Why we are campaigning
(Page last updated 20/12/2022)
Visually impaired persons enjoy films or documentaries as much as everyone else, but in order to fully understand them they need audio description and audio subtitling for what is shown on the screen.
Audio description communicates important visual content with spoken information inserted as a narrative between the dialogue and other programme sounds. Audio subtitling – also known as spoken subtitles – is the reading aloud of subtitles. As a complement – never as a substitute – to audio description, audio subtitling is especially useful to the visually impaired community in the case of foreign-language products that are subtitled rather than dubbed.
However, only a fraction of television or cinema content is produced in an accessible version in the first place. This is because too few production companies are aware of the access needs of blind or partially sighted persons and there are no incentives for them to invest in audio description and audio subtitling of their content.
Since 1991 the European Union (EU) supports the production and distribution of fiction and documentary projects for cinema and for television through the MEDIA strand of the Creative Europe programme. This funding has steadily increased until now, covering today the distribution of more than 400 films each year and the development of 200 films and series per year.
While the costs of audio description and audio subtitling are eligible costs for its funding, MEDIA supports films that fail to include blind and partially sighted persons. In fact, costs related to audio description and/or audio subtitling are rare in supported projects, and their exact figures and proportions are not even available. There have been some innovative MEDIA funding actions aimed at increasing audience by supporting the development of applications for accessibility, but this is very marginal, as recognised by EACEA, the executive agency that manages MEDIA funding.
Yet the EU acceded to the United Nations Convention on the Rights of Persons with Disabilities (CRPD) and it is responsible for its implementation to the extent of its competences. This includes EU funding. Article 30, paragraph 1, of the CRPD defines the right of persons with disabilities to take part on an equal basis with others in cultural life. Among other, it obliges State Parties to “take all appropriate measures to ensure that persons with disabilities (…) enjoy access to (…) films (…) in accessible formats”. The EBU Statement related to Article 30 describes the related accessibility needs for blind and partially sighted persons: “Television, film and video productions need to be audio described and audio subtitled, distributed through normal channels and made available at the same time and cost”.
Besides, Article 7 of the revised EU Directive on audiovisual media services requires media service providers in Europe to make their services continuously and progressively more accessible to persons with disabilities, including through audio description and audio subtitling. For instance, if a film is delivered in DCP Format with audio description, cinemas will need to ensure that the audio description is available, if only through a dedicated application.
We believe that public funding and in particular MEDIA funding to the film industry should be granted only to projects that will create a version with audio description and audio subtitling. But as an intermediate realistic step, we ask that, for the period 2021-2027 the Creative Europe Programme and annual work programmes include audio description and audio subtitling among the selection and award criteria for MEDIA funding, and at least 25% of films that receive MEDIA production or distribution funding have an audio description and audio subtitling in the languages of the production.
In follow-up to our Statement on European Elections 2019, we issued in 2020 a position paper containing recommendations on how to promote equal access to culture for persons with visual Impairments in the EU through EU funding to the film industry. In this paper, we argue that MEDIA must contribute to the awareness of audio description and audio subtitling among film producers as an element of accessibility for blind and partially sighted persons, and suggest how.
Considerable exchange, namely, at EU level, with the European Commission, the European Parliament rapporteur, EACEA (the Executive Agency that manages the MEDIA funding) and EFAD (the European Association of Film Agencies), but also at national level in Germany, have fed into our position paper and into a dedicated edition of our quarterly Focus Newsletter in October.
Although the paper was finalised in September, we started using it in early July 2020, to lobby the German presidency of the EU as the EU resumed discussions on the proposed Regulation on the Creative Europe programme for 2021-2027. We invited our members in the EU to send our (still draft) position paper to their ministries of culture and relevant advisers at their country’s permanent representation to the EU, and to express support for some key amendments proposed by the European Parliament in its first reading position; and to inform of our position and action the key MEPs on this file, urging the European Parliament to stand firm on its amendments in the interinstitutional negotiations.
At the same time, we sent a joint letter with the European Disability Forum to key contacts at the European Parliament, including the Disability Intergroup, the Council and the Commission. In the letter, we expressed support for a general clause of inclusion in the article defining the objectives of the programme, on condition that (a) it be strongly worded – we recommended wording – and (b) that it be not to the detriment of some designated and important amendments proposed by the European Parliament that specifically concern persons with disabilities. This opportunity was used to circulate again and more widely our position paper.
In the October 2020 edition of our quarterly Focus newsletter, on audio description, inter alia, we published our interview of Massimiliano Smeriglio, European Parliament Rapporteur (Committee on Culture and Education) on the proposed Regulation establishing the Creative Europe programme (2021-2027) and an article by the Secretary General of EFAD, the voice of national European Film Agencies in charge of national funding for the audiovisual sector, both expressing support for the EBU demands.
