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Audio description in WCAG 2.1 AA success criterion 1.2.5

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From: Steve Green
Date: Apr 23, 2021 12:07AM

This question relates to the common situation where there are no pauses in the audio track into which an audio description could be added. I welcome everyone's thoughts on what is turning out to be a huge area of uncertainty as UK organisations finally start to address the accessibility of video content.

My view is that it should be a AA non-conformance if an audio description is required, but there are not sufficient gaps in the audio track and the client is not willing to create an extended audio description version (which is a level AAA requirement). However, I can't find anything in WCAG or elsewhere that supports this view.

WCAG 2.1 AA success criterion 1.2.5 requires that an audio description is provided for all prerecorded video content in synchronized media. There is an exception for a single talking head, but we can ignore that for the purposes of this question.

As far as I can tell, the Understanding page and techniques do not explicitly address the situation where there are no pauses in the audio track into which an audio description could be added.

Many consultants and organisations have written explanatory articles about this success criterion, and every one of them either avoids the issue completely or states that the success criterion is automatically met if there are no pauses in the audio track into which an audio description could be added.

An example is https://www.visionaustralia.org/community/news/2019-08-23/wcag-confusion-around-audio-description-0, which contains a flow chart halfway down the page. It explicitly states that if there is no room for audio description, it's a pass at level AA, although a media alternative is still required to pass level A.

This seems like a perverse interpretation of the success criterion. If it's correct, it means that video creators can meet level AA while avoiding the need for audio description by ensuring that there are no gaps in the audio track. How can that possibly be right?

Steve Green
Managing Director
Test Partners Ltd