The strange story of how deaf and blind viewers were left behind by the on-demand revolution

In the fractured world of on-demand TV, subtitles and audio description can become afterthoughts. But is change on the way?

An image of the four boys from Stranger Things

It is no earth-shattering observation to say that the television landscape has been drastically reshaped by the arrival of on-demand TV. But here’s something you might not know: this fundamental shift has been pretty rocky for the deaf and hard-of-hearing and the blind and partially-sighted.

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Did you know that, while the terrestrial channels are legally required to broadcast a minimum proportion of “access services” – that is, subtitles, audio description and visual signing – this obligation doesn’t currently extend to on-demand providers or even to the broadcasters’ own catch-up services?

Did you know that, while many of us are living in an age of “peak TV”, other people are missing out on the TV shows everyone around them is talking about – and it’s leaving them incredibly frustrated?


So what’s the problem with on-demand?

A screenshot of Claire Foy in The Crown waiting to give her Christmas speech, with the subtitle "I've been asked to tell you that they're ready for you" - spoken by her mother

The situation becomes stark when you look at the numbers. An Ofcom survey of UK on-demand providers, excluding BBC iPlayer and the big international giants like Netflix, recently found that 62% of on-demand providers did not offer any access services whatsoever with their programmes. None at all! Not even subtitles! Only 11% had any audio description on offer, and just 8% had some content with visual signing.

But then, even those streamers which did offer access services weren’t offering it in huge quantities. Here’s another surprising statistic: these accessible services subtitled an average of 26% of programme hours, and across ALL on-demand services surveyed, just 7% of programme hours were subtitled.

In the fragmented world of on-demand, accessibility can be hard to predict. Some services are brilliant, to be sure. And then some are accessible if you watch them, say, on a computer – but completely inaccessible on a mobile or smart TV. Some have subtitles and audio description when they air on “linear TV”, but somehow lose them by the time they make their way to catch-up or into the back catalogue of an international streaming service. It’s perplexing and confusing.

“Streaming is a guessing game,” says Joshua Salisbury, who has moderate to severe hearing loss in both ears. Will the content he wants to watch have subtitles? And if so, will they be the kind of subtitles that make things actually worth watching?

This summer he was “obsessed” with Love Island, but there was a problem. “When it aired on ITV2, the subtitles were patchy and very far behind what was actually said,” he explains. “But when the programmes got onto the ITV Hub, the subtitles were somehow even worse – it made it virtually unwatchable for me.

Dani and Jack, winners of Love Island 2018

“Initially there weren’t subtitles when the episodes appeared on the Hub. When they did have subtitles, they lagged further behind than they did with live telly! But it’s also the choice of what’s subtitled. Sometimes it just wouldn’t bother subtitling some of the contestants’ discussions – which leaves you feeling a bit cheated as a viewer.”

Steven Reed, who is visually impaired, was also left feeling cheated after falling in love with an Amazon show.

“I had this really, really horrible experience where I watched the first series of a programme called The Man in the High Castle,” he says. “The first series was audio described, and audio described really well. I’d say it was one of the best audio descriptions I’ve ever heard on the TV. And then I went to watch the second series and there was no audio description at all.”

Through audio description, blind and partially sighted viewers can tune in to what’s happening on screen as a neutral voice narrates the bits between the dialogue: expressions, movements, and everything you need to understand what’s going on. So for example, in Stranger Things you might hear something like: “Police lights flash on the front of the Byers’ house as Officer Callahan stands outside with Joyce and Jonathan.”

Steven tried watching his Amazon show without the AD, but it was hard to follow. “A lot of the scenes are quite dark, and there’s some subtitles as well because there’s some bits in German and Japanese,” he says. “So I’ve stopped watching the series.” (Series one and two are now available with AD via Amazon Prime Video.)

