management in Docebo follows the video delivery model selected at the course level: video content uploaded directly to Docebo is captioned via Docebo's caption upload interface (SRT or VTT, attached at the video level); video content delivered via integrated video platforms (Vimeo, Wistia, YouTube, Kaltura) is captioned at the video platform level.

For direct uploads in Docebo, navigate to the content asset in the central content library, select the video asset, and upload the caption file via the closed captions tab in the video editing interface. Captions uploaded at the central library level are shared across all branches where the content is used — a single caption upload to the central library covers all extended enterprise portals where the content is deployed. This is the operationally efficient approach: caption once in the central library, and the caption propagates to all branch deployments. The failure mode is the reverse: if a content item is added to a branch portal without a caption track attached in the central library, every branch using that content inherits the non-compliant state.

Docebo's reporting API enables custom reports on content metadata, including caption track status on video assets. An L&D team with API access to Docebo can extract a list of all video assets in the central content library and their caption track status — providing a scalable audit mechanism for extended enterprise content compliance. The Docebo caption workflow guide covers the core LMS configuration; the Extended Enterprise branch architecture applies the same caption management at a multi-tenant scale.

TalentLMS

TalentLMS uses a Branches feature for extended enterprise deployments — each branch is a sub-portal with its own branding, catalogue, and user management, accessible at a subdomain of the primary TalentLMS instance or at a custom domain. Branch administrators can manage their own user base and catalogue within the content available to them from the parent account. Caption management in TalentLMS follows the same video delivery model as the core platform: video content added as a TalentLMS video asset (direct upload) is captioned by uploading an SRT file in the course unit settings; video content embedded from YouTube, Vimeo, or Wistia uses the caption track set at the external platform level.

For extended enterprise deployments in TalentLMS, the key operational decision is whether the parent account manages the content library and pushes courses to branches, or whether each branch administrator independently adds content. If the parent account manages the content library and assigns courses to branches, caption management is centralized — the parent account uploads captions once and all branches receive the captioned content. If branch administrators independently add content (a common configuration for large reseller networks where each distributor manages their own training catalogue), caption management is decentralized, and each branch administrator's uploaded content must be independently audited for caption compliance. The governance policy for extended enterprise captioning should specify which model applies and who is responsible for caption quality in each case.

TalentLMS's Branches feature does not provide branch-level caption compliance reporting through the standard interface. Compliance audits require exporting the course inventory for each branch and manually verifying caption presence on each video asset. For large extended enterprise deployments with many branches and large course libraries, this manual audit burden is the strongest argument for centralizing content management in the parent account rather than distributing it to branch administrators.

Kaltura

Kaltura is widely used as the video backbone for extended enterprise training delivery — providing media management, streaming, and player capabilities that are integrated with LMS platforms (Cornerstone, Docebo, Moodle, Canvas, Blackboard) or deployed directly as a standalone video portal. Kaltura's MediaSpace portal can serve as a standalone extended enterprise training portal with user management and access control. Caption management in Kaltura is handled at the media entry level — each video asset in Kaltura's media library can have one or more caption tracks attached, and those captions are available to any downstream player that embeds the media entry.

For Kaltura-based extended enterprise deployments, upload the SRT or VTT caption file as a caption track on the media entry in the Kaltura Management Console (KMC) or through the Kaltura API. Set the default caption language and configure the caption track as the default visible track in the player settings. Kaltura's player supports multiple simultaneous caption tracks (for multilingual content), automatic caption generation via Kaltura's REACH service (which should be verified at 99%+ accuracy before use — REACH's accuracy on technical vocabulary is subject to the same ASR failure modes documented for Whisper and other AI captioning services), and caption download for offline review.

Kaltura's caption quality workflow for extended enterprise content should follow the same batch verification process as internal LMS content: generate captions using a glossary-biased ASR service, review the output against the DCMP spot-check protocol, correct errors in the SRT file, and upload the corrected SRT as the caption track on the Kaltura media entry. For Kaltura caption workflows, the LMS integration method — whether Kaltura Application Framework (KAF), LTI integration, or direct embed — does not affect caption quality but does affect whether the caption track rendered in the LMS player matches the caption track set in KMC. Verify caption display in the downstream player (the LMS or portal where the Kaltura content is embedded) after every caption update, not just in the KMC preview.

