The European Accessibility Act (EAA) (Directive (EU) 2019/882) came into effect on 28 June 2025, and businesses in the EU are facing new accessibility requirements across various sectors. In the audiovisual media (AVM) sector, this applies in particular to providers of relevant hardware and providers of services enabling access to audiovisual content, who will be subject to specific obligations aimed at ensuring accessibility for persons with disabilities.
Scope of application for audiovisual media services
The EAA covers both the hardware devices used to access AVM services and the digital services that provide such access. AVM services are as defined in the Audiovisual Media Services Directive (Directive 2010/13/EU) (AVMD), i.e. either TV broadcasts or on-demand audiovisual media services. In scope are "consumer terminal equipment with interactive computing capability, used for accessing audiovisual media services” which includes receivers or streaming devices. The EAA also covers mere "services providing access to audiovisual media services", meaning any service that helps users find, select, and view TV programs or similar media. This includes websites, web apps, mobile apps and related media players, connected TV services, and electronic program guides (EPG’s).
Importantly, the EAA does not establish a direct legal obligation to make AVM content accessible. An obligation to aim for accessible audiovisual content itself is provided by the AVMD (excluding the accessibility of EPGs which are regulated by the EAA). However, the AVMD does not include any binding accessibility requirements.
Accessibility requirements
Under the EAA, separate accessibility requirements apply to devices used to access AVM services, categorised as "products", and to digital services enabling such access, which are classified as "services".
Relevant obligations for products used to access audiovisual media services include:
- Providing information on the use of the product in an accessible way, ie via more than one sensory channel, drawing up technical documentation of the product and carrying out a conformity assessment procedure.
- The product must provide the accessibility features provided by the service provider for user access, control and transmission to assistive devices. For example, subtitles for people with hearing disabilities must be transmitted via the streaming device.
Providers of services providing access to audiovisual media services must:
- Provide general information on the functioning of the service and how it meets the accessibility requirements as well as make the website or mobile application of the service accessible.
- Make EPGs easy to see, understand, navigate, and use. It should be clearly indicated which programs have accessibility features. For example, sight-impaired people should be able to select TV programmes.
- Subtitles, audio descriptions, spoken subtitles, sign language interpretation and other accessibility components (access services) must be fully transmitted in high quality, accurately displayed, and synchronised with sound and video. Users should be able to control how these features are displayed and used.
Implementation and enforcement in Germany
The EAA’s requirements for the products providing access to audiovisual media services are included in the German implementation of the EAA, the Barrierefreiheitsstärkungsgesetz (BFSG), along with its corresponding delegated regulation Verordnung zum Barrierefreiheitsstärkungsgesetz (BFSGV). Due to the German federal system, accessibility of services providing access to audiovisual media services is, however, implemented in the German State Media Treaty (MStV).
As a result, enforcement responsibility is spread between different regulators. Enforcement of the BFSG lies with the joint market surveillance authority of the federal states, the ‘Market Surveillance Authority of the Federal States for the Accessibility of Products and Services’ (MLBF), which is based in Magdeburg and will be responsible for consistent nationwide enforcement.
In contrast, the enforcement of accessibility provisions for services providing access to AVM under the State Media Treaty falls within the responsibility of the respective state media authorities in each federal state. Consumers may file complaints with the market surveillance authority or the respective media authority, which may then initiate proceedings. The consequences of non-compliance are also discussed in more detail in our earlier overview of the EAA.
Find out more
Please contact us if you have questions about the application of the EAA to audiovisual media, and find out more about the EAA and other accessibility regimes here.