Then there’s another problem: actually accessing the content in the first place – and knowing whether you’ll even be able to watch it – can be tricky. Many viewers tell us they still have to rely on trial and error while searching, or have given up on certain streamers and platforms entirely. Certain websites will have a special page listing accessible content (shout-out to Amazon, Netflix and iPlayer), but not all have made things so easy. And while Netflix “remembers” your preference for subtitles or AD, that’s extremely unusual.

“I know how to do it now, but the process is inconsistent across platforms,” says Sam, who is an AD user. She’s fed up of navigating menus which require so much screen-reading and scrolling and double-clicking and still end in disappointment. “You have to do 12 swipes, and then the thing you want to see isn’t even on that list. It’s quite upsetting!”


On-demand access: the urgent issue

“It became clear to us about three years ago that probably the biggest issue affecting people with hearing loss was the huge gap of there not being subtitles on catch-up and video on demand television,” says Dr Roger Wicks, director of the policy and campaigns team at Action on Hearing Loss.

Some might think: it’s just television – surely there are bigger fish to fry? Surely there are more pressing problems to tackle? But aside from the pleasure of experiencing a brilliant drama or nature documentary or talent show, TV is part of the fabric of everyday life and conversation.

Subtitles are also hugely popular. An estimated 7.5 million people regularly use subtitles in the UK, and over two million subbed programmes are watched on BBC iPlayer every day – so TV clearly remains important for deaf and hard-of-hearing viewers.

A shot of a police scene in series 2 of Unforgotten, with the caption: indistinct chattering in background

Dr Wicks explains: “It’s such a community activity. It’s a bonding activity for friends and family. People talk about it in the work place, it’s part of what people’s lives are. It keeps people connected, and if people can’t follow or can’t understand really key programmes, then it is quite isolating.”

As for the two million people with sight loss, in 2006 research by the University of Birmingham found that 87% of blind and partially-sighted people regularly watch TV and videos or DVDs, while other surveys indicate that they clock up almost as many hours as the average viewer. And 56% said that fully accessible TV and radio would make them feel less socially isolated, according to a survey by the Royal National Institute of Blind People (RNIB).

“Audio description is my eyes, basically, when I watch a film or television,” says Sam, whose current favourites include Mad Men, Grace & Frankie, and The Crown. “When it works, it’s so joyful – I can’t explain how empowering it is. How you feel like you’re just like the rest of society.”


Are legal changes on the way?

When the last big Act that set out access services was passed into law, on-demand TV was just a twinkle in a tech genius’s eye, a distant speck on the television horizon. In the nineties and early noughties, the most pressing issue was to make terrestrial (or  “linear”) TV accessible via subtitles, audio description and signing, and the UK led the way internationally by setting out minimum quotas on broadcast television.

In 2018, that’s not enough.

“The technology has surpassed the legislation,” says Dr Wicks. “Since the last big broadcasting act there has been a huge explosion of on-demand and streaming that really has changed the way people watch television. But there was no obligation on broadcasters to subtitle or audio describe or visually sign their content, like there is for linear TV.”

All this may be about to change. The Digital Economy Act 2017 lays the groundwork for legally requiring access services for on-demand TV, a potentially major development – though precisely what this will mean is still being decided. Earlier this year the UK regulator Ofcom held a consultation, and since April it has been considering what to recommend.

The regulator’s report will go to the government in the autumn, and everyone affected has two big questions; firstly, what suggestions will Ofcom put forward? And secondly, what will DCMS (the Department for Digital, Culture, Media and Sport) actually put into action?


Who’s doing well – and who is behind the curve?

Perhaps unsurprisingly, Netflix is at the head of the pack. On their original content, accessibility is now built in from day one, and even on their back catalogue stuff (like Monty Python or The Dick Van Dyke Show) you’d be hard pressed to find something without at least subtitles.

But then, Netflix is a huge international brand and an on-demand giant, rather than a terrestrial TV channel with a catch-up service bolted on. It doesn’t even come under Ofcom’s control, seeing as its headquarters are officially in the Netherlands, although Netflix has faced pressure from elsewhere; in 2015 it reached an agreement with the American Council of the Blind to dramatically increase its audio description offerings, starting (appropriately) with Marvel’s Daredevil and moving through its catalogue at an impressive speed.