On 16 December, in a press release, we welcomed the reaching of a political agreement between the European Parliament and EU Member States on the new Creative Europe programme for 2021-2027, after over a year of interinstitutional discussions on the Commission’s proposal – delayed partly due to the COVID19 pandemic. We expressed satisfaction that the agreement largely responded to our demands (see “The current situation” below).
Early in 2021 we started to lobby the Commission on the Creative Europe/MEDIA work programmes for 2021 and beyond. So we learned that all funding applicants will be asked to commit to promote diversity and inclusiveness (broadly intended, i.e. beyond disability) in their company strategies, and this horizontal criterion will be taken into account in the selection of the projects. To fine-tune our demands about conditionality for EU funding, though our national member organisations, we started to investigate the practices and needs of the film industry at national level on audio description. In September 2021 we had an awareness-raising campaign on Twitter about the right of access to culture under the UNCRPD. This was an opportunity to raise the visibility of our call for funding to the film industry promote audio description and audio subtitling.
The current situation
The new Creative Europe Regulation provides a good basis for our continued campaign from 2021 onward. In substance:
- A new general clause in Article 3 of the Regulation, on the objectives of Creative Europe, says that the objectives of Creative Europe shall be pursued in a way that encourages inclusion, equality, diversity and participation; and that where appropriate, this shall be achieved through specific incentives that ensure that inter alia people with disabilities can access the culture and creative sectors, and encourage their active participation in those sectors, including both the creative process and audience development.
- More directly related to our campaign, Annex I indicates that activities through which the MEDIA priorities should be pursued include support for subtitling, dubbing and audio description.
The first Creative Europe/MEDIA calls for proposals for 2021-2027
- The call for proposals ‘Films on the Move’ underlines that the MEDIA strand shall provide support namely for encouraging the use of subtitling, dubbing and where applicable, audio description tools. It further indicates that “special attention will be given to applications presenting adequate strategies to ensure gender balance, inclusion, diversity and representativeness”. This counts for points in the award criteria for relevance.
- A similar approach is taken in the calls for proposals ‘Tv and online content’ and ‘Audience Development and Film education’, albeit without explicit mention of audio description. And the call for proposals ‘Networks of European Cinemas’, among expected results, includes adjusting the business practices of European cinema theatres in terms of inclusion.
In June 2021, we issued a press release to welcome some progress observed in the first calls for proposals under the new Regulation. In particular we noted the underlining that the MEDIA strand shall provide support namely for encouraging the use of subtitling, dubbing and where applicable, audio description tools, and that “special attention will be given to applications presenting adequate strategies to ensure gender balance, inclusion, diversity and representativeness”.
A year later, in a statement of July 2022, after more careful monitoring of how the Regulation is concretely implemented, we deplored the lack of concrete incentives for audio description and audio subtitling in MEDIA funding to the film industry, or in any case of visible emphasis on making films accessible for visually impaired people. This is probably because the Creative Europe regulation does not include a legal obligation for the programme’s executive agency to have measurable goals as far as promoting inclusion is concerned, we argued.
With our analysis we intend to contribute to the stock-taking exercise announced by the Unit of the Audiovisual Industry and Media Support Programmes at the European Commission’s DG CNNECT in view of their 2022 monitoring report. We also ask the Commission to use the opportunity of the mid-term review of the Creative Europe Regulation 2021-2027, to consider introducing some benchmarking on how MEDIA funding is used to promote inclusion, and in particular accessible films for people with visual impairment.
Further reading :
- For more information on audiodescription, and arts and culture in general, see the access to arts and culture section of the website
- In October 2020 EBU published a Focus newsletter on Audiodescription, available in English, French, Spanish, and German on line, and as word documents in Polish, Serbian and Turkish
- European Blind Union (2016). Describing Audio Description.
- European Commission (2018). Proposal for a Regulation Establishing the Creative Europe Programme (2021 to 2027) and Repealing Regulation (EU) No 1295/2013. COM(2018) 366 final.
- European Commission (2019). Creative Europe Projects Overview.
- European Disability Forum (2019). Toolkit for transposition of the Audiovisual Media Services Directive.
- ISO/IEC TS 20071-21:2015 Information technology — User interface component accessibility — Part 21: Guidance on audio descriptions
Press releases and position papers:
- EBU Position paper on MEDIA funding to European film industry: Promote Equal Access to Culture for Persons with Visual Impairments in the EU, pdf and word format (September 2020)
- 16 December 2020, Creative Europe (2021-2027) - Cultivating inclusion through EU funding, Press release (pdf)
- 16 June 2021, Creative Europe (2021-2027) - Including people with visual impairment, Press release (pdf)
- EBU Statement on Creative Europe 2021-2027: where are the incentives for audio description and subtitling in MEDIA funding to the film industry? (pdf) a word version of this document is also available. (July 2022)