MSMN Analysis
Explainer based on published Coimisiún na Meán Access Rules, AVMSD and European Accessibility Act materials — not accessibility advice for a specific user and not an exclusive interview package.

Accessibility on Irish and European VOD: subtitles, sign, description, and the two clocks

A European viewer who can turn on subtitles for a language they do not speak is living inside a culture habit. A viewer who needs those subtitles, or audio description, or Irish Sign Language, to use the service at all is living inside a rights habit. MSMN’s earlier subtitle-culture piece was about the first. This piece is about the second. Ireland now has two clocks running on the same screen: Coimisiún na Meán’s media-service rules that implement AVMSD Article 7 for on-demand providers, and the European Accessibility Act, in force for the relevant services from 28 June 2025 under S.I. No. 636/2023, which Cnam also polices where the service is access to audiovisual media.

The useful sentence for a household is that “the streamer has subtitles” is no longer a courtesy. It is a layered duty. The unfinished sentence is that a duty to get progressively more accessible is not the same as a duty to be accessible tonight.

Clock one: AVMSD and the on-demand code

The revised Audiovisual Media Services Directive requires Member States to ensure that media service providers make services continuously and progressively more accessible to persons with disabilities, through proportionate measures, with action plans and regular reporting. Ireland’s transposition for on-demand services is no longer a principle on a page. In November–December 2024 Cnam published a new Media Service Code and Media Service Rules for audiovisual on-demand providers — the first time Irish VOD services established here have sat under formal content rules of that kind — alongside revised Access Rules for television broadcasters.

Section 16 of the on-demand Code is the accessibility clause. Providers must take proportionate measures so that programmes on their on-demand services become continuously and progressively more accessible through access services as the Code defines them: typically subtitling, sign-language interpretation and audio description, with quality and user-control expectations sitting in the rules rather than in a marketing bullet. Providers must submit an accessibility action plan to Cnam — the consultation text said within six months of the rules taking effect, then annually. Plans are supposed to state proposed proportions, quality standards and complaint routes, and to show that the provider considered technical capacity and resources. “Proportionate” is the word that will be litigated in slow motion. It is also the word that lets a small Irish catch-up service and a global platform established in Dublin live under the same heading without the same numbers.

The Code’s recitals point at the UN Convention on the Rights of Persons with Disabilities — Articles 9, 21 and 30 — and at the European Accessibility Act. That is Cnam telling industry these files are cousins. A provider that writes an AVMSD action plan and ignores the EAA interface duties has read only one cousin.

Linear television still has the older, tighter Access Rules: published percentage targets and a longer enforcement memory. On-demand is newer and, in the published Irish text, more plan-based than quota-based. European comparative practice is mixed. Some Member States have already put numerical VOD targets on subtitles. Ireland’s first on-demand year is a reporting year. Households should treat the action plan as the public object. If it is not published in a form a user can find, the duty is still a correspondence with the regulator.

Quality is the second half of “we have subtitles.” Unsynchronised captions, burnt-in captions a user cannot resize, description that vanishes on a second device, sign-language windows that the player crops: those are access services that fail the EAA’s transmission-and-control tests even when a file exists in a library. Cnam’s industry notes are deliberately non-prescriptive about design. They are not non-prescriptive about the outcome. A complaint that says “I cannot switch it on” is the enforcement object, not a brand film about inclusion.

Clock two: the Accessibility Act and the remote control

Directive 2019/882, the European Accessibility Act, is a single-market accessibility law for specified products and services. Ireland implemented it as S.I. 636/2023. From 28 June 2025 the relevant obligations apply. Cnam is the designated compliance authority for services providing access to audiovisual media services — the electronic programme guide, the app, the player, the discovery layer that gets you to the programme. The National Disability Authority and other bodies sit on other EAA products. For a viewer, Cnam’s slice is the one that decides whether you can operate the stream.

Cnam’s published industry guidance lists the functional expectations without prescribing a single design: information in more than one sensory channel; compatibility with assistive technology; accessible support services. For AVMS access services specifically, the statutory list is practical. Electronic programme guides must be perceivable, operable, understandable and robust, and must say whether access services exist. Subtitles for deaf and hard-of-hearing viewers, audio description, spoken subtitles and sign-language interpretation must be transmitted, of adequate quality, synchronised, and under user control. If a Schedule 1 requirement does not cover a feature, the Functional Performance Criteria still apply. Exemptions exist and must be decided, not assumed. Cnam will receive complaints, monitor, and take a published “proportionate” enforcement stance.

This is the clock that hits the button, not only the file. A VOD catalogue can have a subtitle asset that the app buries. A sign-language version can exist and be unselectable with a keyboard or a switch. The EAA is the law that says the remote control is part of cultural rights. AVMSD Article 7 is the law that says the programme should keep gaining access services. A household that only watches one clock will be told the other is “a different department.”

What a European user should test on the next Player

One: Can you switch subtitles, audio description and sign language on without a mouse-only hunt? If the asset exists and the control does not, that is an EAA-shaped problem.

Two: Does the programme information say that those services exist before you press play? An EPG that hides accessibility is not a catalogue. It is a guess.

Three: Is the Irish on-demand service publishing an action plan, or only a brand film about inclusion? Cnam asked for the plan. The plan is the document to request.

Four: Are public-service players ahead of commercial apps? They should be. Licence-fee politics that thin access-service budgets are a disability cut even when nobody files them that way.

Public-service players are the test case Europe will quote. RTÉ Player and TG4 Player take public money. If their access-service catalogues lag a well-resourced commercial app, the licence argument gains a disability chapter. If they lead, they become the reference Cnam can point smaller on-demand services toward. Linear Access Rules already taught Irish broadcasters to live with percentages. On-demand should not get a permanent holiday from numbers just because the first year is a plan year.

Subtitle culture, in the earlier pack sense, is how Ireland learned to read European cinema. Accessibility VOD is how Ireland decides whether disabled European viewers are in the audience those policies keep invoking. The unfinished work is to make the two clocks report in public, in numbers a household can check, and not only in a proportionate plan that never becomes a night of television. A right that exists only in a PDF is not yet a remote-control habit.

Sources

• Coimisiún na Meán, Media Service Code and Rules for audiovisual on-demand providers (November 2024): https://www.cnam.ie/app/uploads/2024/11/Media-Service-Code-Rules-Audiovisual-On-demand-Media-Service-Providers-November-2024-2.pdf
• Coimisiún na Meán, Revised Media Services Codes and Rules published: https://www.cnam.ie/revised-media-services-codes-and-rules-published/
• Coimisiún na Meán, Accessibility of audiovisual media services: https://www.cnam.ie/industry-and-professionals/broadcasting-on-demand-digital/accessibility-of-audiovisual-media-services/
• Coimisiún na Meán, Industry obligations (EAA / AVMS access): https://www.cnam.ie/industry-and-professionals/broadcasting-on-demand-digital/accessibility-of-audiovisual-media-services/industry-obligations/
• Irish Statute Book, S.I. No. 636/2023 — European Union (Accessibility Requirements of Products and Services) Regulations 2023: https://www.irishstatutebook.ie/eli/2023/si/636/made/en/print
• EUR-Lex, Directive (EU) 2019/882 (European Accessibility Act): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019L0882
• EUR-Lex, Audiovisual Media Services Directive 2010/13/EU as amended, Article 7: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02010L0013-20181218