Litmos (SAP)

SAP Litmos is widely deployed in compliance-heavy verticals — financial services, healthcare, manufacturing — and is common in franchise and dealer network deployments where compliance training is the primary extended enterprise use case. Litmos supports external users through Teams functionality and through dedicated external portals. Caption management in Litmos follows the course-level caption model: video content uploaded directly to Litmos supports SRT caption upload through the course content settings; video content linked from external sources (YouTube, Vimeo) uses the caption track set at the external platform.

For Litmos extended enterprise deployments, the compliance reporting capability is a differentiator: Litmos generates completion reports and assessment reports at the Team level, making it possible to report compliance completion by partner organisation. Caption compliance — as distinct from training completion compliance — requires the same manual audit of caption track presence and quality as other platforms. For franchise and dealer deployments where regulatory compliance is the primary training driver (OSHA training, food safety certification, financial product suitability), caption accuracy is a compliance requirement of the training itself, not just a delivery accessibility requirement — a food safety certification course with an inaccurate caption on a critical temperature requirement does not satisfy the certification requirement for a hearing-impaired employee who relied on the caption.

LearnUpon

LearnUpon supports extended enterprise through its Partner Portal feature, which provides a separate branded portal for external business partners with its own catalogue, user management, and reporting. Caption management in LearnUpon follows the course-level model: video content uploaded to LearnUpon can have SRT caption files uploaded through the course unit caption settings; video content embedded from external platforms uses the caption track set at the embedding platform. LearnUpon's caption upload interface supports SRT and VTT formats and attaches the caption to the specific video unit in the course.

For LearnUpon Partner Portal deployments, the key caption management decision is whether to use LearnUpon's native video hosting (which supports SRT/VTT upload) or to embed from an external video platform. Using LearnUpon's native hosting with SRT upload is the recommended approach for caption quality control — the brand controls the caption file, can update it, and can verify caption display in the LearnUpon player. Embedding from YouTube introduces the risk that YouTube's automatic caption generation may replace a manually uploaded caption track, or that the YouTube player's caption toggle may not render correctly within LearnUpon's iframe embed. The LMS migration caption checklist covers caption portability across LMS transitions — the same considerations apply when migrating extended enterprise content from one partner portal platform to another.

The vocabulary accuracy problem: captions for learners who don't yet know the jargon

The vocabulary accuracy problem in extended enterprise captioning is structurally different from the vocabulary problem in internal employee training. When an internal employee encounters a product name or technical term in a caption, they typically have institutional context — they have heard the term in meetings, seen it in internal documentation, and have colleagues they can ask. A slightly misrendered caption on a term they already know is an inconvenience, not a training failure.

When a new channel partner employee encounters the same product name or technical term in a certification training video, they are encountering it for the first time in a training context where they are being evaluated on whether they know it. A caption that renders "QuantumEdge Pro Plus" as "Quantum Edge Pro Plus" teaches the partner to use the wrong product name. A caption that renders "RESTful API endpoint /v2/catalog/sync" as "restful A P I end point slash V 2 slash catalog slash sync" renders the endpoint useless. A caption that renders a competitor's name — referenced in a competitive positioning module — as a phonetically similar but incorrect term trains the partner to misidentify the competitor in sales conversations.

The first-exposure problem compounds the accuracy risk. Internal employees build glossary exposure over months of work before they encounter a formal training module on a topic. Channel partners encounter the brand's vocabulary for the first time in the certification training. If the first formal exposure to a term is a captioned training video that misrenders the term, the partner's initial mental model is built on the wrong spelling and pronunciation. Subsequent correction is harder than initial correct exposure, because the partner must unlearn the first association before forming the correct one.

The technical solution is a partner-specific glossary applied at the ASR decoding stage. This glossary must be distinct from the internal employee glossary in several ways:

• SKU codes and model numbers that internal employees know by memory must be spelled out in the partner glossary because new partners have not yet memorized them. Every product SKU, model code, and variant designation used in partner training content should be in the glossary with both the canonical spelling and the phonetic variants an ASR system might generate.
• Competitor product names referenced in competitive positioning content should be included with correct spellings. An ASR system trained on general language data may render a competitor's brand name using an alternative phonetic interpretation; the partner glossary should include the correct renderings of all competitor names referenced in the training content.
• Integration and API terminology — endpoint names, parameter names, response codes, error messages — should be included verbatim. API endpoints rendered in training video narration should appear in the glossary with both the spoken form (how the narrator says them) and the canonical written form (how they appear in the API documentation).
• Certification exam vocabulary is the highest-priority subset. Any term that appears in a certification assessment — as a correct answer option, a distractor, or a question term — must be rendered with 100% accuracy in the training video captions, because the training video is the learner's primary exposure to the term before the exam.

