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EAAstreamingaudiovisual mediaEN 301 549

EAA streaming compliance: what video services must do

What the European Accessibility Act asks of streaming and on-demand video services: programme guides, subtitles, audio description, player controls.

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Pavel Charkasau

EAA streaming compliance is about the access layer, not the content. The European Accessibility Act covers "services providing access to audiovisual media services" (Directive (EU) 2019/882, Article 2(2)(b)). That means the website, app, set-top box software, connected-TV app and media player that people use to find, pick and watch programmes, plus the electronic programme guide. Whether a given film actually has subtitles or audio description is a separate question. A different law answers it: Article 7 of the Audiovisual Media Services Directive (Directive 2010/13/EU, as amended).

In practice the EAA asks a streaming service for two specific things on top of the general service rules. Its programme guide must be perceivable, operable, understandable and robust, and it must say which titles have accessibility features. And when a title does carry subtitles, audio description, spoken subtitles or sign language, the service must deliver them in full, in sync, and let the viewer control them (Annex I, Section IV(b)). The rules have applied to services provided to consumers since 28 June 2025. Below is what that looks like for a real player, and what you can and can't check automatically.

Does the EAA apply to streaming services?

Yes, if the service gives consumers in the EU access to audiovisual media services. The EAA defines that category as services "used to identify, select, receive information on, and view audiovisual media services", including features such as "subtitles for the deaf and hard of hearing, audio description, spoken subtitles and sign language interpretation", and it explicitly includes electronic programme guides (Article 3(6)).

Recital 31 lists what that can look like: "websites, online applications, set-top box-based applications, downloadable applications, mobile device-based services including mobile applications and related media players as well as connected television services" (Recital 31). So a video-on-demand subscription, a broadcaster's catch-up app and an operator's TV platform all sit in this bucket.

Two scope details are worth knowing before you plan work:

  • The term "audiovisual media service" is borrowed from the AVMSD. It means programmes provided under the editorial responsibility of a media service provider, either as a TV broadcast or on demand (Directive 2010/13/EU, Article 1(1)(a)). The AVMSD defines video-sharing platforms separately, in Article 1(1)(aa), as services without that editorial responsibility. If you run a user-upload platform, get legal advice on whether this EAA category reaches you at all.
  • Microenterprises providing services are exempt from the accessibility requirements (Article 4(5)). That means fewer than 10 staff and annual turnover or balance sheet of €2 million or less (Article 3(23)). Most streaming platforms are well above that line.

The devices are covered too. "Consumer terminal equipment with interactive computing capability, used for accessing audiovisual media services" is a named product category (Article 2(1)(d)). The Act defines it as any equipment whose main purpose is to give access to those services, so set-top boxes count. That obligation sits with the manufacturer. This post is about the service side.

Does the EAA require subtitles on every programme?

No, and this is the point people most often get backwards. Recital 31 says it directly: accessibility of audiovisual media services "is regulated in Directive 2010/13/EU", with the exception of programme guides, which the EAA covers (Recital 31).

The AVMSD rule for the content is softer and works differently. Member States must ensure that media service providers make their services "continuously and progressively more accessible to persons with disabilities through proportionate measures", report regularly to the national regulator, and are encouraged to write accessibility action plans (AVMSD, Article 7(1)–(3)). Each Member State also has to name a single online point of contact for accessibility complaints about those services (Article 7(4)). National rules on how much content needs subtitles or audio description vary by country, so check the rules where your service is established.

The split matters for engineering. The editorial team decides how many titles get audio description. The product team owns the EAA side: if a title has audio description, the player has to let a blind viewer find it, switch it on and hear it in sync. A catalogue full of described titles doesn't help if the audio-track menu can't be reached by keyboard or screen reader.

What does the EAA require of a streaming service?

Every in-scope service first meets the general service requirements in Annex I, Section III. That includes making "websites, including the related online applications, and mobile device-based services, including mobile applications" perceivable, operable, understandable and robust, giving accessible information about how the service works, and having support services that can tell people about accessibility (Annex I, Section III(b)–(d)).

Section IV(b) then adds two duties specific to access services:

Annex I, Section IV(b)What it means for your product
(i) EPGs that are "perceivable, operable, understandable and robust and provide information about the availability of accessibility"The guide or browse grid works with keyboard, remote and screen reader, and each title shows whether it has subtitles, audio description or sign language
(ii) Access services "fully transmitted with adequate quality for accurate display, and synchronised with sound and video, while allowing for user control of their display and use"Your encoding and delivery chain doesn't drop or desync subtitle and audio-description tracks, and the viewer can turn them on, off and adjust them

Annex II gives non-binding examples. One is "providing that a blind person can select programmes on the television". The other describes user controls to activate access services "at the same level of prominence as the primary media controls" (Annex II, Section IV).

How does EN 301 549 translate this into testable checks?

