What the European Accessibility Act means for the Media Industry : Limecraft

With the European Accessibility Act now rapidly approaching, there is growing concern and confusion within the media industry about the specific requirements, particularly around captioning and subtitling. This article summarises our current understanding of the EAA’s intent. It clarifies the specific requirements for captioning and subtitling of audiovisual content, what it means for broadcasters, and what steps you can take to ensure compliance.

The Intent of the European Accessibility Act

The European Accessibility Act (EAA) is an EU directive that aims to improve the functioning of the internal market for accessible products and services, by removing barriers created by divergent rules in member states. The EAA is a landmark legislative framework, designed by the European Union to improve accessibility for individuals with disabilities across a broad range of goods and services. This includes, without limitation, computers and smartphones, ticketing machines, websites, and – for this matter – audiovisual media.

Taking effect on June 28, 2025, the EAA mandates that businesses operating within the EU, as well as those outside the EU but providing services to EU residents, must ensure that their products and services are accessible. The EAA, while broadly focused on digital and online services in general to foster a more inclusive society, has a material impact on the production and distribution of audiovisual media.

The Key Focus Areas of the European Accessibility Act (EAA)

The 2025 European Accessibility Act (EAA) is a directive designed to enhance accessibility for people with disabilities by harmonising accessibility standards across the EU. It aims to remove barriers in various areas of life and promote inclusivity in the EU’s single market.

These are some of the Key Focus Areas:

Consumer Products and Services: Household appliances, such as TVs, telephones, and e-readers, must comply with accessibility requirements. Service providers in retail, hospitality, and other sectors must offer accessible customer experiences.
Transportation Services: Booking and ticketing services, including online systems for public transport, must be accessible. Information at terminals, such as flight or train schedules, must be available in formats accessible to individuals with sensory impairments.
Banking Accessibility: Self-service Terminals: ATMs, ticketing machines, and check-in kiosks must be usable by all, including people with visual or physical impairments.
Digital Accessibility: Companies must ensure that their websites, mobile apps, and digital interfaces comply with accessibility standards, such as WCAG 2.1.
Audiovisual Media: Broadcasters and streaming service providers must produce accessible content, providing complementary closed captions and audio descriptions to make content accessible to individuals with hearing or visual impairments.

What Are the Specific Requirements for Captioning and Subtitling Imposed by the EAA?

Article 11 of the 2025 EAA states that “There is also a need for concerted action to ensure that electronic content, electronic communications services and access to audiovisual media services are fully available to persons with disabilities.”

Article 23 states that the Directive should make functional accessibility requirements compulsory, that the requirements should be precise enough to create legally binding obligations, and sufficiently detailed so as to make it possible to assess conformity as well as leave a certain degree of flexibility in order to allow for innovation.

Further to these general statements, the 2025 EAA refers to the accessibility of audiovisual media services as regulated in Directive 2010/13/EU of the European Parliament, that dates back from March 2010. This states that the right of persons with a disability and of the elderly to participate and integrate in the social and cultural life of the Union is inextricably linked to the provision of accessible audiovisual media services. The means to achieve accessibility should include, albeit not necessarily limited to, sign language, subtitling, audio-description, and easily understandable menu navigation.

Implications for Broadcasters and Content Creators

While most (if not all) broadcasters have developed a solid pedigree over the last couple of years in producing high-quality subtitles, either open captions for translating content and closed captions to assist people with a hearing impairment, the implementation of the EAA will likely result in a number of additional requirements that may be more challenging than subtitling regular long-form content.

Notably short-form content may be hard due to the sheer numbers of items (e.g. a typical newsdesk producing 1000’s of clips per month). Also, subtitling live content is likely to remain a challenge, as there will always be a trade off between latency and accuracy.