An image from Marvel's Daredevil on Netflix

For similar reasons, perhaps, Amazon is also doing pretty well – especially with its original productions. “Netflix, Amazon – if you look at their original content, you would struggle to find a title that does not have description,” says Sonali Rai, RNIB’s Audio Description Manager. “But they don’t have as many other challenges as our broadcasters have.”

“Our broadcasters” are a mixed bag. BBC iPlayer is ahead of the curve, with a solid offering of audio description and subtitles and Visual Signing. On ITV Hub, 100% of pre-recorded content is available with subtitles, as well as some of the more popular live shows, although audio description and visual signing still aren’t available on every platform. All4 has made big improvements, and Ofcom notes that All4 audio describes over 20% of catch-up programming on its website and app.


Why is this all so tricky?

What could possibly be going on behind the scenes to throw up so many problems? Welcome to the fragmented and disjointed world of on-demand television! Here’s a territory of competing giants, complex arrangements and shifting sands.

For one thing, a lot of on-demand services take much of their content from “third parties”. Netflix scoops up past seasons of shows like Peaky Blinders, Love Island and Death in Paradise – so will those series have access services attached as part of the original package, and on what terms? Or what happens when the BBC acquires an Australian series like Picnic at Hanging Rock? And who is responsible for a film’s subtitles or AD track when it arrives on Sky Cinema?

In its submission to Ofcom, BT reports: “Our main issue remains the lack of content which is delivered with the requisite access service files on. As well as commercial issues, there is a reluctance from some content providers to provide their content in the appropriate formats.” Apparently, some providers want to charge separately for subtitles and AD, rather than including it in the package as they would with the audio track.

And then sometimes, in this whole process, access services just seem to get lost.

“At the moment you have a certain programme on one of the UK channels,” says Sonali. “In a few months you’ll see the same programme on one of the international video on demand services.

“When it’s broadcast in the UK it’ll have audio description. Then once it’s out there in the international territory, it doesn’t have description. Now, that doesn’t make sense.” That’s why the RNIB is pushing for a national register of AD recordings, to keep track of what has been produced, who owns it – and where it is now.

A second issue: the proliferation of different so-called “platforms” across mobile, television sets, desktop computers, apps and set-top boxes has made things infinitely more complex.

According to Ofcom’s research, there is especially “patchy provision” when on-demand shows are accessed through major ‘living room’ platforms such as Virgin and Sky. Games consoles and smart TVs are currently less good for subtitle users; much better are desktop and mobile app versions.

Dolores from Sky's Westworld, standing alone in a dry field with ammunition slung over her shoulder

Others complain that subtitles (and AD) disappear on certain platforms: try using catch-up on your smart TV and that accessible show you were watching may suddenly become completely inaccessible.

One supporter told Action on Hearing Loss: “One might be watching a series and missed an episode. No subtitles on Virgin catch-up. It spoils the whole series.” When it’s previously been aired on linear TV but is not available to the deaf on catch-up, that means deaf people cannot watch TV in the same way as wider society.

“If you use any of the catch-up services on the TV, you don’t get any of the audio description at all,” says Steven, who relies on AD to follow action sequences and facial expressions. “If you do it on a device, on a portable device, then you can get the audio description. But if it’s on the TV it doesn’t follow. I don’t know what the problem is there – but it’s really weird.”

The problem may be this: each version of the show that goes up on each “platform” requires its own format, which means making edits to the audio file for every single one. And not every platform is equipped with suitable technology to start with.

So who takes ultimate responsibility for access services – the on-demand broadcaster who provides the show, or the platform provider who hosts it? “Some providers said that they were not being given access services by content providers (or asked to pay for them),” Ofcom says. “Others said that they were not being asked for access services by platform operators.” Caught in the middle are millions of viewers unable to enjoy some of the most popular shows.