The glossary build process for extended enterprise content differs from the internal employee glossary process in one key operational respect: the extended enterprise content team (often the channel marketing or partner enablement team) typically does not own or have access to the L&D caption programme's glossary infrastructure. Building the partner glossary requires coordination between the L&D captioning team, the partner enablement team (who know the partner vocabulary), and the product marketing team (who own the SKU nomenclature and product naming standards). The governance policy for extended enterprise captioning should assign the glossary maintenance responsibility explicitly — the partner enablement team owns vocabulary sourcing, the L&D captioning team owns glossary formatting and ASR integration.

Caption delivery architecture: three scenarios

Scenario A: Brand controls the extended enterprise LMS

In Scenario A, the brand operates the LMS or video portal that partners log into to complete training. The brand controls the content library, the user management, and the caption delivery configuration. This is the most operationally straightforward scenario for caption compliance because every variable — content upload, caption file attachment, player configuration, caption display settings — is under the brand's control.

The caption delivery workflow for Scenario A: (1) Caption all video content using the brand's standard caption production workflow (glossary-biased ASR, DCMP-protocol QA, SRT file output). (2) Upload the SRT file as a caption track on the video asset in the LMS or video host. (3) Configure the player to display captions by default (not requiring learner activation). (4) Verify caption display in the external partner-facing portal, not just in the internal admin interface — caption display settings sometimes differ between the admin preview and the learner-facing portal. (5) Document the caption track upload and QA result for each content item in the compliance record.

The failure mode specific to Scenario A is content update without caption update: when the brand updates a training video (new product features, pricing changes, revised procedures), the original caption file becomes stale. A 30% audio change — the threshold for triggering a new caption review — should be tracked by whoever manages the extended enterprise content library, and any content update above that threshold should trigger a caption re-review and SRT file update before the updated video is published to the partner portal.

Scenario B: Brand delivers SCORM packages to partner LMS

In Scenario B, the brand produces SCORM or xAPI content packages and delivers them to partners who upload and deploy those packages in the partner's own LMS. The partner's LMS — which might be a small business LMS, a commercially available platform, or a custom-built training portal — is outside the brand's control. The brand cannot manage caption configuration in the partner's LMS; the brand's only control point is the SCORM package itself.

Caption delivery in SCORM packages depends on the authoring tool and the caption approach used in the source content. For video-primary SCORM content (slides with embedded video), the options are: (a) burn captions into the video file (open captions — always visible, not toggleable, but guaranteed to render in any player); (b) include the SRT file as a companion file in the SCORM package and reference it from the video player configuration in the SCORM HTML; or (c) use the authoring tool's native closed caption support (Articulate Storyline's text-sync CC feature, Captivate's closed caption text track) within the SCORM package.

Open captions (burned-in) are the most reliable delivery method for Scenario B because they do not depend on the partner's LMS supporting SRT sidecar rendering or the authoring tool's caption mechanism displaying correctly in the partner's browser. The tradeoff is that open captions cannot be turned off by learners who do not need them and cannot be styled to match the partner LMS's visual design. For accessibility compliance purposes, open captions fully satisfy WCAG 2.1 AA SC 1.2.2 — the requirement is synchronized captions, not toggleable captions.

The SCORM delivery channel agreement should specify that the brand delivers content with captions embedded or attached, and that the partner is responsible for deploying the content in an LMS that renders the captions as delivered. If the partner's LMS strips or suppresses caption tracks from SCORM packages on import (a known issue with some older SCORM 1.2 implementations), the partner must notify the brand and identify an alternative delivery method. Including this specification in the channel agreement (see the contract provisions section below) prevents the "we didn't know the captions weren't displaying" defence from succeeding when a partner's hearing-impaired employee cannot access captioned content.

Scenario C: Brand delivers media assets (Kaltura, Vimeo, Wistia, YouTube)

In Scenario C, the brand delivers training content as individually hosted video assets — embedded from Kaltura, Vimeo, Wistia, or YouTube — rather than through an LMS. Partners access the video content via shared links, embedded players in a partner knowledge base, or a lightweight portal that presents embed codes without full LMS infrastructure. This scenario is common for informal channel enablement content (product launch videos, competitive battle cards narrated as video, sales technique demonstrations) that supplements the formal LMS-based certification curriculum.

