DOJ's cinema-access rule was published Friday, December 2, 2016. This December 3 retrospective explains its timetable, not a Saturday announcement. The rule becomes effective January 17, 2017, but equipment and access compliance for auditoriums showing digital movies on December 2, 2016 is due June 2, 2018. Those dates describe different obligations. [2016-28644][2014-17863]

For an auditorium converted from analog after December 2, 2016, the deadline is the later of December 2, 2018 or six months after complete installation of digital projection. Separately, January 17 notice and staff-assistance requirements apply when captioning and audio description are provided. A single headline date cannot accurately summarize all three situations. [2016-28644][2014-17863]

The August 1, 2014 proposal helps explain the change. DOJ had proposed six-month compliance for digital screens and considered a four-year analog deadline or deferral. The final rule does not impose these specific requirements on exclusively analog auditoriums. That is a limited deferral, not a blanket exemption from the Americans with Disabilities Act. The proposal and final document are one rulemaking chain, not independent corroboration. [2016-28644][2014-17863]

Coverage is also bounded by the film and venue. Captioning and audio description are required when a digital movie is distributed with those features, subject to undue burden or fundamental alteration. Theaters need not create unavailable features. The regulatory definition excludes drive-ins and concerns facilities used primarily to show movies to the public for a fee. Readers assessing a showing therefore need scope and timing, not merely the fact that DOJ issued a final rule. [2016-28644][2014-17863]

Source documents

  1. Nondiscrimination on the Basis of Disability by Public Accommodations-Movie Theaters; Movie Captioning and Audio Descriptionhttps://www.govinfo.gov/content/pkg/FR-2016-12-02/html/2016-28644.htm
  2. Nondiscrimination on the Basis of Disability by Public Accommodations-Movie Theaters; Movie Captioning and Audio Descriptionhttps://www.govinfo.gov/content/pkg/FR-2014-08-01/html/2014-17863.htm