Dear Executive Vice-president Henna Virkkunen,
Dear Commissioner Hadja Lahbib,
The undersigned European organisations of persons with disabilities, representing more than 100 million persons with disabilities in Europe, jointly call on the European Commission to live up to its obligations under the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) and to strengthen accessibility in the upcoming revision of the Audiovisual Media Services Directive (AVMSD).
The audiovisual sector has always played a central role in shaping democratic societies and enabling cultural expression across Europe. However, when media content is not accessible, persons with disabilities are denied their most basic human rights: cultural life, political participation, freedom of expression and opinion, access to information and appropriate protection during human-made and natural disasters.
Article 7 of the AVMSD is key to implement the UN CRPD in the audiovisual sector. However, while existing EU rules are an important initial step, it is evident that they have failed to produce the desired effect and equal access to audiovisual media services is not yet guaranteed.
The general wording of Article 7 of the AVMSD and the lack of specific media accessibility requirements under the European Accessibility Act (EAA) have led to divergent approaches to the accessibility of the audiovisual media sector which, in our view, undermine the spirit of this legislation.
This issue has also been identified by the UN CRPD Committee. In its 2025 concluding observations to the EU, the committee warned: “the Audiovisual Media Services Directive lacks timelines and targets for implementation and does not ensure accessibility of video-sharing platforms, social media and the audiovisual sections of news websites”.(pt. 52(b)). In the same document, the Committee recommended the EU to “set timelines and harmonised EU-wide criteria for audiovisual accessibility in the Audiovisual Media Services Directive, including quantitative and qualitative targets” (pt. 53(b)).
Recent reports, including those of the European Audiovisual Observatory (2023) and the European Regulators Group for Audiovisual Media Services (2021), provide detailed evidence on the different measures taken by Member States. Notable findings include:
- Accessibility obligations differ depending on the AVMS provider. In general, they are higher for, or only applicable to, public broadcasters while obligations for commercial broadcasters and video-on-demand platforms are weaker or non-existent[1], undermining the purpose of Article 7(1) of the AVMSD.
- Accessibility obligations differ depending on the type of access service. Certain access services are prioritized over others, leading to discrimination among different disability groups. In general, pre-recorded subtitling is more prevalent than live subtitling, audio description, sign language and spoken subtitles.
- Quality of access services. Few Member States have introduced quality considerations in the provision of access services. This results in situations where subtitles are not specifically designed for deaf and hard-of-hearing persons, audio-description is not delivered by trained professionals or sign language interpreters are not qualified or not easily visible on the screen.
In addition, we must not overlook the changes in the way people consume audiovisual services. While linear television, where accessibility obligations are traditionally stronger, remains relevant, an increasing number of people access audiovisual media content through video-on-demand platforms, video-sharing platforms, online news sites and social media. Unfortunately, the existing EU legal framework fails to address this reality, leaving accessibility as a voluntary practice.
To truly advance accessibility for persons with disabilities, and fulfil its obligations under the CRPD, the European Commission must ensure that the upcoming AVMSD revision:
- Strengthens the wording of Article 7(1) to ensure that all audiovisual media service providers – both public and commercial TV channels as well as video-on-demand platforms – continuously make their services accessible to persons with disabilities. This means to ensure progress on media accessibility for all AVMS providers and for all access services.
- Establishes harmonised accessibility requirements across the different access services.
- Ensures that emergency information (article 7(5)) is accessible to all persons with disabilities with all necessary access services and easy to understand content.
- Ensures the diversity of accessible content across all kinds of programming, including programs for children, sports, culture or films.
- Addresses the inaccessibility of video-sharing platforms, social media and online news platforms.
- Strengthens cooperation of audiovisual media service providers and regulators with organisations of persons with disabilities.
- Establishes robust monitoring and sanctions mechanisms for non-compliance.
- Ensures that access services become a mandatory component of exploitation rights so that they are automatically transferred when content is resold. When access services are unavailable, there should be the possibility to add them to the content without the need of acquiring additional rights.
In other words, the AVMSD must move beyond general duties of progressive improvement and instead promote measurable and enforceable minimum accessibility obligations at the European level. In our experience, the best way to ensure this is through quotas that specify with clear timelines the percentage of audiovisual content to be made accessible for each type of access service and for each type of audiovisual service provider (public and private broadcasters and on-demand platforms). To date, only 16 Member States have introduced such system[8]. The revised AVMSD should require this to all Member States.
Although we recognize the relevance of the topics identified so far by the Commission during the evaluation and consultation process, we believe that any meaningful attempt to improve the existing rules on audiovisual media services, should address the concerns outlined in this letter to ensure equal rights for persons with disability.
We thank you for your consideration and remain available to further support the Commission in preparing this important initiative.
Yours sincerely,
European Blind Union (EBU) Tytti Matsinen, President
European Disability Forum (EDF) Gunta Anca, President
European Federation of Hard of Hearing People (EFHOH) Lidia Best, President
European Union of the Deaf (EUD) Sofia Isari, President
Inclusion Europe Jyrki Pinomaa, President