Subtitles for the deaf and hard of hearing, audio description, sign language and spoken subtitles are a prerequisite for persons with disabilities to access audiovisual content on an equal basis with others and enjoy their right to information, leisure and cultural life.
Since not all audiovisual content includes such important features, the Audiovisual Media Services Directive (AVMSD) has become one of the tools to increase the availability of accessible content. Almost five years after its adoption, EDF organised a webinar on 11 April with key stakeholders to discuss the status of implementation and assess its benefits for persons with disabilities.
To set a general framework, the session started with a presentation by Sofia Karttunen, Legal Officer at the European Commission, who gave an overview of the accessibility provisions of the Directive:
- Obligation to make audiovisual content continuously and progressively more accessible,
- Setting up of an online point of contact for questions and complaints
- Reporting obligations of media service providers and Member States
- Encouragement of accessibility plans
- Accessibility of emergency information.
Sofia also briefed the audience on the upcoming actions in this field. To name a few:
- The European Media Freedom Act will reshape the work of the European Regulators Group for Audiovisual Media Services (ERGA);
- The European Commission will present a Report on the application of the Directive in the first half of the year
- The European Audiovisual Observatory of the Council of Europe will publish a detailed report on audiovisual media accessibility later this year.
To get a better understanding of the measures taken by Member States to transpose the accessibility-related provisions of the AVMSD, Rebecca Parman, Legal Adviser at the Swedish Press and Broadcasting Authority, presented the results of an ERGA Report published in 2021.
Some of the findings presented included:
- the existence of different obligations between the 26 countries surveyed;
- the existence of exceptions to the obligations in 12 countries;
- the lack of quality standards in 18 countries.
Regarding the access techniques, Rebecca explained that 17 countries established obligations to use certain techniques – although combinations are different between these countries – while 9 countries have no obligations whatsoever to use specific techniques.
Gion Linder, Chair Access Services Expert Group at the European Broadcasters Union (EBU), presented some data on the work carried out by public broadcasters in the field of accessibility. The survey carried out in 2022 showed that 78% of the broadcasters surveyed provide subtitling, audio description and sign language.
Regarding the amount of total content that is made accessible, there’s a difference between the different access services: 60% for subtitling, 12% for audio description and 7% for signing. Gion highlighted that accessibility is increasingly seen as an asset rather than a cost.
Shanta Arul, Director of Global Public Policy at Netflix, presented the company’s work to improve accessibility. Among others, she highlighted their investment in Audio description (AD) and Subtitles for the Deaf and Hard of Hearing (SDH), which is always included in the original language of any Netflix-owned content, and their ongoing expansion to include other languages. Shanta also explained Netflix’s initiatives towards ensuring that their service supports the use of assistive technologies – such as screen readers, assistive listening aids settings and voice commands. Finally, she explained that as an entertainment company, their efforts include increasing disability representation both on screen and behind the camera.
Perspectives of organisations of persons with disabilities.
Antoine Fobe, Head of Advocacy at the European Blind Union (EBU), welcomed the positive changes brought by the Directive but warned about its shortcomings: the barriers that visually impaired people still face due to the low availability of audio description or audio subtitling for foreign language, the exclusion of social media and video sharing platforms from its scope, the little consultation with organisations of persons with disabilities when developing and implementing the measures and the lack of tools within the Directive to measure progress.
Lidia Best, President of the European Federation of the Hard of Hearing People (EFHOH), stressed the need to increase the use of subtitling as well as live subtitling -especially for last-minute information – and to consult with organisations of persons with disabilities when implementing the Directive. She called for establishing key performance indicators (KPIs) and Standards to guide how to ensure accessibility.
Daniel Casas, Accessibility Policy Officer, highlighted the problems derived from the broad wording of Article 7 of AVMSD and reminded the participants about the need to ensure progress on all access services and not choose among them, that attention is also paid to the quality of access services and that progress is ensured with clear targets and timelines. Daniel also highlighted the need to pay attention to the interaction between the European Accessibility Act (EAA) and the Audiovisual Media Services Directive.
Presentations
- Presentation Netflix for the AVMSD webinar (PDF document)
- Presentation European Commission for the AVMSD webinar (PDF document)
- Presentation European Regulators Group for Audiovisual Media Services for the AVMSD webinar (PDF document)
Contact
Daniel Casas EDF Accessibility Policy Officer (daniel.casas@edf-feph.org)