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Co-founder @Includio
The European Accessibility Act (Directive 2019/882) came into force on 28 June 2025 across all 27 EU member states. If you operate a streaming platform, broadcast service, or distribute audiovisual content in the EU, parts of this law apply to you.
But there is a lot of confusion about what the EAA actually requires from media companies. Most of the guidance online mixes up the EAA with other legislation, overstates what it mandates, or gets the deadlines wrong.
Here is what the law says, what it does not say, and what you actually need to do.
What the EAA covers (and what it does not)
The EAA covers "services providing access to audiovisual media services." That means the platforms and interfaces people use to find and watch content: websites, apps, electronic programme guides (EPGs), set-top-box applications, connected TV services, and media players (Article 2(2)(b), Article 3(6)).
It does not set quotas for how much content must have subtitles, audio description, or sign language. Those obligations come from a different law: the Audiovisual Media Services Directive (AVMSD, Directive 2018/1808), which each member state implements through its own national legislation.
So when someone tells you "the EAA requires 100% of your content to have audio description by 2025," that is wrong. The EAA requires your platform to be accessible. Your content obligations depend on which country you operate in and what the national regulator requires.
The distinction matters because compliance sits in two different parts of your organisation. Platform accessibility (EAA) is a product and engineering question. Content accessibility (AVMSD/national law) is a production and post-production question.
What the EAA specifically requires for media platforms
Under Annex I, Section IV(b) of the EAA, services providing access to audiovisual media must:
- Provide EPGs that are perceivable, operable, understandable, and robust, and that show information about the availability of access services.
- Ensure that access services (SDH, audio description, spoken subtitles, sign language) are fully transmitted with adequate quality for accurate display.
- Ensure access services are synchronised with sound and video.
- Allow users to control the display and use of access services.
That last point is worth highlighting. EN 301 549 (clause 7.3), the technical standard behind the EAA, requires that user controls for captions and audio description are provided at the same level of prominence as primary media controls. Not buried in a settings menu. At the same level as play, pause, and volume.
The technical standard for conformance is EN 301 549 v3.2.1, which incorporates WCAG 2.1 AA in full. A new version (v4.1.1) incorporating WCAG 2.2 is expected in 2026.
Deadlines and transition periods
New content and services published after 28 June 2025 must comply (Article 2(2)).
Pre-recorded time-based media published before 28 June 2025 on websites and apps is exempt from accessibility requirements (Article 2(4)(a)). But this exemption does not apply to audiovisual media services specifically.
Article 32 provides a transition period: service providers can continue using products (including self-service terminals) that were lawfully in use before 28 June 2025 until 28 June 2030, or until the end of their economic life (up to 20 years for self-service terminals). Service contracts agreed before June 2025 can continue until they expire, but no longer than five years from that date.
This does not mean "all back catalogues must be accessible by 2030." It means the products and systems used to deliver your service get a grace period. If your existing media player or app was in use before June 2025, you have until 2030 to bring it into compliance. But any new platform, app, or interface launched after June 2025 must comply from day one.
Penalties
The EAA requires penalties to be "effective, proportionate and dissuasive" (Article 30). Specific amounts are set by each member state through national law. Germany has set fines up to EUR 50,000 per violation. Other countries have different thresholds. The EAA also allows consumers to take legal action under national law (Article 29).
Microenterprises (fewer than 10 employees, turnover under EUR 2 million) are exempt from service obligations (Article 4(5)).
What about audio description and subtitling quotas?
These come from national regulators implementing the AVMSD:
- UK (Ofcom): 80-90% subtitling, 10% audio description, 5% signing for broadcast TV. New VoD quotas (80% subtitling, 10% AD, 5% signing) coming under the Media Act 2024.
- Spain (CNMC/LGCA): 75-90% subtitling, minimum 2 hours/day audio description on public and commercial channels.
- France (ARCOM): up to 100% subtitling for high-audience channels, AD obligations set per channel agreement.
- Germany (Medienanstalten): progressive obligation to increase accessible content, no fixed percentages.
- Italy (AGCOM): specific targets for RAI (public), guidance for private broadcasters.
For a full country-by-country breakdown, see our reference guide: Audio Description and Subtitling Requirements in Europe.
Each country has its own regulator, its own quotas, and its own enforcement approach. If you distribute across multiple territories, you are dealing with multiple sets of rules.
Why audio description is the hardest part
SDH is well-understood. Most broadcasters have subtitling workflows that scale. Audio description is different.
AD requires a trained describer who can write narration that fits into gaps in the dialogue without stepping on the soundtrack. It requires voice recording, mixing, and QA. For every finished hour of content, expect roughly 8 to 10 hours of production work.
The supply side is tight. Qualified describers who can work in specific languages or regional dialects are hard to find. If you are trying to produce AD in 10+ languages across multiple territories, lead times get long.
The organisations that handle this well do three things:
- Start AD when the edit is locked, not after final delivery.
- Use one vendor or a managed network rather than sourcing describers ad hoc per territory.
- Build AD into their delivery specs alongside subtitle requirements, so it is scheduled and budgeted from the start.
What Includio does
We deliver SDH and audio description for national broadcasters, distributors, production houses, and enterprises across Europe.
- 400+ professional describers across 42 languages
- 325,000+ minutes of audio description delivered
- Centralised workflow: AD, SDH, sign language, and translations handled in one place
If you are working through EAA platform compliance or national content obligations and need access services at scale, get in touch.
