“EN 301 549 vs WCAG” – Study Group Meeting Notes

Date: February 11, 2025
Participants:

• Pär Lannerö
• Sanna Kramsi
• Nadia Törnroos
• Sander Nijsingh
• Erik Gustafsson Spagnoli
• Tobias Christian Jensen

Spoken Subtitles

The group continued discussions on spoken subtitles, referencing the ongoing discussion thread in the GitHub repository: GitHub Discussion #9.

Experiments and Examples:

• Pär shared insights from his experiments with Able Player, which allows toggling and customizing spoken closed captions. Notably, it enables captions to pause the video’s audio when spoken:
  • Pär’s experiments: Understanding Spoken Subtitles – Metamatrix
  • Able Player’s documentation: https://ableplayer.github.io/ableplayer/
• Sander mentioned that in the Netherlands, an accessible video player has been developed by the government, supporting toggling audio descriptions, and downloading separate accessibility assets (video-only, transcript, or audio description). Example video: https://www.rijksoverheid.nl/documenten/videos/2022/10/10/video-tim-ter-haar

Requirements are Unclear:

The group discussed a key question: What are the actual requirements for spoken subtitles?

• Should there be a button to enable spoken subtitles for all users (not just screen reader users)?
• How should these be presented to ensure compliance?

EAA Uncertainties

The group exchanged thoughts on the upcoming EAA, which is set to take effect later this summer. Currently, much remains unclear across different countries.

Observations & Open Questions:

• Sweden:
  • Companies must self-report accessibility shortcomings to the monitoring agency.
  • No official templates exist—only law documents, which are vague about reporting requirements.
  • Uncertainty around public disclosure:
    • How much detail should companies provide?
    • What level of transparency is required?
• Enforcement & Penalties:
  • No clear answers yet on penalties for non-compliance.
  • Question: Will monitoring agencies collaborate across countries or operate independently? Likely the latter.
• Cross-Country Collaboration:
  • The EAA mentions a collaboration group (Article 28) for enforcement coordination, but this group does not appear to have been established yet.

Accessibility of WAD Statements:

• WAD (Web Accessibility Directive) statements are often written in complex, inaccessible language.
• However, the process of creating them forces organizations to engage with accessibility, potentially improving their practices.

3. Upcoming Meetups & Events

Pär shared details on two upcoming accessibility meetups, external to the Nordic Accessibility Community Group, but open to all:

• April 1st – Stockholm (Topic: Accessible Self-Service Terminals)
  • Time: 13:00–17:00
  • Free to attend
• April 28th – Malmö & Online (Topic: Accessible Events)
  • Time: 13:00–17:00
  • Free to attend

4. Homework & Next Steps

• Collect information on each country’s monitoring agency, enforcement expectations, penalties, and collaboration efforts. Put your findings in the GitHub discussion: GitHub Discussion #3
  • Any clarity—however small—is valuable.
  • Goal: For us to be able to map similarities/differences and provide better guidance for those navigating compliance.

Next Meeting:

• Scheduled for March 4th, 2025.