Technology
The European Accessibility Act: The Impact to Broadcast and OTT Services
The European Accessibility Act: The Impact to Broadcast and OTT Services
The European Accessibility Act: The Impact to Broadcast and OTT Services
The European Accessibility Act: The Impact to Broadcast and OTT Services
8 min read
|
19 Feb 2025
Legislation is coming….and it's closer than you think
The European Accessibility Act (EAA) is set to transform the way digital and media platforms serve users with disabilities across the European Union (EU). By 28th June 2025, organisations will be required to meet sweeping accessibility requirements aimed at ensuring equitable access to online services, broadcast media, hardware interfaces, and more.
The reason to why this is so impactful to OTT, streaming and digital publishing platforms, is that the EAA is Technology-Neutral Legislation - meaning obligations apply irrespective of delivery method, and that a service streaming content over satellite or over the internet must both remove accessibility barriers.
Broadly speaking, the EAA primarily addresses the functional and interface-level accessibility of products and services (e.g., websites, mobile applications, self-service terminals, e-book readers) rather than the actual audio or video content itself. So, good news for media managers, bad news for product managers.
To understand why, it's helpful to look at three key points:
Functional Accessibility Focus
The EAA sets out functional requirements, for example, making sure a platform or device can be operated with assistive technologies, that websites can be navigated via keyboard, or that a set-top box interface accommodates users with vision or motor impairments.
In other words, the Act is about how users access and interact with a product or service. It might require that a media player’s controls be accessible, but not necessarily mandate how much of the underlying audio or video must be subtitled, for example.
Complementary Legislation
Content accessibility obligations - such as requirements for subtitling, sign language interpretation, or audio description, are usually found in other directives like the Audio-visual Media Services Directive (AVMSD) (for broadcast and on-demand services) or the Web Accessibility Directive (for public-sector websites and apps). These laws deal more directly with ensuring that video and audio materials themselves are accessible.
The EAA, by contrast, is broader, covering everything from banking services to e-readers to e-commerce websites, focusing on the usability and interactivity of those products/services.
Overlap in Practice
Because many EU laws work in tandem, you might still see references to subtitling or audio description in an EAA context if, for example, that is considered part of making a service “functionally accessible.” But in general, the EAA’s real emphasis is on platforms, interfaces, and support materials - it ensures that the service’s “infrastructure” (website, app, device, etc.) does not create barriers for people with disabilities, rather than regulating the content’s creation or editorial requirements.
Functional Goals of the EAA
At its heart, the EAA outlines functional goals
Perceivable: Ensuring content is visible or audible to individuals with visual or hearing impairments, such as providing text alternatives for video or images.
Operable: Allowing for alternative input controls, including keyboard navigation and voice recognition, making set-top boxes and app interfaces usable by those with limited mobility.
Understandable: Maintaining logical, consistent layouts and clear instructions to help a broad user base - including those with cognitive impairments - navigate easily.
Robust: Requiring compatibility with a variety of existing and emerging assistive technologies, such as screen readers, braille displays, and alternative remote controls.
Who Does the EAA Apply to?
Any organisation - located in the EU or elsewhere - that provides covered products or services to EU users must comply. This includes:
Traditional Broadcasters National or regional television networks and satellite or cable broadcasters who deliver content to EU households.
OTT and Digital-First Media Providers Subscription-based or ad-supported streaming services, video-on-demand portals, and other internet-distributed content platforms that reach EU audiences.
Local transposition laws vary, but the principle remains consistent: if you market broadcast or OTT services within the EU, you are subject to the EAA’s accessibility requirements.
Key Milestones and Enforcement Framework
Legislative Timeline
28 June 2019: Directive (EU) 2019/882 (the EAA) is adopted.
By 28 June 2022: EU Member States transpose the directive into national laws, defining local enforcement bodies and penalties.
From 28 June 2025: Accessibility obligations become mandatory. New or substantially updated broadcast and OTT services must meet the EAA’s accessibility requirements or risk enforcement actions.
National Enforcement
Each Member State designates one or more authorities to conduct market surveillance, handle complaints, and levy sanctions. While specific fines or remedies differ among countries, the EAA stipulates that measures be “effective, proportionate, and dissuasive.” Broadcasters and OTT providers may be subject to:
Monetary Penalties: Varying scales of fines for non-compliance.
Service Withdrawal: Temporary or permanent suspension of a channel, streaming service, or specific application if non-compliance is severe.
Liability or Damages: Risk of legal claims from consumers or disability advocacy organisations.
What Global Standards Should Digital Services Benchmark Against?
Web Content Accessibility Guidelines (WCAG)
Who Develops It:
The World Wide Web Consortium (W3C), under its Web Accessibility Initiative (WAI).
Scope and Use:
Primarily defines how websites and web-based applications should handle text, images, forms, and other interactive content to accommodate users with various disabilities (visual, hearing, cognitive, mobility, etc.).
References testable success criteria (e.g., use of alt text for images, correct heading structure, keyboard navigability).
Commonly adopted across government websites in many countries and forms the foundation for most other accessibility regulations worldwide.
Current Versions:
WCAG 2.1 (published June 2018) is widely referenced.
WCAG 2.2 is in progress, adding new success criteria around target sizing, visual indicators, etc.
WCAG 3.0 (codenamed “Silver”) is an upcoming overhaul intended to support emerging technologies and contexts.
EN 301 549 (Europe)
Who Develops It:
Joint collaboration of CEN, CENELEC, and ETSI (European standardisation organisations), often referencing the W3C’s WCAG.
Scope and Use:
Intended as a European-wide ICT accessibility standard, covering not just web content but also software, mobile apps, hardware, telecommunications, and digital documents.
Heavily referenced in EU legislation, including the European Accessibility Act (EAA) and the Web Accessibility Directive for public-sector websites and apps.