But in defence of the broadcasters, some of these technical and logistical challenges are undeniably daunting.

Sky tells us: “Making subtitles available for on-demand shows isn’t as straightforward as it may seem. Over the past two years, a dedicated team have manually edited, matched and attached subtitles to the on-demand versions of our programmes, before uploading them to our viewing library.” For popular shows, this has involved working overnight to get things up as soon as humanly possible.

Patrick Melrose and his best friend sitting at the airport in Sky's Patrick Melrose

Channel 4 says it is battling the huge variation in delivery and workflow requirements for each individual platform, and for older and newer devices, and notes to Ofcom: “Development and support for increasing number of platforms requires increased resource.” Still, almost a quarter of programming hours on All4 (via the app and website) are now audio described, and when it comes to subtitles Joshua says it has “definitely improved over the past few years.”

Meanwhile at Channel 5 there have been big improvements in audio description. 8.8-9.1% of programming hours on My 5 were accessible to the blind and visually impaired according to Ofcom’s latest figures. That might not sound a lot, but before March 2015 there was literally no audio description.

Another major challenge definitely not unique to Channel 5 is the subtitling of live television. The broadcaster airs live programmes such as the Celebrity Big Brother evictions, but complains that “current technology doesn’t allow for us to take any live-subtitled content and deliver the content with those subs embedded.” So in other words, you’ll see subtitles while the show is going out on Channel 5 – but try to catch up later on My 5 and those same subtitles will not have made the jump.

ITV has also set out the stark issues it faces in the battle to make ITV Hub accessible.

“Linear broadcast is a very mature market, with technologies and services that are standardised and a supplier landscape that is very simple. Providing access services for linear channels is therefore relatively straightforward and economic,” the broadcaster said in its lengthy response to Ofcom.

“By contrast, on demand services are based on emerging and fast-changing and often proprietary technologies, with no consensus on technical standards. Broadcasters are in the difficult position of being dependent on platforms, which are often large companies based overseas, over which they have little influence.”

They reckon there are 97 “different permutations” of on-demand video stream types and platforms, each requiring bespoke editing. “As a matter of simple demand economics, whereas the viewing audiences are considerably smaller on demand than for linear TV, the amount of cost and effort required is considerably larger – it is literally almost 100 times as complicated for an audience that is less than 2% the size of some broadcast channels,” ITV argues.

But while there is a bunch of “cost and effort” involved with all of this, making on-demand TV accessible is not impossible. It’s just difficult.

“Audio description tracks have to be customised to every single different platform, that means it has to be cut over and over again. That’s a technical barrier. However, the barrier actually is commercial,” says Sonali.

“There is a cost for repurposing files, for re-versioning, but that can’t come at the cost of accessibility.” When it comes to catch-up TV, she points out, “The AD track already exists. All you need to do is cut it to a different version. Yes, there is a cost, but there’s a cost for everything.”

Dr Wicks is also unimpressed by the phrase “technical difficulties”. “We think that is spurious, actually, because some broadcasters do it, some don’t,” he says. “The vast majority of the BBC’s iPlayer content is subtitled and actually there’s been some progress with other providers. After we put a bit of pressure on, after there’s been this big signal that the law has changed.”

The RNIB was even blunter in its response to the Ofcom consultation. “If AD does not fit the current workflows of a broadcaster then this is not a technical issue but a procedural one,” the charity said. “And if progress is not being made in this area it is not due to technical difficulties, but rather a lack of motivation or resources being committed.”


Misunderstood: where access services go wrong

Sometimes even when AD and subtitles are available, they miss the mark. “I watch a lot of quiz programmes, and sometimes they’ll describe the most ridiculous things – and not something that’s really quite important,” says Steven. “So they’ll tell me, for instance, that one of the contestants has got a moustache.” That’s something which might admittedly be important to the contestant, but is not wildly important to the viewing experience. Far better to tell viewers about facial expressions than facial furniture.

