Short answer
The European Accessibility Act (EAA) does not, by itself, require every video to carry audio description. It requires the services that give people access to audiovisual media, meaning players, apps, connected-TV services and programme guides, to deliver audio description accurately, in sync with the picture, and under the viewer's control. The duty to make the content itself accessible sits mainly in national media law that implements the Audiovisual Media Services Directive (AVMSD). The EAA has applied since 28 June 2025.
What the EAA is and when it applies
The EAA is Directive (EU) 2019/882. It applies to products placed on the market, and services provided to consumers, after 28 June 2025.
For media companies the relevant part is Article 2(2)(b): "services providing access to audiovisual media services". Article 3(6) defines these as services that let users identify, select, receive and view audiovisual media, including features such as subtitles for the deaf and hard of hearing, audio description, spoken subtitles, sign language interpretation and electronic programme guides.
Two transitional rules matter. Service contracts agreed before 28 June 2025 may run until they expire, for no more than five years (Article 32(1)). Pre-recorded time-based media published before 28 June 2025 is excluded from the website and mobile-app content rules (Article 2(4)(a)).
Who has to comply
Two groups are covered, according to Taylor Wessing's overview:
- Providers of hardware used to access audiovisual media, such as receivers and streaming devices.
- Providers of services that give access to audiovisual media: websites, web apps, mobile apps, media players, connected-TV services and electronic programme guides.
In practice that means streaming and video-on-demand platforms, broadcasters' apps and players, and programme-guide providers. Microenterprises that provide services are exempt from the service requirements (Article 4(5)). A microenterprise has fewer than 10 employees and an annual turnover or balance sheet total of no more than EUR 2 million (Article 3(23)).
What exactly has to be delivered
Under the EAA, audio description is an "access service". Providers must:
- transmit subtitles, audio description, spoken subtitles and sign language interpretation in full;
- display them accurately and keep them synchronised with sound and video;
- let users control how these features are displayed and used;
- make electronic programme guides perceivable, understandable, navigable and operable, and flag which programmes have accessibility features;
- make the website or app itself accessible, and publish information on how the service meets the requirements;
- for devices, pass accessibility features through so they reach the user or an assistive device.
The split between the EAA and media law is the part most teams miss.
- Must the content itself carry audio description? The EAA sets no direct obligation. National media law does, where it implements the AVMSD.
- Must the player and app deliver audio description properly? Yes, under the EAA.
- Must the programme guide show which programmes have it? Yes, under the EAA.
- Who enforces? A market surveillance authority for the EAA, and the media regulator for media law.
The AVMSD itself only asks providers to work towards accessible content; binding rules come from how each country implemented it.
Country notes
Germany. The EAA's product rules are implemented through the Barrierefreiheitsstärkungsgesetz (BFSG) and its regulation (BFSGV). Accessibility of access services for audiovisual media is implemented through the State Media Treaty (MStV). The BFSG is enforced by the joint market surveillance authority of the federal states (MLBF, Magdeburg); the MStV by each state's media authority. Consumers can complain to either.
German penalties. Under Section 37 BFSG, offering or providing a service that does not meet the accessibility requirements can be fined up to EUR 100,000. Breaches of the information duties carry fines of up to EUR 10,000. Taylor Wessing also points out that competitors and consumer associations can seek injunctions. Access services for audiovisual media are implemented through the State Media Treaty rather than the BFSG, so check with counsel which sanctions apply to your service.
Other EU countries. Member States transposed the directive at different speeds and in different detail. Check the national law of every market you serve, both the EAA transposition and the media-law rules on audio description.
United Kingdom. The UK is outside the EU, so the EAA does not apply there. UK broadcasters follow Ofcom's rules instead, in particular its Code on Television Access Services.
Practical steps for a streaming or broadcast team
- Map your catalogue. List which titles already have an audio description track and which markets they are served in.
- Test the player and app. Check that the audio description track can be found, switched on and off, and stays in sync on every device and platform you support.
- Check the programme guide. Make sure titles with audio description are flagged and the guide can be used with a screen reader.
- Read the national media law of each market, because that is where the duty to produce audio description sits.
- Set up a production workflow. Decide who writes, who reviews and who voices the description, and how the finished track reaches your platform.
- Document it. Keep the information on how your service meets the accessibility requirements current and published.
Step 5 is where tooling matters. Synchrogen is an AI-assisted audio description tool for professional describers: it drafts the description script and a human describer reviews and approves it before anything is published.
FAQ
Does the EAA require audio description on all videos?
No. It requires that services giving access to audiovisual media deliver audio description properly where it exists. The duty to provide it comes from national media law.
When did the EAA start to apply?
On 28 June 2025.
Are small companies exempt?
Microenterprises (fewer than 10 employees and no more than EUR 2 million turnover or balance sheet total) are exempt from the service requirements.
Does the EAA apply in the UK?
No, the UK is not in the EU. In the UK, access services on television, including audio description, are regulated by Ofcom under its Code on Television Access Services.
Does the EAA say how audio description must be produced?
No. It regulates delivery and display, not production. How the description is written and reviewed is up to you and to your national regulator.
This article is general information, not legal advice.