Defines technical requirements and test procedures for a wide range of digital products and services.
Section 508 Standards (United States)
Who Develops It:
The U.S. Access Board, referencing WCAG for web-based content.
Scope and Use:
Requires federal agencies (and organisations receiving federal funding) to ensure electronic and information technology is accessible to people with disabilities.
Substantially aligned with WCAG 2.0 in its “Refresh” (effective since 2018), merging U.S. federal requirements with globally recognised guidelines.
ISO Standards and Other International Frameworks
Officially recognises WCAG 2.0 as an international standard through the ISO system, reinforcing its global relevance.
Focuses on accessibility APIs and how software can interact with assistive technologies.
ISO/IEC 9241-210 Series:
Deals with ergonomics of human-system interaction, which includes accessibility aspects for user interfaces.
Country-Specific Adaptations
In addition to the major global standards above, many countries or regions have developed localised adaptations that embed WCAG or related principles into their laws or regulations. Examples include:
RGAA (France): Référentiel Général d'Amélioration de l'Accessibilité, closely aligned with WCAG.
BITV (Germany): Barrierefreie Informationstechnik-Verordnung, implementing EU directives in local context.
AODA (Ontario, Canada): Accessibility for Ontarians with Disabilities Act, referencing WCAG for websites.
The “Presumption of Conformity” Get Out of Jail Free Card?
Under the EAA, the presumption of conformity applies when an organisation follows an officially designated harmonised standard (e.g., EN 301 549).
Harmonised standards translate legal requirements into detailed technical specifications. For broadcast and OTT providers, EN 301 549 offers a clear roadmap for designing user interfaces and controlling the accessibility of online video platforms. By following this standard, organisations can streamline their approach rather than attempt to piece together separate guidelines for hardware, web design, and app interfaces.
If a service or device fully complies with a harmonised standard cited in the Official Journal of the EU (such as EN 301 549), you earn a presumption of conformity - a significant advantage when demonstrating EAA compliance. However, regulators may still conduct spot checks and investigate user complaints to confirm genuine alignment. Falsely claiming adherence or applying standards only partially can lead to substantial fines or service suspensions.
Practical Recommendations for Broadcast and OTT Compliance
1. Conduct an Accessibility Audit
Start by reviewing your current offerings, websites, mobile apps, video libraries, and assess where you stand against accessibility standards like WCAG and EN 301 549. Identify gaps in user interface design, captioning or subtitling processes, and compatibility with assistive technologies.
2. Embed Accessibility in Product Development
Include accessibility best practices from the ground up. For instance, build navigable interfaces that can be operated without a mouse, ensure video content includes closed captions and audio descriptions, and provide text alternatives for images and infographics.
3. Adopt Harmonised Standards Early
Aligning with EN 301 549 helps clarify and unify your team’s efforts across different platforms - web, mobile, smart TV apps, EPGs, and more. By adhering to a recognised standard, you significantly reduce compliance guesswork and strengthen your legal position.
4. Policy, Training, and Continuous Improvement
Create an internal policy framework that mandates accessibility reviews at each stage of product development. Offer staff training on how to design, code, and test accessible digital solutions. Keep abreast of evolving standards and be prepared for updates the European Commission may adopt as harmonised standards.
5. Engage End-Users
Since each Member State enforces the EAA with its own specifics, early engagement with local regulators or accessibility consultancies can help clarify any grey areas. Consulting with end-users or disability advocacy groups can also provide practical feedback on real-world accessibility barriers.
Legislation is coming….and it's closer than you think
The European Accessibility Act (EAA) is set to transform the way digital and media platforms serve users with disabilities across the European Union (EU). By 28th June 2025, organisations will be required to meet sweeping accessibility requirements aimed at ensuring equitable access to online services, broadcast media, hardware interfaces, and more.
The reason to why this is so impactful to OTT, streaming and digital publishing platforms, is that the EAA is Technology-Neutral Legislation - meaning obligations apply irrespective of delivery method, and that a service streaming content over satellite or over the internet must both remove accessibility barriers.
Broadly speaking, the EAA primarily addresses the functional and interface-level accessibility of products and services (e.g., websites, mobile applications, self-service terminals, e-book readers) rather than the actual audio or video content itself. So, good news for media managers, bad news for product managers.
To understand why, it's helpful to look at three key points:
Functional Accessibility Focus
The EAA sets out functional requirements, for example, making sure a platform or device can be operated with assistive technologies, that websites can be navigated via keyboard, or that a set-top box interface accommodates users with vision or motor impairments.
In other words, the Act is about how users access and interact with a product or service. It might require that a media player’s controls be accessible, but not necessarily mandate how much of the underlying audio or video must be subtitled, for example.
Complementary Legislation
Content accessibility obligations - such as requirements for subtitling, sign language interpretation, or audio description, are usually found in other directives like the Audio-visual Media Services Directive (AVMSD) (for broadcast and on-demand services) or the Web Accessibility Directive (for public-sector websites and apps). These laws deal more directly with ensuring that video and audio materials themselves are accessible.
The EAA, by contrast, is broader, covering everything from banking services to e-readers to e-commerce websites, focusing on the usability and interactivity of those products/services.
Overlap in Practice
Because many EU laws work in tandem, you might still see references to subtitling or audio description in an EAA context if, for example, that is considered part of making a service “functionally accessible.” But in general, the EAA’s real emphasis is on platforms, interfaces, and support materials - it ensures that the service’s “infrastructure” (website, app, device, etc.) does not create barriers for people with disabilities, rather than regulating the content’s creation or editorial requirements.
Functional Goals of the EAA
At its heart, the EAA outlines functional goals
Perceivable: Ensuring content is visible or audible to individuals with visual or hearing impairments, such as providing text alternatives for video or images.