One recent media storm focused on Netflix’s makeover show Queer Eye, when many deaf and hearing impaired users pointed out that the subtitles did not match the words actually coming out of people’s mouths. Dialogue was summarised and sanitised, removing swear words and cutting things down. “We can tell when the captions don’t match up to the content and it’s frustrating. It treats us as infants and not equal viewers,” says Joshua.

Dr Wicks agrees. “The whole point about accessible television, like subtitles, is it means you can enable viewers to get the same service in a different way,” he explains. “I think this could have been well intentioned, I don’t know. But the idea that you might summarise but also start to censor language, I think is wrong headed in many, many ways. And also it is, whatever the intentions are, providing a second-class service. And actually I think it definitely was deeply patronising to people.”

Queer Eye star Karamo Brown said the comments “break his heart,” promising to push for better subtitles – and Netflix also responded to say they were “fixing it.”

Some of this is down to a lack of understanding of what it’s like to have sight or hearing impairments. That’s something which now seems to be shifting.

In February 2018, ex-Hollyoaks star and filmmaker Rachel Shenton won an Oscar for her short film The Silent Child, starring deaf young actress Maisie Sly as a girl learning sign language for the first time. Shenton gave her acceptance speech both verbally and using British Sign Language, keeping the promise she made to little Maisie and melting hearts across the world. And then – a major milestone – the BBC decided to show The Silent Child on TV over Easter, catching the attention of 3.5 million viewers.

“Deafness is a silent disability that’s not life-threatening and you can’t see it, and it largely flies under everybody’s radar because of that,” Rachel tells us. “To put The Silent Child, on the subject of deafness, in front of a mainstream audience was brilliant for us. Just for the subject alone and to really raise the profile of it.”

She adds: “I feel that the main problem is that people don’t really understand what’s needed. It isn’t a wilful ignorance, it’s just that people don’t understand what is actually required.”

Sam also reckons it’s a matter of increasing awareness and pushing this as a priority. “We know that the broadcasters – it’s not that they don’t want to, it’s just not top of mind always for them,” she says. “And I think when they realise the impacts, the effects that audio description has on over two million people in the UK, why wouldn’t they do it?”


Change is in the air for access services

Thankfully, things are already starting to move forward as viewers make their voices heard. One big complaint for the blind community is that certain sites – like Amazon Prime Video – are virtually unnavigable, so you can’t even find the AD content. “My husband operates the telly when I’m on Amazon Prime, but there’s not that many films. I don’t think we’ve actually ever found a film that’s audio described on Amazon Prime,” Sam, who is visually impaired, explains. So far, Steven has had a similar issue: “You have to search through all the programme description and the cast list and all that sort of stuff to find whether it’s audio described.”

But now Amazon Prime Video tells RadioTimes.com that it has formed a new partnership with the RNIB to share their listings of audio described titles including Goliath, Sneaky Pete and The Marvelous Mrs Maisel, and movies including Star Trek Beyond and Arrival. This list brings them all together in one place on Amazon, and also on the RNIB website. Currently there are around 100 audio described shows and movies – and that catalogue will only grow.

“The majority of shows created by Amazon Studios include English audio descriptions and subtitles, including all new shows,” Amazon says. “We are actively working with studio partners to obtain and incorporate audio descriptions and subtitles for as many titles as possible.”

ITV also has big plans. “We want to make the Hub available for everyone to enjoy,” a spokesperson tells us. Despite the ITV Hub existing on 30 different platforms, efforts are underway to make as many of those as accessible as possible.

“So far we’ve concentrated efforts on subtitles which are now available across virtually every platform, and as we roll out the Hub onto new platforms we’re making sure that subtitles are baked into the roll out,” ITV says. “With both visual signed and audio described, work is already in progress and we know what we need to do to roll them out onto more platforms. AD is already on the android version of the Hub and we’ve planned what needs to be done for visually signed on iOS.”