For content creators that don’t have a background as a broadcaster, the EAA’s requirements may have vastly more far-reaching implications. While some micro-enterprises are exempted from the obligations, they will be encouraged as well to provide services that comply with the accessibility requirements. In either case, content creators will need to make significant adjustments to their production workflow and technology stack to ensure compliance:

Technology Stack: Unless they outsource the production of subtitles, content creators need to invest in or upgrade captioning and subtitling software to ensure that all content meets the required accessibility standards.
Staff Training: Implementing these changes likely requires skilled staff. Not just to operate the software, but first and foremost to make sure subtitles meet an appropriate level of readability and quality. Creating quality subtitles is a matter of good standing; experts will acknowledge that this is infinitely more subtle and complex than just letterboxing by 40 characters on a line.

Steps to Ensure Compliance

EU member states are required to implement the EAA through national laws and regulations by June 28, 2025; in fact most have done so by now. For content creators and broadcasters, it usually boils down to the obligation to provide subtitles, either open or closed captions, for at least 90% (or more) of the published content.

While obviously none of the European nor regional legislation frameworks outline the steps to ensure compliance, these are the steps you should consider to improve accessibility of the content you are producing.

Accessibility Audits: Start with a comprehensive audit of your current services to identify any gaps in accessibility, particularly in captioning and subtitling.
Outsource to experts: numerous great companies specialised in providing high quality subtitles, intralingual (same-language) or interlingual (translated), live or on demand, can help you with your subtitling requirements.
Do it yourself (DIY): in case you have the time and the resources, you may want to create subtitles yourself. In cases where the quality of the audio is good enough, Artificial Intelligence (audio transcription and natural language processing) can do the grunt work, but don’t neglect the human touch. AI is prone to errors, and you should not take it for granted.

💡More on subtitling and localisation on our website, and on the use of AI subtitling on the Knowledge Base

Spill Over Effects

Important to mention is that there are, besides the accessibility of content as such, numerous advantages to producing content with proper quality subtitles.

As a producer, you are also reaching those people who don’t want to use audio. For example, an estimated 50% of content created for social media is consumed without audio.
By localisation of content using subtitles translated from the original language, you are potentially addressing a global audience far beyond a single regional community without having to reproduce the material in other languages
When distributing content with subtitles in the form of a side-car file, search engines perceive this as a strong indicator for increased relevance. Search engines rank content with complementary subtitles significantly higher compared to the same pieces of content without subtitles.

Repercussions for Non-Compliance

Member states are required to enforce the EAA through national laws and regulations by June 28, 2025. Penalties will apply for non-compliance, ensuring businesses and public services adhere to the standards.

While article 98 of the Directive states that such penalties ‘should be adequate in relation to the character of the infringements and to the circumstances so as not to serve as an alternative to the fulfilment by economic operators of their obligations to make their products or services accessible’, non-compliance can lead to significant penalties, which vary across EU member states.

Germany: Fines up to €50,000 for non-compliant products (allyant.com)
France: France will bann non-compliant products from the market, with potential daily fines for unresolved issues (allyant.com)
Ireland: Severe non-compliance can result in fines up to €60,000 and/or imprisonment of up to 18 months (Reed Smith LLP)
Sweden: Penalties up to €200,000, along with mandated corrective actions (Recite Me)
Belgium: Fines up to €50,000, with continuous non-compliance potentially leading to business suspension (Recite Me)
Italy: Penalties can be up to 5% of the non-compliant organisation’s turnover, or between €5,000 and €40,000 (Recite Me)

Limecraft Recommends : No Time to Waste, Opt for Decent Quality

While the details of the EAA’s requirements are somewhat vague, the specific targets for content creators and broadcasters are reasonable, feasible, and beneficial at the same time. Hence we suggest not to wait for the deadline on June 28th. In fact, taking into account you may need some changes to the workflow and get on par with proper quality standards, there is no time to waste.

If you are in the video business, subtitles are an essential aspect of your work. Given the numerous benefits and perks that come with subtitles of higher quality, we recommend to not rely solely on computer generated subtitles. For most types of content, AI may take care of the grunt work, but it needs a human touch for great subtitles to help you stand out. To discuss how Limecraft can support your subtitling and localisation needs for recorded content, feel free to contact us.

Stay updated and subscribe to our monthly newsletter 👇.