ATVOD report and next steps

Subtitles missing on over 150,000 hours of programming

It’s almost crunch time. Back in summer 2013, the Government said that three years from then it would consider introducing legislation around the provision of subtitles on on-demand services if it was clear that progress hadn’t been made. That three years is nearly up and the regulator’s new report will be central to the Government’s assessment of progress.

ATVOD report

The final report from the Authority for Television on Demand (ATVOD) (Ofcom took over regulation of on-demand services on 1 January 2016)  gives us the most comprehensive picture to date of the provision of video-on-demand access services (including subtitles) in the UK.

Download the full ATVOD report 2015 

The Government has indicated that it will use this report, among other considerations, to decide whether enough progress has been made voluntarily by the industry, or whether regulation is now needed. We are now urging the Government to respond to the findings by announcing their next steps.

What does the report tell us? Below we pull out the key findings - including some exciting news about improvements promised by providers in 2016 - and outline why the progress made doesn’t go far enough. See our press release for our reaction to the report.

The good news.


The big broadcasters (ITV, Channel 4, Channel 5 and STV) continue to offer a good level of subtitles on their own website players, with Channel 4 increasing the percentage of subtitled programming from 65% to 77%. Overall, 38% (19 out of 50) of those with web players now offer subtitles - an increase of five providers since 2014.

We’ve also seen a small increase in the availability of subtitles on apps and devices, for example we welcome Channel 5’s fantastic achievements in offering subtitles on mobile devices (Windows, iOS and Android), games consoles (PS3. PS4 and Xbox), a Connected TV app (Panasonic), YouView and Roku, EETV, Freesat and Fire TV.

The report also notes the increase in the level of provision offered by Amazon, who offered no subtitles in 2014, and now subtitle over half of their content.

You can find a full breakdown of which on-demand providers offer subtitles, and on which platforms and apps, in the report’s useful table.

The bad news.

ATVOD opens its analysis by stating that video-on-demand content “is simply nowhere near as accessible as broadcast television”, citing the lack of obligations on on-demand services to offer subtitles as a possible cause.

Shockingly, the report shows that 76% of the UK’s 90 on-demand providers still offer no subtitles at all, which represents a tiny increase of 4% from 2014. For the first time, the report gives us an indication of the number of hours of on-demand programming that subtitle users are missing out on, which amounts to over 150,000 hours of inaccessible content over the course of a year. 
Astonishingly, that’s the equivalent of watching the complete seven-series box set of “Mad Men” over 3000 times.

“Stalemate” within the industry

ATVOD highlights the poor subtitling provision by big subscription companies as central to the problem, stating that “there continue to be large gaps in access service provision on the major television platforms such as Virgin, Sky and YouView”.  The report demonstrates that:

  • 85% of Sky’s on-demand content via their set-top box is inaccessible
  • There is no subtitling provision on Sky Go
  • Just one of the 21 on-demand services (5%) offered through Virgin Tivo have subtitles
  • 25% of the on-demand services offered through YouView have subtitles (three out of 12)

Please note that BBC iPlayer is not included in ATVOD’s statistics as they are not a regulated service.

ATVOD states that this issue is due to a  “stalemate” between the broadcasters (content providers) who provide the programmes (e.g. ITV and UKTV) and the set top box operators (platforms) who pull together content from lots of different providers (e.g. Sky and Virgin), and a lack of clarity about whose responsibility it is to make content accessible.

For example UKTV states that “We continue to ask our platform partners for details of the technical specification… but they are not providing us with an answer…” whist Virgin states that its platform is “fully capable of hosting subtitles… but to date we have not received a positive response from content providers”.

Biggest barriers to providing subtitles

The biggest barrier to making on-demand services accessible cited by providers was cost and resources (37%) followed by technical issues (22%), while 18% said it is “not my responsibility” to provide subtitles.

The report reveals that a key technical barrier is the absence of a shared subtitle format, or standard, across the industry, which means subtitles won’t automatically work on different platforms, players or apps, and need to be converted or recreated from scratch. To demonstrate the complexity of this issue, ITV states that the on-demand market is “exceptionally fast moving”, with “no consensus of standards”, and, according to its own analysis, “there are 97 different permutations of on demand video stream types and platforms”.

Disappointingly, the report confirms that neither content providers nor platforms are prepared to take responsibility for ensuring that content is accessible wherever it is watched. However, as ATVOD states, “someone has to pay for the subtitles… to be put into the right technical format for each platform”. It is therefore clear that the implementation of a standardised subtitle format across the industry would greatly support the process of sharing subtitles and therefore increase overall accessibility.

What progress is promised in 2016?


Encouragingly, progress is promised across a range of platforms and devices in 2016:

  • Virgin plans to roll out a new platform which will allow it to “host significant volumes of subtitled assets and should reduce the costs of provision for content providers”.  
  • BT states that it has “funding agreed” to develop access services.
  • ITV reveals plans to add subtitles to its iOS app in the first half of 2016.
  • Channel 4 commits to “supplying subtitling, where there is the technical capability, in line with the voluntary commitment of 100% made for linear services” including YouView within the next six months, Sky+HD set top box by the beginning 2016, and Android apps during 2016.The rollout of subtitles on iOS apps began at the end of 2015.
  • Sky confirms its plans to enable subtitles on Sky on-demand content in 2016, and they state they are working towards enabling subtitles on Now TV.

See the full report for more plans, including from UKTV, STV and Sainsbury’s.

Has enough progress been made?

While some incremental changes have been made, the changes simply don’t go far enough. The industry will not meet the reasonable targets which we, alongside colleagues at RNIB and Sense, called for the Government to set the industry in our report Defining Progress, published in April 2015.

ATVOD’s limited powers have not enabled the industry to advance beyond a ‘stalemate’  which has persisted for a number of years, and it is now clear that intervention is required in order to set required levels of subtitling, allocate responsibility and implement a standard subtitling format.


What’s next?

The Government has previously indicated that, following the report, it will set targets for broadcasters to reach by the summer of 2016. We are now engaging with the Government and supportive MPs to ensure that these targets are published and that a robust benchmark is set for providers to meet.

In the meantime we will be communicating with broadcasters and platforms about the content of ATVOD’s report, and urging them to follow its recommendations, including:

  • “Platform operators should ensure that their platforms are able to support access services and that their technical requirements are understood by their content providers.”
  • “All parties in the supply chain should keep access services in mind when revising contractual arrangements or technical systems”
  • “Content providers should consider adopting EBU-TT as a standard file format for subtitle exchange”

Thanks again for all your support, and watch this space for news!

Read all of ATVOD’s access services reports between 2011 and 2015.



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