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Newsletter 06/2026 Legal

Tuesday, 16 of June of 2026
Audiovisual accessibility is becoming increasingly integrated into production and distribution

Accessibility is becoming an increasingly important part of an audiovisual work’s journey. Subtitles, audio description and sign language allow more people to enjoy content on a more equal basis, and are also among the legal requirements that apply to certain audiovisual services.

Last May, Spain’s National Markets and Competition Commission (CNMC) published its latest accessibility report, covering 2025. The data shows a positive trend, particularly in free-to-air television, although significant differences between services remain, along with room for improvement in areas such as audio description, sign language and interoperability between platforms.

What the legislation requires

Spain’s General Audiovisual Communication Act sets out different requirements depending on the type of service.

For on-demand audiovisual television services subject to these obligations, at least 30% of the programmes in the catalogue must be subtitled, including those likely to be of greatest interest to viewers. Content with audio description and sign language must also be introduced gradually and given appropriate prominence within the catalogue.

An important distinction should be made: as a general rule, these obligations fall on the audiovisual service provider, meaning the entity that makes the content available to the public. They do not automatically fall on the production company that made a film, series or programme.

When a broadcaster, platform or distributor needs certain accessible versions, these requirements may become part of the materials the production company must deliver. Preparing accessible subtitles, audio description or additional versions requires coordination with post-production and involves costs that should be budgeted for.

The legislation also stipulates that, when a provider distributes content produced by third parties, it must retain any accessibility features already included in that content, provided the relevant interoperable formats are used.

Integrating accessibility from the outset

As with international versions, masters and certain promotional materials, knowing the delivery requirements in advance allows them to be properly factored into the budget and post-production schedule.

If accessibility needs are only raised once production has been fully completed, additional work and costs may arise that were not originally anticipated. It therefore makes sense to review the broadcasting or distribution agreement from the outset: what materials must be delivered, in which formats, and who will bear the cost of preparing them.

Planning for accessibility from the outset makes it easier to incorporate it into the production budget and schedule, avoids unexpected costs at the end of the project and helps content reach more people on a more equal basis.