Subtitles and the Law: Accessibility Requirements by Region

If you publish video content online, accessibility requirements may apply to your organisation, depending on the countries in which you operate, the services you provide and the type of content you publish. Captions and subtitles can help people who are deaf or hard of hearing access spoken information and other meaningful audio content.

However, there is no single international law requiring every business to subtitle every video. Legal obligations vary by jurisdiction, organisation and content type. Failure to meet applicable accessibility requirements can lead to complaints, enforcement action or legal claims, depending on the circumstances.

This guide outlines key accessibility laws and standards in several major markets. It is intended as a general overview rather than legal advice, so organisations should check the rules applicable to their particular circumstances.

United States: ADA and Section 508

In the United States, the Americans with Disabilities Act (ADA) prohibits disability discrimination in areas covered by the legislation. The US Department of Justice has stated that ADA obligations can apply to websites and online services provided by businesses open to the public and by state and local governments.

Depending on the circumstances, businesses and public bodies may need to provide effective communication for people with disabilities. Captions can be one way to achieve this for video content, although the precise requirements depend on the applicable legal duties and the circumstances in which the content is provided.

Section 508 of the Rehabilitation Act concerns the accessibility of information and communications technology developed, procured, maintained or used by federal agencies. It includes requirements relevant to video and multimedia content. Its application to contractors depends on the circumstances, including their role in providing technology to federal agencies.

Where applicable, technical accessibility requirements may include captions that are synchronised with the audio and convey the dialogue and other meaningful sounds. Organisations should assess the relevant legal and technical requirements rather than assume that one rule applies to every online video.

European Union: Web Accessibility Directive and European Accessibility Act

The EU Web Accessibility Directive requires public-sector bodies to make their websites and mobile applications accessible, subject to the Directive's scope and exemptions. Its requirements include provisions concerning pre-recorded audiovisual media published on websites and in mobile applications.

The date of publication is relevant: pre-recorded time-based media published before 23 September 2020 is generally exempt under the Directive, as is live time-based media, subject to the applicable rules. The Directive also contains other exemptions and qualifications. Member States implement and enforce the requirements through their respective national arrangements.

The United Kingdom has a separate public-sector accessibility framework under the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018. These regulations have their own scope, exceptions and requirements.

Commercial businesses may also be subject to other applicable EU legislation. The European Accessibility Act, which has applied to specified products and services since 28 June 2025, covers certain services, including e-commerce services, subject to its scope and exemptions. Whether particular video content is covered depends on the relevant service and legal requirements; the Act should not be interpreted as a universal requirement to subtitle every online video.

United Kingdom: Equality Act 2010 and Ofcom

In Great Britain, the Equality Act 2010 prohibits disability discrimination and requires service providers to make reasonable adjustments where the relevant legal duties apply. Depending on the circumstances, these adjustments may include providing accessible information or captions for video content.

The Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 impose additional accessibility requirements on public-sector websites and mobile applications within their scope. They are not a blanket set of technical requirements applying to every private-sector website.

Ofcom regulates accessibility requirements for television broadcasting and certain on-demand programme services. The rules differ between broadcast television and on-demand services. The Media Act 2024 has introduced a framework for accessibility requirements affecting certain on-demand programme services, with the applicable obligations depending on the service and relevant regulatory requirements.

Consequently, a business publishing videos online should not assume that the same statutory subtitle quotas apply to all websites, social media videos and streaming services. The relevant legislation depends on the nature of the service, the organisation and the content.

In Northern Ireland, disability discrimination law operates under a separate legislative framework, including the Disability Discrimination Act 1995.

Australia: Disability Discrimination Act 1992

Australia's Disability Discrimination Act 1992 prohibits disability discrimination in areas covered by the legislation, including the provision of services. Accessibility obligations may therefore be relevant to online services and digital content.

The Australian Human Rights Commission recognises the Web Content Accessibility Guidelines (WCAG) as an important benchmark for web accessibility. However, the applicable legal obligations should be assessed in context; it would be inaccurate to assume that one WCAG version or conformance level automatically constitutes the complete legal standard for every Australian organisation.

Where WCAG requirements apply, captions for pre-recorded video with audio are among the relevant technical accessibility considerations. Organisations should identify the standards applicable to their services, including any relevant legal, regulatory or contractual requirements.

International standards: WCAG

The Web Content Accessibility Guidelines (WCAG), developed by the World Wide Web Consortium (W3C), provide internationally recognised technical guidance for making web content more accessible. They are widely used in accessibility policies, technical specifications and legal or regulatory frameworks, but they are not, by themselves, a universal law applicable to every organisation.

WCAG includes specific success criteria for captions. Under WCAG 2.1 and WCAG 2.2, Success Criterion 1.2.2 (Captions (Prerecorded)) is a Level A criterion. It requires captions for pre-recorded audio content in synchronised media, subject to the criterion's stated exception. The requirement covers dialogue and meaningful non-speech audio information, not merely a transcript of spoken words.

Live captions are addressed separately under Success Criterion 1.2.4, a Level AA criterion in WCAG 2.1 and WCAG 2.2. Other success criteria address audio description and alternative media formats.

The version and conformance level relevant to an organisation depend on the applicable legal, regulatory or contractual requirements. WCAG 2.1 Level AA should therefore not be described as the universal legal standard across all jurisdictions.

For organisations operating internationally, using an appropriate WCAG conformance level as part of an accessibility strategy can provide a useful technical baseline. However, following WCAG alone does not guarantee compliance with every applicable law. Organisations should also review the specific requirements, exemptions and enforcement arrangements in each relevant jurisdiction.

Sources and further reading

United Kingdom, public-sector accessibility

GOV.UK: Understanding accessibility requirements for public-sector bodies. Explains the scope of the regulations, reasonable adjustments, exemptions and WCAG requirements.

United States, ADA

US Department of Justice: Guidance on Web Accessibility and the ADA. Official guidance on web accessibility and disability discrimination, including the role of captions.

European Union, public-sector websites

Directive (EU) 2016/2102 on the accessibility of public-sector websites and mobile applications. The primary legal source for the Web Accessibility Directive, including its scope and exemptions.

United Kingdom, broadcasting and on-demand services

Ofcom: Television and on-demand accessibility report. Distinguishes statutory broadcast requirements from the developing framework for on-demand programme services.

International, WCAG captions criterion

W3C: Understanding Success Criterion 1.2.2 — Captions (Prerecorded). Explains precisely which content requires captions under this criterion and how it works.

Australia, disability discrimination and accessibility standards

Australian Human Rights Commission: Standards and guidelines for digital accessibility. Discusses WCAG and its relevance to digital accessibility in Australia.

How Subify helps with compliance

Subify generates accurate, synchronised subtitle files that can help support accessibility compliance efforts. Our AI produces captions with high accuracy, and our editing interface lets you correct any errors before publishing. We support SRT and ASS formats, which are compatible with all major platforms and players. For organisations that need to demonstrate accessibility, our subtitle files include proper timing information and can be exported in standard formats that align with WCAG captioning requirements. Our guide on subtitles for accessibility covers the practical steps in more detail.

Getting started

To create accessible subtitles, upload your video to Subify and let automatic processing convert the spoken content to text. Download your SRT file and upload it to your platform of choice. The Free plan includes 10 minutes of processing per month, which is enough to subtitle a short video and test the workflow. For multi-language support and full styling control, upgrade to a paid plan for ASS files and translation.

You can see all plans or start free today.