Operable: Allowing for alternative input controls, including keyboard navigation and voice recognition, making set-top boxes and app interfaces usable by those with limited mobility.
Understandable: Maintaining logical, consistent layouts and clear instructions to help a broad user base - including those with cognitive impairments - navigate easily.
Robust: Requiring compatibility with a variety of existing and emerging assistive technologies, such as screen readers, braille displays, and alternative remote controls.
Who Does the EAA Apply to?
Any organisation - located in the EU or elsewhere - that provides covered products or services to EU users must comply. This includes:
Traditional Broadcasters National or regional television networks and satellite or cable broadcasters who deliver content to EU households.
OTT and Digital-First Media Providers Subscription-based or ad-supported streaming services, video-on-demand portals, and other internet-distributed content platforms that reach EU audiences.
Local transposition laws vary, but the principle remains consistent: if you market broadcast or OTT services within the EU, you are subject to the EAA’s accessibility requirements.
Key Milestones and Enforcement Framework
Legislative Timeline
28 June 2019: Directive (EU) 2019/882 (the EAA) is adopted.
By 28 June 2022: EU Member States transpose the directive into national laws, defining local enforcement bodies and penalties.
From 28 June 2025: Accessibility obligations become mandatory. New or substantially updated broadcast and OTT services must meet the EAA’s accessibility requirements or risk enforcement actions.
National Enforcement
Each Member State designates one or more authorities to conduct market surveillance, handle complaints, and levy sanctions. While specific fines or remedies differ among countries, the EAA stipulates that measures be “effective, proportionate, and dissuasive.” Broadcasters and OTT providers may be subject to:
Monetary Penalties: Varying scales of fines for non-compliance.
Service Withdrawal: Temporary or permanent suspension of a channel, streaming service, or specific application if non-compliance is severe.
Liability or Damages: Risk of legal claims from consumers or disability advocacy organisations.
What Global Standards Should Digital Services Benchmark Against?
Web Content Accessibility Guidelines (WCAG)
Who Develops It:
The World Wide Web Consortium (W3C), under its Web Accessibility Initiative (WAI).
Scope and Use:
Primarily defines how websites and web-based applications should handle text, images, forms, and other interactive content to accommodate users with various disabilities (visual, hearing, cognitive, mobility, etc.).
References testable success criteria (e.g., use of alt text for images, correct heading structure, keyboard navigability).
Commonly adopted across government websites in many countries and forms the foundation for most other accessibility regulations worldwide.
Current Versions:
WCAG 2.1 (published June 2018) is widely referenced.
WCAG 2.2 is in progress, adding new success criteria around target sizing, visual indicators, etc.
WCAG 3.0 (codenamed “Silver”) is an upcoming overhaul intended to support emerging technologies and contexts.
EN 301 549 (Europe)
Who Develops It:
Joint collaboration of CEN, CENELEC, and ETSI (European standardisation organisations), often referencing the W3C’s WCAG.
Scope and Use:
Intended as a European-wide ICT accessibility standard, covering not just web content but also software, mobile apps, hardware, telecommunications, and digital documents.
Heavily referenced in EU legislation, including the European Accessibility Act (EAA) and the Web Accessibility Directive for public-sector websites and apps.
Defines technical requirements and test procedures for a wide range of digital products and services.
Section 508 Standards (United States)
Who Develops It:
The U.S. Access Board, referencing WCAG for web-based content.
Scope and Use:
Requires federal agencies (and organisations receiving federal funding) to ensure electronic and information technology is accessible to people with disabilities.
Substantially aligned with WCAG 2.0 in its “Refresh” (effective since 2018), merging U.S. federal requirements with globally recognised guidelines.
ISO Standards and Other International Frameworks
Officially recognises WCAG 2.0 as an international standard through the ISO system, reinforcing its global relevance.
Focuses on accessibility APIs and how software can interact with assistive technologies.
ISO/IEC 9241-210 Series:
Deals with ergonomics of human-system interaction, which includes accessibility aspects for user interfaces.
Country-Specific Adaptations
In addition to the major global standards above, many countries or regions have developed localised adaptations that embed WCAG or related principles into their laws or regulations. Examples include:
RGAA (France): Référentiel Général d'Amélioration de l'Accessibilité, closely aligned with WCAG.
BITV (Germany): Barrierefreie Informationstechnik-Verordnung, implementing EU directives in local context.
AODA (Ontario, Canada): Accessibility for Ontarians with Disabilities Act, referencing WCAG for websites.
The “Presumption of Conformity” Get Out of Jail Free Card?
Under the EAA, the presumption of conformity applies when an organisation follows an officially designated harmonised standard (e.g., EN 301 549).
Harmonised standards translate legal requirements into detailed technical specifications. For broadcast and OTT providers, EN 301 549 offers a clear roadmap for designing user interfaces and controlling the accessibility of online video platforms. By following this standard, organisations can streamline their approach rather than attempt to piece together separate guidelines for hardware, web design, and app interfaces.
If a service or device fully complies with a harmonised standard cited in the Official Journal of the EU (such as EN 301 549), you earn a presumption of conformity - a significant advantage when demonstrating EAA compliance. However, regulators may still conduct spot checks and investigate user complaints to confirm genuine alignment. Falsely claiming adherence or applying standards only partially can lead to substantial fines or service suspensions.
Practical Recommendations for Broadcast and OTT Compliance
1. Conduct an Accessibility Audit
Start by reviewing your current offerings, websites, mobile apps, video libraries, and assess where you stand against accessibility standards like WCAG and EN 301 549. Identify gaps in user interface design, captioning or subtitling processes, and compatibility with assistive technologies.
2. Embed Accessibility in Product Development
Include accessibility best practices from the ground up. For instance, build navigable interfaces that can be operated without a mouse, ensure video content includes closed captions and audio descriptions, and provide text alternatives for images and infographics.
