How To Make Audiovisual Content EAA-Compliant

To meet the European Accessibility Act requirements, especially if you’re publishing a lot of video content, automating the addition of subtitles and captions is key. This approach not only ensures compliance but also makes your content more accessible and engaging for all viewers. Let’s dive in!

What is the European Accessibility Act?

The European Accessibility Act (EAA) is a law of the European Parliament and of the European Council that took effect in April, 2019. The mandate addresses accessible products and services across the entire European Union (EU), replacing Member State rules, and by 2025, all Member States must be in compliance. Captions and subtitles for audiovisual (AV) media services are indispensable features for compliance with the EAA in order to make products and services accessible for deaf and hard of hearing individuals.

First proposed in 2011 as a complement to the EU's Web Accessibility Directive (which focused on the public sector and became law in 2016), the EAA began with a proposal by the European Commission to harmonize accessibility requirements. It incorporates inclusive design and accessibility standards for all manner of consumer information and public services.

As a result of the vast collection of standards along its development path, the EAA is quite comprehensive. Many committees worked through several years and myriad consultations with disability organizations, industry representatives, and accessibility experts to arrive at a detailed directive that ensures inclusivity for basically any type of product and service communication.

The directive’s requirements apply to public and private organizations with more than 10 employees and an annual turnover under EUR 2 million. All companies above the exception threshold need to ensure all their media is accessible. And soon. This article addresses compliance with subtitling and captioning systematically incorporated in audiovisual content.

Far Reaching Impact

The EAA refers to audiovisual media services as defined in a previously enacted EU rule, the 2010 Audiovisual Media Services Directive. According to this directive, audiovisual media services include mass media used “to inform, entertain, and educate the general public, and should include audiovisual commercial communication.” Private correspondence is excluded, but intra-office communications are not, which brings inclusivity into labor directives territory as well.

The pre-EAA rule considers that audiovisual media services have both cultural and economic value with increasing significance for societies, democracy, and education. While making such services accessible by way of features like subtitles for the deaf and hard of hearing (SDH) is mandatory only for companies above the threshold previously mentioned, it makes no sense, not even for single content creators, to ignore the directive.

Although compliance is a good reason for making content accessible, a single creator and companies of any size that add subtitles to valuable information, entertainment, marketing, or educational content can expect to expand their viewership, potentially on a global scale depending on the type of content and target language chosen.

Audiovisual Media Subtitling

The EAA requirements for audiovisual media services do not specifically mention captions or subtitles, but the need to add them is implied in the language: “services transmitted by electronic communications networks which are used to identify, select, receive information on, and view audiovisual media services and any provided features, such as subtitles for the deaf and hard of hearing, audio description, spoken subtitles and sign language interpretation.”

As mentioned above, the directive is wide in scope, and it includes most products with a digital user interface, such as personal computing devices, any public communication systems, and any kind of transactional or informational terminal. Audiovisual materials are considered across the gamut of products and services, though. In general terms, the directive mandates for audiovisual content to be accessible, as in being compatible with assistive technologies and also providing access for people with specific disabilities, such as deaf or hard of hearing, and visually impaired people.

Specific mentions of AV services are:

• Websites

• Online apps

• Set-top box-based apps

• Downloadable apps

• Mobile device-based services (apps, players, and streaming services)

This means that any video media inside these services must be accessible via subtitles for the deaf and hard of hearing (SDH). There are differences between subtitles and captions, and these differences should be understood within the context of language access as well as accessibility.

The best way to comply, especially when an organization already has a vast amount of video-based media, is to automate the addition of subtitles and/or captions across the entire library of media assets. Note that expecting viewers to turn on auto-generated subtitles in platforms like YouTube will not make the video creator compliant with the EAA.

A number of tasks involved in generating good quality SDH or multilingual subtitles can benefit from various levels of automation, for example:

Transcription

This is the first step in the process. Automatic transcriptions can capture the audio content of the video, including dialogues, time stamps, and speaker identification. A human should review the transcriptions to make corrections and keep or eliminate fillers (fillers remain if verbatim captions are being created).

Adaptation for readability.

An AI-based application can flag places where transcribed segments do not meet essential readability criteria such as characters per line (CPL) and characters per second (CPS).

Translation

When translation applies (Member States decide based on content purpose), machine translation or AI-enabled translation is a good way to save time and costs, provided a human linguist reviews the translations to ensure they are accurate and fit the cultural and topical context.

Timing adaptation

After subtitles have been translated, they need to be checked and adjusted to ensure timing was preserved. Automated checks can flag CPL and CPS deviations, and a human can subsequently fix any issues.

Quality assurance (throughout the process, not just at the end)

Automated language checks can include spelling and other issues, and humans can read through for things such as country-specific standards or censored language.

Integration with video

When ready, subtitles are integrated with the video file in different formats that vary based on preference and platform.

Testing and validation

Subtitles should be tested on different devices and platforms to ensure they display correctly and are accurately synched with the audio.

Automation is the key to EAA compliance as increasing amounts of video content are created. It is not just a matter of volume, but also of incurring costs that could become prohibitive without the help of technology. If an organization’s media assets are already organized and sorted, certain technologies can also help automate the compliance process even more via platform integration, but the most important step is the first one: transcription, a task that can already be accomplished in minutes thanks to AI transcription and automated subtitles.