Caption delivery for Scenario C is managed entirely at the video host level: upload the SRT caption track to the Kaltura media entry, Vimeo video, Wistia video, or YouTube video, and configure the player to display captions by default. For Kaltura, the caption track is set at the KMC media entry level and propagates to all embed instances. For Vimeo, the SRT file is uploaded through Vimeo's closed captions interface in the video settings. For Wistia, captions are uploaded through the Wistia caption upload tool and can be configured as auto-visible. For YouTube, the manual SRT upload through YouTube Studio's subtitles interface is preferred over YouTube's automatic caption generation — YouTube's auto-captions fail on technical product vocabulary at the same rates as other ASR services.

The failure mode specific to Scenario C is caption persistence across sharing. When a video is shared from Vimeo as an embed code, the caption track is embedded in the embed; when it is shared as a direct Vimeo link, the Vimeo player on vimeo.com displays the caption track. But when a partner downloads the video file (if download is enabled) and re-uploads it to their own platform, the SRT sidecar file is not automatically included — the partner receives the video file without the caption track. The channel agreement should specify that partners who download and re-host brand video content must include the caption track as provided, and the brand should provide the SRT file as a companion download alongside any downloadable video file.

Contract provisions: eight clauses that make the channel agreement defensible

The channel partner agreement, franchise agreement, or dealer operating agreement is the primary compliance instrument for extended enterprise training that is not clearly covered by ADA Title III. Eight contract provisions, taken together, create an enforceable caption quality standard and allocate liability between the brand and the partner.

1. Technical standard specification

Specify WCAG 2.1 AA Success Criterion 1.2.2 as the technical standard by name. Do not reference "ADA compliance" without the technical specification — "ADA compliance" is not a technical standard and cannot be measured. The provision should read: "All video training content assigned to Partner under this Agreement must meet WCAG 2.1 AA Success Criterion 1.2.2 (Captions — Prerecorded), requiring synchronized captions at 99% or higher word accuracy with a maximum synchronization error of ±2 seconds per caption event." This gives the compliance team a specific, measurable standard for which content is compliant and which is not.

2. Accuracy measurement protocol

Specify how accuracy is measured. DCMP (Described and Captioned Media Program) protocol is the industry standard for training-content caption quality measurement. The provision should reference DCMP spot-check protocol by name and specify the minimum sample rate: "Accuracy shall be measured using the DCMP Quality Spot Check Protocol, applied to a random sample of not less than 10% of each content item's duration." This prevents the use of automated word-error-rate measurement (which overestimates accuracy relative to DCMP scoring) as a substitute for meaningful quality verification.

3. Remediation timeline

Specify the timeline for remediating content that fails the accuracy threshold. A 30-day remediation SLA for captioned content failing the 99% threshold is reasonable for most production workflows. For content identified as critical to partner certification (content that appears in certification assessments), a shorter SLA — 10 business days — is appropriate. The provision should specify: "Brand shall remediate any content failing the accuracy threshold within 30 calendar days of notification, or within 10 business days for content designated as certification-critical. Partner shall notify Brand of any caption quality failure within 5 business days of identification."

4. New content gate

Require that all new training content assigned to the partner portal must be captioned at the specified standard before assignment. This prevents the workflow error in which content is published to the partner portal before captions are added: "Brand shall not assign to Partner's training portal any video content that does not have a verified caption track meeting the requirements of Section [X]. Brand shall verify caption quality before assignment using the DCMP spot-check protocol."

5. Glossary provision

Specify that the brand provides a partner-specific vocabulary list for caption accuracy verification. This is particularly important for product naming, SKU codes, and technical terminology: "Brand shall maintain and provide to Partner a current vocabulary reference list of all product names, SKU codes, configuration parameters, and proprietary terminology used in assigned training content. Brand shall update the vocabulary reference list within 30 days of any product naming or terminology change that affects assigned training content."

6. Partner delivery obligation

Specify the partner's obligation to deploy the captioned content in a way that renders captions correctly. The partner controls the LMS or portal into which the brand's content is loaded, and the partner must ensure that the delivery platform supports caption display: "Partner shall deploy Brand-provided training content in a learning management system or training portal that (a) supports display of the caption track as provided; (b) does not modify, remove, or suppress the caption track on import or deployment; and (c) renders caption text synchronized with video content as specified. Partner shall notify Brand within 5 business days of any delivery configuration issue that prevents correct caption display."