Then there’s Sky, which has come on leaps and bounds since 2015 when it subtitled just 4% of its on-demand content. A deaf teenager called Jamie Danjoux, fed up of not being able to watch Game of Thrones on catch-up, started a petition which gained more than 27,000 signatures – and since then the situation has dramatically improved, despite ongoing problems with Sky’s NowTV service which they’re still working to fix.

Sky now provides subtitles on 85% of its own shows, including 90% of catch-up shows such as Patrick Melrose and Game of Thrones. Excluding Sky News and Sky Sports News, 30% of content has audio description. “I do most of my programmes through Sky,” says Steven. “It’s really easy to find audio described programmes, as well, because on the on-screen guide they highlight it.”


A brighter technological future?

All of this is particularly frustrating because technology can be such a massive help to the disabled community, so you’d expect the development of catch-up and streaming technology to have made life much easier. Instead, it is blocking many people out.

“It’s weird, because a lot of blind and visually impaired people use these things [mobile devices] in everyday life to assist them,” says Steven. “It is the biggest piece of assistive technology that blind and partially-sighted people use.

“I can put an app on my phone that will give me guided directions to a place, I can put an app on my phone that will read documents to me, that’ll read texts to me. I can put an app on my phone whereby if I’m looking for something in my room that I can’t find, I can access a volunteer anywhere in the world that can look through my camera and help me find it.” But when it comes to on-demand, those innovations fade away.

A shot of a little girl having a procedure in Black Mirror episode Ark Angel

Many issues stem from one problem: the rise of on-demand has been so bitty and fragmented that access services have not been “built in” from the start. Formats have not been standardised across platforms and apps have not been optimised. It’s a bit like buses – not the metaphorical ones that always come along three at once, but actual, literal buses.

“Finally more buses are being built from the beginning with audio visual information in rather than having to retrofit,” Dr Wicks explains. “If you do have to retrofit something, that’s always harder. Thinking about access, thinking about your audience, communication, at the beginning of any piece of technology is vital.”

We are no longer at the beginning of this rapid growth spurt, but as the streaming industry becomes more mature and the technology develops ever-further, the blind and deaf communities have big hopes. Popular ideas include:

  1. “Closed signing” which you can switch off and on in the same way as subtitles, ultimately enabling all programmes to be accessible to British Sign Language speakers without affecting the experience of other viewers;
  2. Screen readers and magnification should be built into all the platforms and properly integrated into apps;
  3. Personalisation – that is, “remembering” a preference for AD or subtitling or signing, and delivering the next episode with this option automatically switched on;
  4. Giving the viewer control over the show’s sound levels.

This last one is a particularly intriguing idea. As the population ages and more and more people experience some degree of hearing loss (an estimated four million by 2050), why not provide an option where important sounds are easier to hear?

The fashion for authentically mumbly period dramas makes life hard for lip-readers and anyone struggling to make out the dialogue. Throw in a bit of background noise or music and many will simply get lost. And sure, sound editors may baulk at letting go of the controls, but it’s not beyond the reach of technology that you could press a button at the bottom of the screen – perhaps in the shape of a little ear – and get an audio track especially adapted to the hard-of-hearing, with the music dialled way down and the dialogue ramped way up.

An example of a dark scene in Netflix's Mindhunter where subtitles are necessary

There is a sense that what is difficult now will, in the future, be a walk in the park as technology and artificial intelligence (AI) shift our ideas of what’s possible. Action on Hearing Loss has recommended ambitious targets of 95% of new and existing content to be subtitled within a decade. “The premise of our proposed targets,” they say, “is that within 10 years and likely sooner, industry will benefit from increasingly sophisticated tools for the generation of access services and of subtitles in particular.”

Today, broadcasters may point to the resources and time and money that goes into access services, but the world is moving quickly – so quickly that parliament will have to consider how to future-proof these regulations so they’re not immediately out of date.


So – what now?

While international streaming giant Netflix is based abroad, all of the UK’s on-demand services are waiting to see what Ofcom comes up with in the autumn when it publishes its “next steps” and “recommendations for government.”

