New Ofcom guidance on subtitling, audio description and signing tools for broadcasters

The question

What areas do broadcasters need to focus on to meet Ofcom’s new requirements around the quality of access services?

The key takeaway

The UK’s broadcast regulator Ofcom has updated its TV access services code (the Code) and best practice guidelines (the Guidelines) to preserve the quality of access services. Access services refer to subtitling, audio description and signing tools used to provide accessible content to TV and on-demand audiences. Broadcasters should be aware of these updated regulatory requirements to ensure their access services meet Ofcom’s statutory targets for accessibility.

The background

Despite a rise in accessible content on screen, Ofcom emphasises its commitment to ensuring access services are suitable. The previous Code by Ofcom already set statutory targets for a proportion of TV content to include access services. However, there are presently no legal requirements for equivalent quotas on on-demand platforms. This is expected to change with the draft Media Bill, as reflected in the latest Ofcom Guidelines.

The updated Code and Guidelines follow a July 2023 consultation between Ofcom and various stakeholders, including ITV and Channel 4, and the Royal National Institutes for Deaf and Blind People. 

The development

The Code clarifies factors meeting Ofcom’s statutory targets for access services, including accuracy and synchronicity, assessed on a case-by-case basis. These targets apply “regardless of the means of delivery” via on-demand platforms.

The regulator has expanded specific guidance for subtitling, audio description and signing, considering different platforms and devices like Smart TVs and mobile phone viewing. In summary:

• subtitling: key changes to subtitling guidance include recommendations for synchronised subtitles, though paraphrasing might be suitable for fast dialogue. Subtitles should be easy to read, clear against the background and able to identify non-speech information. For live broadcasts, there’s a recommended average delay of 4.5 seconds and they should be in the preferred language of the intended audience
• audio description: updates to audio description under the Guidelines acknowledge different approaches for various programme genres, suggesting improvements using audio introductions or extended audio descriptions, particularly for programmes less suited to traditional audio descriptions, such as news or game shows. It should include descriptions of features beyond the plot, such as diversity characteristics
• signing guidance: Ofcom’s signing guidance confirms the use of British or Irish Sign Language, with consistency in signers throughout a series. Providers should consider size and position of the signer, especially for mobile phone viewing. 

Other recommendations in the Guidelines include:

• accommodating viewers with cognitive and neurodevelopmental conditions
• customisation options allowing simultaneous use of multiple access services
• increasing the availability of accessible content and sharing access service files alongside content
• increasing the accessibility of emergency information and national importance moments
• timely provision and easy accessibility of access services for on-demand content
• ensuring compatibility with assistive technologies.

Why is this important?

Broadcasters and TV content providers need to stay updated with these regulatory changes to ensure compliance with statutory requirements and recommendations. With the expansion of regulations to include on-demand services, broadcasters must consider the accessibility of their content for all consumers. While new technologies like AI can aid accessibility and be cost efficient for broadcasters, these technological developments should not impact the quality of access services. 

Any practical tips?

Broadcasters should consider:

• reviewing the updated Code and Guidelines to understand how the access service requirements apply in practice and evaluate whether their current approach meets the standards set by the Code. If not, they should use the Guidelines to identify areas for improvement
• ensuring that accessibility considerations are integrated into content creation and distribution processes for both traditional broadcast and non-demand platforms
• as indicated by Ofcom, they should also be aware of changing regulatory requirements to access services as part of the proposed Media Bill. Adapting to these updates not only ensures legal compliance but also enhances inclusivity and improves the viewing experience for all audiences. 

Summer 2024