7. Compliance documentation

Require the brand to maintain and provide compliance documentation on request: "Brand shall maintain, for each video training content item assigned to Partner, a record of (a) the caption track verification date; (b) the DCMP spot-check score; (c) the caption file version and last update date; and (d) any remediation history. Brand shall provide this documentation to Partner within 10 business days of Partner's written request, and shall make it available to Partner's legal counsel or compliance officers in connection with any accessibility accommodation request, complaint, or investigation involving a Partner employee."

8. ADA accommodation pass-through

Specify the process for handling ADA accommodation requests from partner employees that relate to caption quality. The partner, as the employer, is the primary party responsible for processing accommodation requests — but the brand controls the content quality. The provision should create a clear escalation path: "In the event Partner receives an ADA or state law disability accommodation request from a Partner employee that relates to the accessibility of Brand-provided training content, Partner shall notify Brand within 5 business days. Brand shall provide, within 15 business days, either (a) a WCAG 2.1 AA-compliant version of the requested content; (b) an accessible transcript of the content; or (c) written confirmation that the content cannot be made accessible by the deadline, with an alternative accommodation proposal. Brand's failure to respond within 15 business days authorizes Partner to source a captioned version from a third party at Brand's expense."

Franchise networks and dealer academies: operational structure and compliance documentation

Franchise and dealer networks have operational characteristics that distinguish them from channel partner relationships and require additional compliance documentation beyond the standard contract provisions.

For franchise networks, the Franchise Disclosure Document (FDD) is the primary disclosure instrument and is regulated by the FTC Franchise Rule (16 CFR Part 436). FDD Item 11 covers training — the franchisor is required to disclose the subject matter, location, duration, and instructors of the initial training programme and any ongoing training. Accessibility of the training content is a material aspect of the training programme for franchisees whose employees include individuals with hearing impairments. While the FTC Franchise Rule does not explicitly require disclosure of caption quality specifications, the standard of providing complete and accurate disclosure under Item 11 encompasses the accessibility characteristics of training content that affect the franchisee's ability to train their employees in compliance with applicable law.

The practical FDD implication: the Item 11 training description should specify that all video training content in the franchise training programme meets WCAG 2.1 AA captioning standards. This provides the franchisee with the information needed to represent to their employees (and to state employment agencies if investigated) that the franchise training programme's accessibility meets the required standard. The caption quality specification in the FDD also creates a franchisor obligation — once disclosed, the franchisor must actually provide captioned content meeting the disclosed standard, or update the FDD to reflect a different standard.

For dealer networks, the dealer operating agreement or dealer sales and service agreement is the operative document. The caption quality provisions described in the contract provisions section above apply to dealer agreements in the same way as channel partner agreements. The operational characteristic that distinguishes dealer training from channel partner training is the service procedure dimension: dealer certification on service procedures involves technical content (torque specifications, part numbers, diagnostic procedures, fluid types and quantities) where caption accuracy is a safety-critical dimension, not just a compliance dimension. A dealer technician who misreads a torque specification from a poorly captioned training video and applies the wrong torque to a safety-critical fastener creates a product liability exposure for the manufacturer that exceeds the ADA compliance exposure.

Dealer academy caption compliance documentation should be maintained at the content item level, with records of the caption QA date, the DCMP spot-check score, and the service procedure verification date (confirming that all technical specifications in the captions match the current service manual values). When the manufacturer issues a service bulletin that changes a specification, the training video caption must be updated to reflect the revised specification — the caption file is not just an accessibility artifact; it is part of the technical training record.

For both franchise and dealer networks, the compliance documentation strategy should include a training programme accessibility statement — a document that describes the accessible features of the training programme (captioned video content, transcript availability, accessible LMS player) and provides a mechanism for franchisee or dealer employees to request alternative formats or accommodations. This statement can be incorporated into the franchise training materials package or the dealer academy welcome documentation, and its existence is evidence of the brand's affirmative accessibility programme — relevant to good-faith defence arguments in any ADA complaint or investigation.