3. Adopt Harmonised Standards Early
Aligning with EN 301 549 helps clarify and unify your team’s efforts across different platforms - web, mobile, smart TV apps, EPGs, and more. By adhering to a recognised standard, you significantly reduce compliance guesswork and strengthen your legal position.
4. Policy, Training, and Continuous Improvement
Create an internal policy framework that mandates accessibility reviews at each stage of product development. Offer staff training on how to design, code, and test accessible digital solutions. Keep abreast of evolving standards and be prepared for updates the European Commission may adopt as harmonised standards.
5. Engage End-Users
Since each Member State enforces the EAA with its own specifics, early engagement with local regulators or accessibility consultancies can help clarify any grey areas. Consulting with end-users or disability advocacy groups can also provide practical feedback on real-world accessibility barriers.
Legislation is coming….and it's closer than you think
The European Accessibility Act (EAA) is set to transform the way digital and media platforms serve users with disabilities across the European Union (EU). By 28th June 2025, organisations will be required to meet sweeping accessibility requirements aimed at ensuring equitable access to online services, broadcast media, hardware interfaces, and more.
The reason to why this is so impactful to OTT, streaming and digital publishing platforms, is that the EAA is Technology-Neutral Legislation - meaning obligations apply irrespective of delivery method, and that a service streaming content over satellite or over the internet must both remove accessibility barriers.
Broadly speaking, the EAA primarily addresses the functional and interface-level accessibility of products and services (e.g., websites, mobile applications, self-service terminals, e-book readers) rather than the actual audio or video content itself. So, good news for media managers, bad news for product managers.
To understand why, it's helpful to look at three key points:
Functional Accessibility Focus
The EAA sets out functional requirements, for example, making sure a platform or device can be operated with assistive technologies, that websites can be navigated via keyboard, or that a set-top box interface accommodates users with vision or motor impairments.
In other words, the Act is about how users access and interact with a product or service. It might require that a media player’s controls be accessible, but not necessarily mandate how much of the underlying audio or video must be subtitled, for example.
Complementary Legislation
Content accessibility obligations - such as requirements for subtitling, sign language interpretation, or audio description, are usually found in other directives like the Audio-visual Media Services Directive (AVMSD) (for broadcast and on-demand services) or the Web Accessibility Directive (for public-sector websites and apps). These laws deal more directly with ensuring that video and audio materials themselves are accessible.
The EAA, by contrast, is broader, covering everything from banking services to e-readers to e-commerce websites, focusing on the usability and interactivity of those products/services.
Overlap in Practice
Because many EU laws work in tandem, you might still see references to subtitling or audio description in an EAA context if, for example, that is considered part of making a service “functionally accessible.” But in general, the EAA’s real emphasis is on platforms, interfaces, and support materials - it ensures that the service’s “infrastructure” (website, app, device, etc.) does not create barriers for people with disabilities, rather than regulating the content’s creation or editorial requirements.
Functional Goals of the EAA
At its heart, the EAA outlines functional goals
Perceivable: Ensuring content is visible or audible to individuals with visual or hearing impairments, such as providing text alternatives for video or images.
Operable: Allowing for alternative input controls, including keyboard navigation and voice recognition, making set-top boxes and app interfaces usable by those with limited mobility.
Understandable: Maintaining logical, consistent layouts and clear instructions to help a broad user base - including those with cognitive impairments - navigate easily.
Robust: Requiring compatibility with a variety of existing and emerging assistive technologies, such as screen readers, braille displays, and alternative remote controls.
Who Does the EAA Apply to?
Any organisation - located in the EU or elsewhere - that provides covered products or services to EU users must comply. This includes:
Traditional Broadcasters National or regional television networks and satellite or cable broadcasters who deliver content to EU households.
OTT and Digital-First Media Providers Subscription-based or ad-supported streaming services, video-on-demand portals, and other internet-distributed content platforms that reach EU audiences.
Local transposition laws vary, but the principle remains consistent: if you market broadcast or OTT services within the EU, you are subject to the EAA’s accessibility requirements.
Key Milestones and Enforcement Framework
Legislative Timeline
28 June 2019: Directive (EU) 2019/882 (the EAA) is adopted.
By 28 June 2022: EU Member States transpose the directive into national laws, defining local enforcement bodies and penalties.
From 28 June 2025: Accessibility obligations become mandatory. New or substantially updated broadcast and OTT services must meet the EAA’s accessibility requirements or risk enforcement actions.
National Enforcement
Each Member State designates one or more authorities to conduct market surveillance, handle complaints, and levy sanctions. While specific fines or remedies differ among countries, the EAA stipulates that measures be “effective, proportionate, and dissuasive.” Broadcasters and OTT providers may be subject to:
Monetary Penalties: Varying scales of fines for non-compliance.
Service Withdrawal: Temporary or permanent suspension of a channel, streaming service, or specific application if non-compliance is severe.
Liability or Damages: Risk of legal claims from consumers or disability advocacy organisations.
What Global Standards Should Digital Services Benchmark Against?
Web Content Accessibility Guidelines (WCAG)
Who Develops It:
The World Wide Web Consortium (W3C), under its Web Accessibility Initiative (WAI).
Scope and Use:
Primarily defines how websites and web-based applications should handle text, images, forms, and other interactive content to accommodate users with various disabilities (visual, hearing, cognitive, mobility, etc.).
References testable success criteria (e.g., use of alt text for images, correct heading structure, keyboard navigability).
Commonly adopted across government websites in many countries and forms the foundation for most other accessibility regulations worldwide.
Current Versions:
WCAG 2.1 (published June 2018) is widely referenced.
WCAG 2.2 is in progress, adding new success criteria around target sizing, visual indicators, etc.
