European Accessibility Act and video captions: a checklist for 2026
What the European Accessibility Act's text says about captions, where guides disagree, and a practical checklist for captioning video in 2026. Not legal advice.
The Scriptorium team ·
The European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025. Its text names subtitles for the deaf and hard of hearing in one place: the access components of services that provide access to audiovisual media. Whether your own videos are covered depends on who you are and what you provide, and vendor guides disagree on how far it reaches. What is safe either way is the practice the standards describe: caption pre-recorded video that has speech, review automatic captions before you publish them, and keep a record. This guide separates what the Directive says from what guides claim, then gives a checklist. It is not legal advice.
What the Directive's text says
We read the Directive's text on 2026-10-27. EUR-Lex (the Directive on EUR-Lex) would not load for our automated reader that day, so the wording below was read on the UK National Archives' copy of the Directive as adopted, which carries the same articles; check EUR-Lex for the authoritative text. National laws transpose the Directive, so your country's law is what binds you.
- When it applies. Article 31 says Member States apply their measures from 28 June 2025 (transposition was due by 28 June 2022).
- What it covers. Article 2 lists services including services providing access to audiovisual media services, electronic communications services, consumer banking, e-books and e-commerce services, plus passenger transport. It is not a general rule for every website or video.
- Captions in the text. Annex I, section IV on services providing access to audiovisual media services, requires access components to be fully transmitted, including subtitles for the deaf and hard of hearing, audio description and spoken subtitles. The word "captions" does not appear in Annex I as we read it.
- Small providers. Article 4(5) exempts microenterprises providing services. Who counts as a microenterprise is defined by EU rules we have not quoted here; check the definition that applies to you.
- Existing contracts. Article 32 lets service contracts agreed before 28 June 2025 continue unchanged until they expire, with a limit of 28 June 2030.
For plain-language scope, see the European Commission's accessibility act page, which lists the product and service categories. It was the page we could read; it did not state the application date in the text we read.
Where sources disagree
Several companies that sell caption tools have written about the Act. We read two on 2026-10-27 and set them beside the Directive text above. This is not a criticism: it shows why you should read the primary text and ask counsel instead of relying on a vendor summary, ours included.
| Source | What it says (paraphrased) | What the Directive text we read says |
|---|---|---|
| Kapwing's EAA guide | The Act applies to all new public-facing digital products and services; videos published after 28 June 2025 must include captions and older ones by 2030; captions should follow WCAG 2.1 AA; micro-enterprises may be exempt from some requirements. | Scope is a list of products and services (Article 2). Annex I names subtitles for the deaf and hard of hearing for services providing access to audiovisual media. WCAG is not named in the Articles we read. 2030 appears in Article 32 for service contracts. |
| Happy Scribe's guide | Requirements apply to organisations with more than 10 employees and a turnover threshold; it concedes the Act does not specifically mention captions or subtitles; it gives the Act's start as April 2019. | Microenterprises providing services are exempt (Article 4(5)); Annex I does name subtitles for the deaf and hard of hearing for audiovisual media access services; the Directive applies from 28 June 2025 (Article 31). |
Where guides and the text differ, treat the text as the baseline and a lawyer in your country as the authority. Both companies sell captioning, and so do we, so everyone here has an interest.
The checklist
These are practices, mapped to standards you can read. Which of them the law requires of you is the part to confirm with counsel.
- Caption pre-recorded video that has speech. WCAG 2.2 success criterion 1.2.2 (Level A) says captions are provided for all prerecorded audio content in synchronized media.
- Plan for live video separately. Criterion 1.2.4 (Level AA) asks for captions on live audio content in synchronized media. A file-based tool does not do live captions; use the platform's live captioning or a live service.
- Read automatic captions against the audio before you publish. Names, numbers, technical terms and overlapping speakers are where they fail. See how to improve transcription accuracy.
- Add what captions need beyond speech. Speaker changes and meaningful sounds are part of captions in practice; an automatic transcript contains speech only, so add them by hand.
- Ship a caption file, not burned-in text, where you can. A separate SRT or VTT file can be switched off, corrected later and translated; text burned into the picture cannot. See SRT vs VTT.
- Check line length and timing. The subtitle checker runs in your browser and has a preset for Netflix's published limits and editable limits for others.
- Test in the player your audience uses. Arabic, Hebrew and Persian in particular can show punctuation on the wrong side; see the SRT punctuation fixer.
- Keep a record. Note the date, who reviewed the captions, and which tool made the first draft. It is cheap and useful if anyone asks.
- Ask counsel about scope. Whether you are a microenterprise, whether the Directive reaches your service, and what your national law adds are legal questions this guide cannot answer.
For standards behind the checklist: the European standard EN 301 549 (version 3.2.1 from ETSI) says in its clause 9.1.2.2 that web content shall satisfy WCAG 2.1 success criterion 1.2.2 for prerecorded captions, and the same for live captions in clause 9.1.2.4. We read the ETSI PDF; we did not find an official EU page that states which standard applies to the Act, so we make no claim about that.
Doing the caption draft with TryScriptorium
What it does: an automatic first draft of the speech with a timestamp on every line, which you correct in the editor, then export as SRT or VTT. What it does not: live captions, sound descriptions, burned-in captions, or a compliance check. Guests get the small model, so expect to correct more than a paid human service would.
- Upload the video or its audio on audio or video to SRT (no account for one file up to 15 minutes and 25 MB, 3 tries a day).
- Choose the spoken language, wait for the transcript, then read it against the video and fix every line that is wrong.
- Add speaker changes and sounds in the editor where they matter.
- Export SRT or VTT, run it through the subtitle checker, and upload the file to your video platform.
Longer files need a free account; see pricing. The guide for platforms is how to add subtitles to a video.
When this tool is not enough
- You need live captions for an event or meeting: use a live captioning service or your platform's built-in feature.
- You need certified or human-verified captions, for example for broadcast or a legal obligation: a human captioning service is the right tool; some are compared on our alternatives page.
- You need a conformity assessment or legal opinion: neither a caption tool nor a blog post supplies one.
Sources
- Directive (EU) 2019/882, EUR-Lex (authoritative text; did not load for our reader on 2026-10-27)
- Directive (EU) 2019/882 as adopted, UK National Archives copy: Articles 2, 4, 31, 32 and Annex I, read 2026-10-27
- the European Commission's accessibility act page
- Web Content Accessibility Guidelines 2.2, W3C: success criteria 1.2.2 and 1.2.4
- ETSI EN 301 549 V3.2.1: clauses 9.1.2.2 and 9.1.2.4
- Kapwing: EAA closed captions guide and Happy Scribe: EAA guide (vendor material, read 2026-10-27)
Checked on 2026-10-27. Not legal advice. We could not read EUR-Lex itself or the European Commission's Q&A on microenterprises that day; anything not listed above is not claimed.