Eight failure modes in extended enterprise caption compliance

1. Treating extended enterprise training as excluded from the caption programme scope

The most common failure mode is structural: the caption compliance programme is scoped to "all employee training" and extended enterprise training is administratively classified as "partner content" or "channel content" that is outside the L&D team's remit. The partner enablement team produces and manages partner training video; the L&D team manages the caption compliance programme; the two teams do not coordinate; and the partner portal accumulates years of uncaptioned video content while the internal employee LMS is audited and remediated. The prevention is to include extended enterprise content in the caption compliance programme scope from the programme's inception, with a written scope statement that names the partner portal and channel training library alongside the internal LMS. The caption compliance programme build guide covers the scope definition step in detail.

2. Assuming authenticated partner portals are automatically exempt from ADA Title III

An L&D or legal team determines that the partner portal requires a partner agreement and login credentials, concludes that it is not a "public accommodation" because it is not accessible to the general public, and decides that ADA Title III does not apply. The analysis is applied at the entity level (the portal as a whole) rather than at the geographic level (the circuits in which the brand operates). In the Ninth Circuit, courts have applied Title III to authenticated digital services without requiring a physical-place nexus. A brand with partner portal users in California that has not captioned its partner training content based on the "authenticated portal" reasoning is exposed to Ninth Circuit Title III litigation. The prevention is to obtain circuit-specific legal analysis before relying on the authenticated-portal argument, and to implement WCAG 2.1 AA captions regardless of the Title III analysis — the contractual theory closes the gap the statutory analysis leaves open.

3. Not specifying caption quality in the channel partner agreement

The channel partner agreement specifies that the brand will provide training and certification content, but does not include any specification of caption quality or accessibility standard. The brand produces captioned content — but with 94% average word accuracy rather than 99% WCAG 2.1 AA. A partner's hearing-impaired employee files a complaint through the partner company's HR process; the partner requests a captioned version meeting WCAG 2.1 AA from the brand; the brand reviews its content and determines that it does not meet the standard. The partner must now accommodate the employee through alternative means (transcript, sign language interpreter) while the brand remediates its content — a process that takes months. The prevention is the contract provision structure described above, with accuracy threshold, measurement protocol, and remediation SLA specified before a complaint arises.

4. Using the internal employee glossary without modification for partner-facing content

The brand's internal L&D caption programme uses a company glossary that includes all products, SKUs, and technical terms used in internal training. The partner enablement team uses the same glossary for the channel training content captions because it is the glossary that is available. The internal glossary is calibrated to the vocabulary density and error distribution of internal training content — which is produced by internal employees who know the product vocabulary and self-correct misstatements. Channel partner content is produced for audiences who are encountering the vocabulary for the first time, and the vocabulary subset that is most critical for new learners (certification vocabulary, exam terms, SKU codes used in assessments) is not necessarily the highest-frequency vocabulary in the internal glossary. The prevention is a partner-specific glossary that prioritizes certification vocabulary and assessment terms over frequency-weighted internal vocabulary.

5. Failing to verify caption display in the partner-facing view after LMS configuration changes

The brand's extended enterprise LMS team updates the player configuration — switching from the LMS's native video player to an external video player integration, updating the LMS to a new version, or changing the SCORM runtime version from SCORM 1.2 to SCORM 2004. After the update, the internal admin view shows caption tracks correctly, but the external partner-facing view has a player version that does not render the caption track that was uploaded. The brand does not discover the issue until a partner employee reports that captions are not displaying — at which point, all partners who logged into the portal during the affected period have been accessing uncaptioned content. The prevention is a post-configuration-change caption verification protocol: after any LMS player configuration change, verify caption display in the partner-facing portal view (not the admin view) for at least three representative content items before clearing the change as complete. The LMS migration caption checklist covers the post-migration verification protocol; the same verification steps apply after platform configuration changes that affect the video player.

6. Not captioning content from third-party compliance training vendors before assigning to partner portal

The brand licenses compliance training content (harassment prevention, data security, workplace safety) from a third-party compliance training vendor and assigns that content to the franchise or partner training portal as part of the mandatory training curriculum. The vendor provides auto-generated captions at 87–92% accuracy. The brand assigns the content without reviewing the caption quality, treating the vendor's provision of captions as satisfying the WCAG 2.1 AA requirement. A franchisee's employee with a hearing impairment completes the harassment prevention training relying on the captions; the captions misrender key policy terms; the employee later files a harassment complaint and claims the training was inaccessible. The brand is the party who assigned the content; the brand bears the compliance obligation for caption quality regardless of whether the content was self-produced or licensed. The prevention is the same analysis described in the third-party compliance training captioning guide — the brand must verify caption quality on all assigned content, not assume the vendor's provision of captions satisfies WCAG 2.1 AA.