WCAG 3.0 (codenamed “Silver”) is an upcoming overhaul intended to support emerging technologies and contexts.
EN 301 549 (Europe)
Who Develops It:
Joint collaboration of CEN, CENELEC, and ETSI (European standardisation organisations), often referencing the W3C’s WCAG.
Scope and Use:
Intended as a European-wide ICT accessibility standard, covering not just web content but also software, mobile apps, hardware, telecommunications, and digital documents.
Heavily referenced in EU legislation, including the European Accessibility Act (EAA) and the Web Accessibility Directive for public-sector websites and apps.
Defines technical requirements and test procedures for a wide range of digital products and services.
Section 508 Standards (United States)
Who Develops It:
The U.S. Access Board, referencing WCAG for web-based content.
Scope and Use:
Requires federal agencies (and organisations receiving federal funding) to ensure electronic and information technology is accessible to people with disabilities.
Substantially aligned with WCAG 2.0 in its “Refresh” (effective since 2018), merging U.S. federal requirements with globally recognised guidelines.
ISO Standards and Other International Frameworks
Officially recognises WCAG 2.0 as an international standard through the ISO system, reinforcing its global relevance.
Focuses on accessibility APIs and how software can interact with assistive technologies.
ISO/IEC 9241-210 Series:
Deals with ergonomics of human-system interaction, which includes accessibility aspects for user interfaces.
Country-Specific Adaptations
In addition to the major global standards above, many countries or regions have developed localised adaptations that embed WCAG or related principles into their laws or regulations. Examples include:
RGAA (France): Référentiel Général d'Amélioration de l'Accessibilité, closely aligned with WCAG.
BITV (Germany): Barrierefreie Informationstechnik-Verordnung, implementing EU directives in local context.
AODA (Ontario, Canada): Accessibility for Ontarians with Disabilities Act, referencing WCAG for websites.
The “Presumption of Conformity” Get Out of Jail Free Card?
Under the EAA, the presumption of conformity applies when an organisation follows an officially designated harmonised standard (e.g., EN 301 549).
Harmonised standards translate legal requirements into detailed technical specifications. For broadcast and OTT providers, EN 301 549 offers a clear roadmap for designing user interfaces and controlling the accessibility of online video platforms. By following this standard, organisations can streamline their approach rather than attempt to piece together separate guidelines for hardware, web design, and app interfaces.
If a service or device fully complies with a harmonised standard cited in the Official Journal of the EU (such as EN 301 549), you earn a presumption of conformity - a significant advantage when demonstrating EAA compliance. However, regulators may still conduct spot checks and investigate user complaints to confirm genuine alignment. Falsely claiming adherence or applying standards only partially can lead to substantial fines or service suspensions.
Practical Recommendations for Broadcast and OTT Compliance
1. Conduct an Accessibility Audit
Start by reviewing your current offerings, websites, mobile apps, video libraries, and assess where you stand against accessibility standards like WCAG and EN 301 549. Identify gaps in user interface design, captioning or subtitling processes, and compatibility with assistive technologies.
2. Embed Accessibility in Product Development
Include accessibility best practices from the ground up. For instance, build navigable interfaces that can be operated without a mouse, ensure video content includes closed captions and audio descriptions, and provide text alternatives for images and infographics.
3. Adopt Harmonised Standards Early
Aligning with EN 301 549 helps clarify and unify your team’s efforts across different platforms - web, mobile, smart TV apps, EPGs, and more. By adhering to a recognised standard, you significantly reduce compliance guesswork and strengthen your legal position.
4. Policy, Training, and Continuous Improvement
Create an internal policy framework that mandates accessibility reviews at each stage of product development. Offer staff training on how to design, code, and test accessible digital solutions. Keep abreast of evolving standards and be prepared for updates the European Commission may adopt as harmonised standards.
5. Engage End-Users
Since each Member State enforces the EAA with its own specifics, early engagement with local regulators or accessibility consultancies can help clarify any grey areas. Consulting with end-users or disability advocacy groups can also provide practical feedback on real-world accessibility barriers.
Legislation is coming….and it's closer than you think
The European Accessibility Act (EAA) is set to transform the way digital and media platforms serve users with disabilities across the European Union (EU). By 28th June 2025, organisations will be required to meet sweeping accessibility requirements aimed at ensuring equitable access to online services, broadcast media, hardware interfaces, and more.
The reason to why this is so impactful to OTT, streaming and digital publishing platforms, is that the EAA is Technology-Neutral Legislation - meaning obligations apply irrespective of delivery method, and that a service streaming content over satellite or over the internet must both remove accessibility barriers.
Broadly speaking, the EAA primarily addresses the functional and interface-level accessibility of products and services (e.g., websites, mobile applications, self-service terminals, e-book readers) rather than the actual audio or video content itself. So, good news for media managers, bad news for product managers.
To understand why, it's helpful to look at three key points:
Functional Accessibility Focus
The EAA sets out functional requirements, for example, making sure a platform or device can be operated with assistive technologies, that websites can be navigated via keyboard, or that a set-top box interface accommodates users with vision or motor impairments.
In other words, the Act is about how users access and interact with a product or service. It might require that a media player’s controls be accessible, but not necessarily mandate how much of the underlying audio or video must be subtitled, for example.
Complementary Legislation
Content accessibility obligations - such as requirements for subtitling, sign language interpretation, or audio description, are usually found in other directives like the Audio-visual Media Services Directive (AVMSD) (for broadcast and on-demand services) or the Web Accessibility Directive (for public-sector websites and apps). These laws deal more directly with ensuring that video and audio materials themselves are accessible.
The EAA, by contrast, is broader, covering everything from banking services to e-readers to e-commerce websites, focusing on the usability and interactivity of those products/services.