The EAA states outcomes, and no harmonised standard has been cited under it in the Official Journal yet, so you assess against Annex I directly. EN 301 549 is still the practical way to do it. ETSI published V4.1.1 on 2 September 2026, and its Annex ZB maps the standard to the EAA. Table ZB.5 links the programme-guide duty to Clauses 9, 10, 11 and 12, and the access-services duty to Clause 7 plus the subtitle and audio-description criteria in 9.1.2, 10.1.2 and 11.1.2 (ETSI EN 301 549 V4.1.1). V4.1.1 is not cited in the Official Journal either, so it carries no presumption of conformity yet (AccessibleEU, September 2026).

Clause 7 is the part streaming teams tend to skip, and it is concrete (EN 301 549 V4.1.1, Clause 7):

  • 7.1.1 Subtitle playback. The player must have a mode that displays available subtitles and let the user choose to show closed subtitles.
  • 7.1.2 Subtitle synchronization. Subtitles must appear within 100 ms of their timecode.
  • 7.1.3 and 7.2.3 Preservation. Anything that transmits, converts or records the video must keep the subtitle and audio-description data intact, including position and colour. Your transcoding pipeline is in scope here.
  • 7.1.4 Subtitle characteristics. If you control subtitle rendering, users must be able to adapt it (font, size, colours, background).
  • 7.1.5 Spoken subtitles and 7.2.1 Audio description playback. If those tracks exist, the player has to be able to play them. Letting the user pick between audio tracks counts for audio description.
  • 7.3 User control. One user operation turns subtitles, audio description or spoken subtitles on or off, "at the same level as the volume control".

My opinion on 7.3: it is the cheapest fix on this list, and it's the one I'd do first. If turning on audio description takes the gear icon, then "Audio", then a submenu, then a track name, you have work to do. The subtitle toggle belongs in the control bar, next to volume, as a real button:

<button type="button" aria-pressed="false" aria-label="Subtitles">…</button>

A div with a click handler and an SVG icon looks identical on screen. A screen reader announces it as nothing at all, and a keyboard user can't reach it.

What can an automated scan check on a streaming site?

Less than you'd like. Automated testing finds roughly 57% of issues by volume in Deque's analysis of more than 2,000 audits; measured by WCAG success criteria, coverage is closer to 30% (Deque, 2021).

On the web player and browse pages, a scanner is good at the structural defects: player buttons with no accessible name (WCAG 4.1.2), icon-only controls, low contrast on overlay text and the progress bar, missing page language, and form problems in sign-up and payment. Clear those first; a free scan lists them with the failing selectors.

What a scanner can't tell you:

  • whether the subtitles are accurate, complete and in sync (Clause 7.1.2's 100 ms is a playback measurement, not a DOM check);
  • whether audio description exists and plays in the right place;
  • whether a screen-reader user can actually move through the guide grid and know where they are;
  • anything inside a native smart-TV or set-top box app, which a web scanner never loads.

That last point is a limit of our product too. We scan web pages. For TV and native apps you need device testing with the platform's screen reader and a remote. Full conformance needs that human review on top of any automated scan. Our WCAG checklist covers the manual pass for the web surfaces.

What should go in a streaming service's accessibility statement?

Say what works, what doesn't and when it will. A useful accessibility statement for a streaming service names the surfaces covered (web, iOS, Android, each TV platform), the standard you tested against, and known gaps. A real gap reads like this: "audio description can be selected on web and mobile but not yet on our TV app". It also gives a feedback contact. Separately, Annex V asks service providers to explain how the service meets the accessibility requirements in their general terms and conditions or an equivalent document (Annex V). A statement documents your efforts. It isn't a promise that every title is accessible, and it shouldn't read like one. The statement generator gives you a structure to start from.

Frequently asked questions

Does the EAA apply to subscription video-on-demand services?

Yes, when they serve consumers in the EU. The EAA covers "services providing access to audiovisual media services", which includes the websites, apps, connected-TV apps and media players used to find and watch on-demand programmes, plus the programme guide.

Does the EAA require captions on all videos?

No. The EAA requires that existing access services such as subtitles and audio description are fully transmitted, synchronised and controllable by the user. How much content must carry them is governed by Article 7 of the Audiovisual Media Services Directive and national rules.

What is an EPG under the EAA?

An EPG is the electronic programme guide, and the EAA names it explicitly as part of services providing access to audiovisual media. It must be perceivable, operable, understandable and robust, and it must show which programmes have accessibility features.

Are smart TVs and set-top boxes covered?

Yes, as products. Equipment whose main purpose is accessing audiovisual media services is a named product category, and Annex I requires it to make the provider's accessibility components available for selection, control and personalisation. Those duties fall on the device manufacturer.

Can an automated scanner make a streaming service EAA compliant?

No. A scanner finds structural defects on web pages, such as unnamed player buttons and contrast problems. Subtitle sync, audio description, guide navigation with a screen reader and native TV apps all need human testing.

See what your web player gets wrong

Start with the surface you control most directly. Scan your browse pages and web player to find the unnamed controls and contrast failures, then test subtitle and audio-description switching by hand on each platform you ship.

Pavel Charkasau, founder, wcagc.com. Last updated 5 October 2026.

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