7. Using content update cadence that does not trigger caption re-verification

The brand's partner portal uses evergreen training content — product training videos that are updated quarterly as products evolve. Each quarterly update replaces 10–30% of the video narration: new pricing, new features, revised procedures. The caption file is not updated after content revisions below a certain threshold of change because the update process (re-submit to ASR, QA, upload revised SRT) is cumbersome. After three quarters, the caption track references discontinued pricing tiers, removed product features, and superseded procedure steps — while the video narration reflects the current product. Partners completing certification training are being certified to the current narration but receiving captions that reference outdated content. The prevention is a content revision trigger in the caption programme workflow: any revision to a training video's narration triggers a caption re-review, with the DCMP spot-check run on the revised segments before the updated content is published. A percentage-change threshold (10% audio change triggers re-review) provides a manageable workflow without requiring full re-review of unchanged content.

8. Structuring contractor training as "not training" to avoid the joint employer analysis

A brand that uses contractor pools (field service technicians, retail merchandisers, IT contractors) concludes that the joint employer analysis makes training risky and restructures the training relationship: instead of assigning contractors to the brand's training portal, the brand provides a "reference library" of product information videos and labels them as informational resources rather than required training. The contractor staffing agency is nominally responsible for any required training. In practice, the brand's service quality standards for contractor-performed work require knowledge that is only conveyed through the "reference library" videos; contractors who have not watched the reference library videos consistently fail quality audits; and the brand's field operations team informs contractors (via the staffing agency) that watching the reference library is a performance expectation. Courts applying the joint employer economic reality test would likely look through the "reference library" label to the operational requirement — the brand controls the standards, the performance expectation, and the consequence (contractor removal) for not meeting the standard. The prevention is to address the joint employer analysis directly rather than through labeling — caption the contractor reference content at WCAG 2.1 AA, include the captioning specification in the staffing agency master service agreement, and document the accessibility programme as a good-faith effort regardless of how the joint employer question ultimately resolves.

FAQ

We require partners to complete our certification training as a condition of the partner agreement. Does that mean we're responsible for captioning?

Yes, under the contractual enforcement theory, and potentially under ADA Title III depending on how your portal operates and which federal circuit you're in. The contractual theory applies regardless of the Title III analysis: when you require training completion as a condition of a commercial relationship, you control what training content is available and whether that content is accessible. If a partner's employee with a hearing impairment cannot access the certification training you require, you — as the party who assigns the training and controls its content — are the party positioned to remediate the accessibility failure. The channel partner agreement should reflect this reality through the eight contract provisions described in this post. If your agreement is already signed without accessibility provisions, add a contract amendment or rider specifying WCAG 2.1 AA caption quality before the next complaint arises. Your partner bears the accommodation obligation under ADA Title I (as the employer), but your partner cannot accommodate an employee if you refuse to provide accessible content — and your refusal creates the liability gap that the contractual framework should close.

Our franchise agreement requires franchisee employees to complete our training. Are we a joint employer for caption accommodation purposes?

Possibly, in California, New York, and Illinois — states with broader joint employer doctrine in franchise contexts. The joint employer analysis turns on how much control the franchisor exercises over the content, completion requirements, and consequences of non-completion for franchisee employee training. If your franchise agreement (a) specifies required training modules by name, (b) sets completion deadlines tied to franchise operational milestones, (c) ties compliance or renewal to franchisee employee completion rates, and (d) directs what franchisee employees must do as a result of the training — you are exercising substantial control over the training component of the franchisee employment relationship. California courts applying PAGA have found joint employer status in franchise relationships with less control than this. The conservative compliance position — caption all mandatory franchise training content at WCAG 2.1 AA — eliminates the caption-accommodation dimension of any joint employer finding. You may still face joint employer analysis for other training-related obligations, but caption quality will not be the vector.

A dealer's technician employee requested captioned training. The dealer says it's our responsibility. Are they right?

