Audio description and audio subtitling should become eligibility criteria for EU-funded film projects.
To make films accessible for blind and partially sighted persons, among other things audio description and audio subtitling are required. The European Union should use its financial support for the film industry as a lever to raise awareness among producers to this end.
The EU acceded to the United Nations Convention on the Rights of Persons with Disabilities (CRPD) in its own right in 2010. It is thus responsible for implementation of the convention, to the extent of its competences.
Article 30(1) of the CRPD defines the right of persons with disabilities to take part on an equal basis with others in cultural life. Inter alia, it obliges states-party to ‘take all appropriate measures to ensure that persons with disabilities … enjoy access to … films … in accessible formats’.
Moreover, article 7 of the revised EU directive on audiovisual media services requires providers in Europe to make their services continuously and progressively more accessible to persons with disabilities. This includes through audio description and audio subtitling.
Visually impaired people like to watch films or documentaries as much as anyone else. But to enjoy the experience to the full, they need television, film and video productions to be audio-described and, when dubbed, audio-subtitled.
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Henrik Götesson, advocacy officer for the Swedish Association of the Visually Impaired, put it this way: ‘Audio description has opened new doors. I can now watch movies such as Spector or The Crown. I can also watch information videos from the local government where I live. My knowledge on facial expressions and body language has improved.’
Yet still only a fraction of television or cinema content is produced in an accessible version in the first place. Too few production companies are aware of the access needs of visually impaired persons and there are no incentives for them to invest in audio description and audio subtitling of their content.
Some EU member states do have schemes to fund audio description. Since 2013, the German federal film board has only been permitted to fund film-production projects that include audio description in their budget or distribution projects for films that are already audio-described. The number of accessible films in the cinema and on television has increased significantly in Germany as a result.
The European Blind Union (EBU) proposes this a model for funding of the European film industry under the MEDIA strand of the Creative Europe programme. In a 2020 position paper, ahead of the adoption of the Creative Europe regulation the following year, EBU recommended that audio description and audio subtitling be included among the selection-and-award criteria, based on which proposals eligible for MEDIA funding are assessed. As an intermediate realistic step, it proposed that at least 25 per cent of films in receipt of MEDIA funding should have audio description and audio subtitling in the programme’s 2021-27 period.
Not fit for purpose
Unfortunately, the regulation does not appear fit for that purpose. Despite initial concerns, support measures under MEDIA do take in audio description and subtitling. But the description of MEDIA’s ‘audience development’ cluster fails to mention these under means of ‘ensuring access’.
A welcome general clause affirms that the programme’s objectives shall be pursued in a way that encourages inclusion, equality, diversity and participation and, where appropriate, through specific incentives that ensure access to culture and creative sectors for people with disabilities—among other groups at risk of social exclusion and marginalisation—and encourage their active participation in those sectors. This criterion is supposed to count for 5 per cent of assessment calculations.
EBU was keen to monitor the relevant MEDIA grant, to see whether the programme was delivering in practice, as far as the needs of visually impaired people were concerned. And it was initially reassuring to see the systematic indication in the calls for proposals that ‘special attention will be given to applications presenting adequate strategies to ensure gender balance, inclusion, diversity and representativeness’.
This however turned to disappointment. Disability—let alone visual impairment specifically—was not mentioned in any of the calls observed; audio description was seldom mentioned and audio subtitling never. Particularly deplorable was the silence on concrete measures for inclusion in the ‘MEDIA 360°’ call, given its wide scope across the value chain. The specific weight in award criteria of inclusion of persons with disabilities is unknown and might as well be null, given the silence on audio description and audio subtitling in the relevant MEDIA calls observed so far.
To say the least, in MEDIA institutional communication and calls for proposals there is no visible emphasis on using funding to promote audio description and audio subtitling. This stems from the absence in the Creative Europe regulation of a legal obligation for the programme’s executive agency to have measurable goals as far as promoting inclusion is concerned.
The mid-term review of the programme regulation provides the opportunity for concrete recommendations. In response to the recent call for evidence for the review, EBU has called on the European Commission to consider introducing benchmarks on how MEDIA funding is used to promote inclusion—and, in particular, accessible films for people with visual impairment.
Antoine Fobe is head of advocacy and campaigning at the European Blind Union, which has a network of 41 national members. He previously worked for European Citizens’ Action Service, Amnesty International, the Council of Bars and Law Societies and the French data-protection authority.