Overlap in Practice
Because many EU laws work in tandem, you might still see references to subtitling or audio description in an EAA context if, for example, that is considered part of making a service “functionally accessible.” But in general, the EAA’s real emphasis is on platforms, interfaces, and support materials - it ensures that the service’s “infrastructure” (website, app, device, etc.) does not create barriers for people with disabilities, rather than regulating the content’s creation or editorial requirements.
Functional Goals of the EAA
At its heart, the EAA outlines functional goals
Perceivable: Ensuring content is visible or audible to individuals with visual or hearing impairments, such as providing text alternatives for video or images.
Operable: Allowing for alternative input controls, including keyboard navigation and voice recognition, making set-top boxes and app interfaces usable by those with limited mobility.
Understandable: Maintaining logical, consistent layouts and clear instructions to help a broad user base - including those with cognitive impairments - navigate easily.
Robust: Requiring compatibility with a variety of existing and emerging assistive technologies, such as screen readers, braille displays, and alternative remote controls.
Who Does the EAA Apply to?
Any organisation - located in the EU or elsewhere - that provides covered products or services to EU users must comply. This includes:
Traditional Broadcasters National or regional television networks and satellite or cable broadcasters who deliver content to EU households.
OTT and Digital-First Media Providers Subscription-based or ad-supported streaming services, video-on-demand portals, and other internet-distributed content platforms that reach EU audiences.
Local transposition laws vary, but the principle remains consistent: if you market broadcast or OTT services within the EU, you are subject to the EAA’s accessibility requirements.
Key Milestones and Enforcement Framework
Legislative Timeline
28 June 2019: Directive (EU) 2019/882 (the EAA) is adopted.
By 28 June 2022: EU Member States transpose the directive into national laws, defining local enforcement bodies and penalties.
From 28 June 2025: Accessibility obligations become mandatory. New or substantially updated broadcast and OTT services must meet the EAA’s accessibility requirements or risk enforcement actions.
National Enforcement
Each Member State designates one or more authorities to conduct market surveillance, handle complaints, and levy sanctions. While specific fines or remedies differ among countries, the EAA stipulates that measures be “effective, proportionate, and dissuasive.” Broadcasters and OTT providers may be subject to:
Monetary Penalties: Varying scales of fines for non-compliance.
Service Withdrawal: Temporary or permanent suspension of a channel, streaming service, or specific application if non-compliance is severe.
Liability or Damages: Risk of legal claims from consumers or disability advocacy organisations.
What Global Standards Should Digital Services Benchmark Against?
Web Content Accessibility Guidelines (WCAG)
Who Develops It:
The World Wide Web Consortium (W3C), under its Web Accessibility Initiative (WAI).
Scope and Use:
Primarily defines how websites and web-based applications should handle text, images, forms, and other interactive content to accommodate users with various disabilities (visual, hearing, cognitive, mobility, etc.).
References testable success criteria (e.g., use of alt text for images, correct heading structure, keyboard navigability).
Commonly adopted across government websites in many countries and forms the foundation for most other accessibility regulations worldwide.
Current Versions:
WCAG 2.1 (published June 2018) is widely referenced.
WCAG 2.2 is in progress, adding new success criteria around target sizing, visual indicators, etc.
WCAG 3.0 (codenamed “Silver”) is an upcoming overhaul intended to support emerging technologies and contexts.
EN 301 549 (Europe)
Who Develops It:
Joint collaboration of CEN, CENELEC, and ETSI (European standardisation organisations), often referencing the W3C’s WCAG.
Scope and Use:
Intended as a European-wide ICT accessibility standard, covering not just web content but also software, mobile apps, hardware, telecommunications, and digital documents.
Heavily referenced in EU legislation, including the European Accessibility Act (EAA) and the Web Accessibility Directive for public-sector websites and apps.
Defines technical requirements and test procedures for a wide range of digital products and services.
Section 508 Standards (United States)
Who Develops It:
The U.S. Access Board, referencing WCAG for web-based content.
Scope and Use:
Requires federal agencies (and organisations receiving federal funding) to ensure electronic and information technology is accessible to people with disabilities.
Substantially aligned with WCAG 2.0 in its “Refresh” (effective since 2018), merging U.S. federal requirements with globally recognised guidelines.
ISO Standards and Other International Frameworks
Officially recognises WCAG 2.0 as an international standard through the ISO system, reinforcing its global relevance.
Focuses on accessibility APIs and how software can interact with assistive technologies.
ISO/IEC 9241-210 Series:
Deals with ergonomics of human-system interaction, which includes accessibility aspects for user interfaces.
Country-Specific Adaptations
In addition to the major global standards above, many countries or regions have developed localised adaptations that embed WCAG or related principles into their laws or regulations. Examples include:
RGAA (France): Référentiel Général d'Amélioration de l'Accessibilité, closely aligned with WCAG.
BITV (Germany): Barrierefreie Informationstechnik-Verordnung, implementing EU directives in local context.
AODA (Ontario, Canada): Accessibility for Ontarians with Disabilities Act, referencing WCAG for websites.
The “Presumption of Conformity” Get Out of Jail Free Card?
Under the EAA, the presumption of conformity applies when an organisation follows an officially designated harmonised standard (e.g., EN 301 549).
Harmonised standards translate legal requirements into detailed technical specifications. For broadcast and OTT providers, EN 301 549 offers a clear roadmap for designing user interfaces and controlling the accessibility of online video platforms. By following this standard, organisations can streamline their approach rather than attempt to piece together separate guidelines for hardware, web design, and app interfaces.
If a service or device fully complies with a harmonised standard cited in the Official Journal of the EU (such as EN 301 549), you earn a presumption of conformity - a significant advantage when demonstrating EAA compliance. However, regulators may still conduct spot checks and investigate user complaints to confirm genuine alignment. Falsely claiming adherence or applying standards only partially can lead to substantial fines or service suspensions.