Partially. The dealer, as the employer, has the primary ADA Title I obligation to accommodate their employee's hearing impairment — the accommodation obligation runs from employer to employee, and the dealer is the employer. But the dealer's ability to accommodate the employee depends on whether accessible training content is available from you, the manufacturer. If you control the service training content and you refuse to provide a captioned version, the dealer must find an alternative accommodation (sign language interpreter for live training, human-captioned recording, written transcript) that may be less effective for technical service procedure training. The practical answer is to provide the captioned content — the cost of captioning one service training video is far lower than the cost of a dispute over who bears the accommodation obligation. Your dealer operating agreement should specify the eight contract provisions described in this post, including the 15-business-day response timeline for accommodation requests tied to your content. If the dealer agreement is already signed, a letter of agreement covering captioning obligations is the near-term fix.

We run an open certification programme — anyone can sign up and pay the fee. Is this ADA Title III?

Yes, almost certainly. An openly accessible certification programme — where any individual can register, pay a certification fee, access the training content, and take the certification exam — is a place of public accommodation under ADA Title III in the same way that a physical training facility or testing centre is a public accommodation. The DOJ's 2022 web accessibility guidance confirms that digital platforms providing goods or services to the public must be accessible. Your certification programme is providing a service (certification training and examination) to any member of the public who pays the fee. ADA Title III requires that service to be accessible to individuals with disabilities, including through the provision of synchronized captions on all video training content at 99%+ word accuracy. There is no revenue threshold, employee size threshold, or authentication mechanism that removes an openly accessible certification programme from Title III coverage. All video content in the programme should be captioned at WCAG 2.1 AA as a Title III compliance matter.

What's the practical difference between "partner training captioning" and "customer education captioning" from a compliance standpoint?

The legal framework differs; the technical caption quality standard is identical. Customer education captioning — covered in the customer education captioning guide — applies to training delivered to customers through a publicly accessible or publicly marketed academy (Skilljar, Thought Industries, Gainsight CE). The compliance theory is ADA Title III public accommodation for all accessible content. Partner training captioning applies to training delivered to channel partners, resellers, franchisees, and dealers through authenticated portals or contractually required training assignments. The compliance theory is ADA Title III where the portal is accessible to the public, and contractual enforcement theory where the portal is restricted. In practice, both categories require WCAG 2.1 AA captions on all video content — the legal theories differ, but they point to the same technical standard. The operational difference is the contract provisions: customer education captioning is governed by terms of service (which you draft); partner training captioning is governed by bilateral commercial agreements (channel partner agreements, franchise agreements, dealer agreements) that must include mutual obligations and remediation timelines.

Our contractor staffing agency says captioning contractor training is their responsibility, not ours. Who is right?

The contractor is employed by the staffing agency; the staffing agency has the primary ADA Title I accommodation obligation for its employees. But if you control the content of the training the contractor completes, the staffing agency cannot provide accessible training without your cooperation. The master service agreement between you and the staffing agency should specify that any training content you require contractors to complete will be provided with WCAG 2.1 AA captions, and that the staffing agency is responsible for deploying that content in an accessible format through its LMS or training portal. The MSA should also include the ADA accommodation pass-through provision described in the contract section above: when the staffing agency receives an accommodation request from a contractor that relates to your content, they must notify you within 5 business days, and you must provide accessible content within 15. Neither party can discharge the compliance obligation by pointing exclusively to the other. Structure the MSA to allocate responsibilities clearly: you own content quality; the agency owns accommodation processing and LMS delivery.

How do we audit our extended enterprise content library for caption compliance?

The LMS caption audit methodology provides the audit framework for internal LMS libraries; the same framework applies to extended enterprise content with three adjustments. First, expand the scope definition to include all partner portals, franchise training systems, and dealer academy platforms — not just the internal LMS. Map every system where video training content is deployed to non-employee audiences and include it in the audit scope. Second, adjust the inventory extraction method for each system: Cornerstone and Docebo provide content library exports through their admin interfaces; TalentLMS branch inventories require branch-by-branch export; Kaltura provides a media entry export through KMC. Extract a complete list of video assets in each system, with caption track presence indicated where the platform exposes that metadata. Third, adjust the QA sampling strategy to prioritize certification-critical content first: start with any video content that is directly referenced in certification assessments (the content a learner must watch before they are tested), apply DCMP spot-check QA to those items first, and work outward to supplementary and reference content. Document the audit results at the content-item level, including the system where each item is deployed, the caption QA date, the DCMP score, and the remediation history. Maintain this record as the compliance evidence base for any ADA investigation or partner accommodation request.