What might those recommendations look like? Many in the hearing-impaired and visually-impaired communities are hoping for some form of quotas, mirroring and perhaps exceeding those for linear TV. It’s generally agreed that the bigger broadcasters should have higher quotas, at least at first; they’re most able to afford it. While the ultimate aim is full accessibility, for now they have suggested a focus on making the most popular platforms and programmes accessible.

But any recommendations will have to take into account all those thorny issues around platforms, and make clear whose responsibility it is to produce access services and actually make them available to those who need them. And how would a quota even be measured if a show has access services on one device – but not on another? And will there be a let-out for “technical difficulties”?

Dr Wicks says: “We’re definitely optimistic that the case has been made, and we’ve got very good rationale behind it. It’s obviously got the weight of Parliament and now government behind it. But obviously there’s that nervousness. There’s no use getting this far if the actual code, the regulation, lacks teeth.

“I imagine Ofcom are being lobbied by certain sections of the industry to dilute the code, and they’ve got to resist that or they won’t be doing their job. When Ofcom finishes it goes back to DCMS, and we just implore them to be courageous and have resolve, and not dilute the code, especially when very spurious reasons are given around ‘technical difficulties’.”

Sonali says she is “really hopeful” for some big changes and has already seen progress. But this will not be easy for the on-demand providers. “I think it’ll be a challenge, if I’m being honest here,” she tells us. “I think it represents a massive, massive challenge at the moment.”

One broadcaster that has already expressed concerns about quotas is ITV. While others may have similar worries, ITV is the only one of the big broadcasters to lay things out in such an extensive public submission to Ofcom for its access services report – raising a number of points discussed at length in this article. Their argument is that badly-drawn legislation could force them to focus their resources on less popular catch-up content instead of the popular shows, and that having to provide set amounts of access services could be a commercial liability.

“Onerous on-demand quotas would slow the expansion of some digital on-demand platforms and lead others to close,” ITV argues. “The UK has led the way in the development of innovative online digital TV services. But each of the underlying platforms and stream types requires continual work and cost to develop and launch the service.

“Without such work there wouldn’t be anything like the range of TV services that are springing up. Access service provision is an important part of this work, but actually getting services launched at all is clearly a top priority.”

A shot of Prince Albert and Queen Victoria with their daughter from the Christmas episode of ITV's Victoria

The argument goes further. “There is no direct comparison to linear TV quotas, because there is a large volume of content that will never attract significant catch-up audiences,” the broadcaster says. ITV is concerned, in particular, about subtitling the catch-up versions of topical shows like Good Morning Britain, which apparently get “tiny” catch-up audiences. Like Channel 5, it’s currently not able to transfer over its live subtitles, and instead would have to get them re-subtitled – a process which takes “at least 48 hours” after the original broadcast.

“These hours of programming would distort our ability to meet any prescriptive quotas and would create unhelpful incentives for us to direct our time and investment into subtitled content that very few viewers would want,” ITV says. “To be completely clear, the perverse effect of quotas would be for us to create subtitled versions of programmes that no one would watch, inevitably diverting resources away from the access services activity our audiences really want.”

There are some real concerns there, and the rules will have to be carefully laid out to avoid those “perverse effects.” But isn’t it better to “bake in” the access services when you launch a new on-demand service, anyway? And is it not possible to distinguish between highly-watched content and niche content and live content?

Either way, it looks like change is coming – and responses from broadcasters indicate they’re taking this seriously. It seems many on-demand providers are currently ramping up their access service offerings and working on app re-designs and rolling out on more devices. Perhaps they are looking towards that new legislation on the horizon, or perhaps they are simply bringing things up to scratch.

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“It was never talked about before,” says Sam. “Years ago you just had to accept it. And now because things are much more accessible, you’re less likely to accept it, because you know how simple it is to be accessible and to be a part of society, and the profound impact it has on you. You kind of don’t want to settle for second best any more.”


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