Practical Recommendations for Broadcast and OTT Compliance
1. Conduct an Accessibility Audit
Start by reviewing your current offerings, websites, mobile apps, video libraries, and assess where you stand against accessibility standards like WCAG and EN 301 549. Identify gaps in user interface design, captioning or subtitling processes, and compatibility with assistive technologies.
2. Embed Accessibility in Product Development
Include accessibility best practices from the ground up. For instance, build navigable interfaces that can be operated without a mouse, ensure video content includes closed captions and audio descriptions, and provide text alternatives for images and infographics.
3. Adopt Harmonised Standards Early
Aligning with EN 301 549 helps clarify and unify your team’s efforts across different platforms - web, mobile, smart TV apps, EPGs, and more. By adhering to a recognised standard, you significantly reduce compliance guesswork and strengthen your legal position.
4. Policy, Training, and Continuous Improvement
Create an internal policy framework that mandates accessibility reviews at each stage of product development. Offer staff training on how to design, code, and test accessible digital solutions. Keep abreast of evolving standards and be prepared for updates the European Commission may adopt as harmonised standards.
5. Engage End-Users
Since each Member State enforces the EAA with its own specifics, early engagement with local regulators or accessibility consultancies can help clarify any grey areas. Consulting with end-users or disability advocacy groups can also provide practical feedback on real-world accessibility barriers.
Legislation is coming….and it's closer than you think
The European Accessibility Act (EAA) is set to transform the way digital and media platforms serve users with disabilities across the European Union (EU). By 28th June 2025, organisations will be required to meet sweeping accessibility requirements aimed at ensuring equitable access to online services, broadcast media, hardware interfaces, and more.
The reason to why this is so impactful to OTT, streaming and digital publishing platforms, is that the EAA is Technology-Neutral Legislation - meaning obligations apply irrespective of delivery method, and that a service streaming content over satellite or over the internet must both remove accessibility barriers.
Broadly speaking, the EAA primarily addresses the functional and interface-level accessibility of products and services (e.g., websites, mobile applications, self-service terminals, e-book readers) rather than the actual audio or video content itself. So, good news for media managers, bad news for product managers.
To understand why, it's helpful to look at three key points:
Functional Accessibility Focus
The EAA sets out functional requirements, for example, making sure a platform or device can be operated with assistive technologies, that websites can be navigated via keyboard, or that a set-top box interface accommodates users with vision or motor impairments.
In other words, the Act is about how users access and interact with a product or service. It might require that a media player’s controls be accessible, but not necessarily mandate how much of the underlying audio or video must be subtitled, for example.
Complementary Legislation
Content accessibility obligations - such as requirements for subtitling, sign language interpretation, or audio description, are usually found in other directives like the Audio-visual Media Services Directive (AVMSD) (for broadcast and on-demand services) or the Web Accessibility Directive (for public-sector websites and apps). These laws deal more directly with ensuring that video and audio materials themselves are accessible.
The EAA, by contrast, is broader, covering everything from banking services to e-readers to e-commerce websites, focusing on the usability and interactivity of those products/services.
Overlap in Practice
Because many EU laws work in tandem, you might still see references to subtitling or audio description in an EAA context if, for example, that is considered part of making a service “functionally accessible.” But in general, the EAA’s real emphasis is on platforms, interfaces, and support materials - it ensures that the service’s “infrastructure” (website, app, device, etc.) does not create barriers for people with disabilities, rather than regulating the content’s creation or editorial requirements.
Functional Goals of the EAA
At its heart, the EAA outlines functional goals
Perceivable: Ensuring content is visible or audible to individuals with visual or hearing impairments, such as providing text alternatives for video or images.
Operable: Allowing for alternative input controls, including keyboard navigation and voice recognition, making set-top boxes and app interfaces usable by those with limited mobility.
Understandable: Maintaining logical, consistent layouts and clear instructions to help a broad user base - including those with cognitive impairments - navigate easily.
Robust: Requiring compatibility with a variety of existing and emerging assistive technologies, such as screen readers, braille displays, and alternative remote controls.
Who Does the EAA Apply to?
Any organisation - located in the EU or elsewhere - that provides covered products or services to EU users must comply. This includes:
Traditional Broadcasters National or regional television networks and satellite or cable broadcasters who deliver content to EU households.
OTT and Digital-First Media Providers Subscription-based or ad-supported streaming services, video-on-demand portals, and other internet-distributed content platforms that reach EU audiences.
Local transposition laws vary, but the principle remains consistent: if you market broadcast or OTT services within the EU, you are subject to the EAA’s accessibility requirements.
Key Milestones and Enforcement Framework
Legislative Timeline
28 June 2019: Directive (EU) 2019/882 (the EAA) is adopted.
By 28 June 2022: EU Member States transpose the directive into national laws, defining local enforcement bodies and penalties.
From 28 June 2025: Accessibility obligations become mandatory. New or substantially updated broadcast and OTT services must meet the EAA’s accessibility requirements or risk enforcement actions.
National Enforcement
Each Member State designates one or more authorities to conduct market surveillance, handle complaints, and levy sanctions. While specific fines or remedies differ among countries, the EAA stipulates that measures be “effective, proportionate, and dissuasive.” Broadcasters and OTT providers may be subject to:
Monetary Penalties: Varying scales of fines for non-compliance.
Service Withdrawal: Temporary or permanent suspension of a channel, streaming service, or specific application if non-compliance is severe.
Liability or Damages: Risk of legal claims from consumers or disability advocacy organisations.
What Global Standards Should Digital Services Benchmark Against?
Web Content Accessibility Guidelines (WCAG)
Who Develops It:
The World Wide Web Consortium (W3C), under its Web Accessibility Initiative (WAI).
Scope and Use:
Primarily defines how websites and web-based applications should handle text, images, forms, and other interactive content to accommodate users with various disabilities (visual, hearing, cognitive, mobility, etc.).
References testable success criteria (e.g., use of alt text for images, correct heading structure, keyboard navigability).
Commonly adopted across government websites in many countries and forms the foundation for most other accessibility regulations worldwide.
Current Versions:
WCAG 2.1 (published June 2018) is widely referenced.
WCAG 2.2 is in progress, adding new success criteria around target sizing, visual indicators, etc.
WCAG 3.0 (codenamed “Silver”) is an upcoming overhaul intended to support emerging technologies and contexts.
EN 301 549 (Europe)
Who Develops It:
Joint collaboration of CEN, CENELEC, and ETSI (European standardisation organisations), often referencing the W3C’s WCAG.
Scope and Use:
Intended as a European-wide ICT accessibility standard, covering not just web content but also software, mobile apps, hardware, telecommunications, and digital documents.
Heavily referenced in EU legislation, including the European Accessibility Act (EAA) and the Web Accessibility Directive for public-sector websites and apps.
Defines technical requirements and test procedures for a wide range of digital products and services.
Section 508 Standards (United States)
Who Develops It:
The U.S. Access Board, referencing WCAG for web-based content.
Scope and Use:
Requires federal agencies (and organisations receiving federal funding) to ensure electronic and information technology is accessible to people with disabilities.
Substantially aligned with WCAG 2.0 in its “Refresh” (effective since 2018), merging U.S. federal requirements with globally recognised guidelines.
ISO Standards and Other International Frameworks
Officially recognises WCAG 2.0 as an international standard through the ISO system, reinforcing its global relevance.
Focuses on accessibility APIs and how software can interact with assistive technologies.
ISO/IEC 9241-210 Series:
Deals with ergonomics of human-system interaction, which includes accessibility aspects for user interfaces.
Country-Specific Adaptations
In addition to the major global standards above, many countries or regions have developed localised adaptations that embed WCAG or related principles into their laws or regulations. Examples include:
RGAA (France): Référentiel Général d'Amélioration de l'Accessibilité, closely aligned with WCAG.
BITV (Germany): Barrierefreie Informationstechnik-Verordnung, implementing EU directives in local context.
AODA (Ontario, Canada): Accessibility for Ontarians with Disabilities Act, referencing WCAG for websites.
The “Presumption of Conformity” Get Out of Jail Free Card?
Under the EAA, the presumption of conformity applies when an organisation follows an officially designated harmonised standard (e.g., EN 301 549).
Harmonised standards translate legal requirements into detailed technical specifications. For broadcast and OTT providers, EN 301 549 offers a clear roadmap for designing user interfaces and controlling the accessibility of online video platforms. By following this standard, organisations can streamline their approach rather than attempt to piece together separate guidelines for hardware, web design, and app interfaces.
If a service or device fully complies with a harmonised standard cited in the Official Journal of the EU (such as EN 301 549), you earn a presumption of conformity - a significant advantage when demonstrating EAA compliance. However, regulators may still conduct spot checks and investigate user complaints to confirm genuine alignment. Falsely claiming adherence or applying standards only partially can lead to substantial fines or service suspensions.
Practical Recommendations for Broadcast and OTT Compliance
1. Conduct an Accessibility Audit
Start by reviewing your current offerings, websites, mobile apps, video libraries, and assess where you stand against accessibility standards like WCAG and EN 301 549. Identify gaps in user interface design, captioning or subtitling processes, and compatibility with assistive technologies.
2. Embed Accessibility in Product Development
Include accessibility best practices from the ground up. For instance, build navigable interfaces that can be operated without a mouse, ensure video content includes closed captions and audio descriptions, and provide text alternatives for images and infographics.
3. Adopt Harmonised Standards Early
Aligning with EN 301 549 helps clarify and unify your team’s efforts across different platforms - web, mobile, smart TV apps, EPGs, and more. By adhering to a recognised standard, you significantly reduce compliance guesswork and strengthen your legal position.
4. Policy, Training, and Continuous Improvement
Create an internal policy framework that mandates accessibility reviews at each stage of product development. Offer staff training on how to design, code, and test accessible digital solutions. Keep abreast of evolving standards and be prepared for updates the European Commission may adopt as harmonised standards.
5. Engage End-Users
Since each Member State enforces the EAA with its own specifics, early engagement with local regulators or accessibility consultancies can help clarify any grey areas. Consulting with end-users or disability advocacy groups can also provide practical feedback on real-world accessibility barriers.
Ready to ensure your broadcast, OTT, or digital media services meet the new European Accessibility Act requirements? Our expert team can guide you through an accessibility audit, help embed WCAG and EN 301 549 best practices into your product roadmap, and provide ongoing support for continuous improvement. Get in touch to future-proof your services, avoid penalties, and deliver a truly inclusive experience for all users by the 28th June 2025 deadline.
More insights you may enjoy
More insights you may enjoy
More insights you may enjoy
More insights you may enjoy
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Get in touch
Contact us - we don't bite
Drop us an email at hello@spicymango.co.uk or call us on +44 (0)844 848 0441 or fill out the contact form below for a friendly chat.
Get in touch
Contact us - we don't bite
Drop us an email at hello@spicymango.co.uk or call us on +44 (0)844 848 0441 or fill out the contact form below for a friendly chat.
Get in touch
Contact us - we don't bite
Drop us an email at hello@spicymango.co.uk or call us on +44 (0)844 848 0441 or fill out the contact form below for a friendly chat.
Get in touch
Contact us - we don't bite
Drop us an email at hello@spicymango.co.uk or call us on +44 (0)844 848 0441 or fill out the contact form below for a friendly chat.