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From: Jonathan Avila
Date: Mon, Sep 13 2021 8:46AM
Subject: EN 301 549 Video requirements discussion
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Hi all,

EN 301 549 criterion 7.1.5 indicates that subtitles and captions need to be spoken. This requirement is aimed at making sure that foreign language subtitles are available to people who are blind or visually impaired. The requirement seems to use the word "sub titles" in the heading but in the actual criterion seems to state "captions" and also uses the word "captions" in Appendix C for test steps. This would seem to indicate that spoken captions could be interpreted as needed for all web content that has captions or subtitles under EN 301549 V3.1.1 (and that are programmatically available ).

Is there any different interpretations of this requirement for web sites? Even if the requirement is for sub-titles only it would seem that you'd have to implement some approach where the sub-titles could be announced either through a button to speak them in an audio track or by using a live region to have the screen reader announce them. The latter being difficult in some situations due to timing.

Also criterion 7.1.4 indicates that captions need to be adjustable to user settings - the criterion lists some items that can be used to contribute to meeting the criterion - but doesn't clearly state what is or is not actually required to meet it. While all of the items listed are useful including being able to change the font outline, color, size, background, and opacity - it fails to state explicitly if all of those are actually required. So it would seem that all web video players would need to support some level of customization to meet this criterion but there may be inconsistency in how it is interpreted.

Jonathan

From: Patrick H. Lauke
Date: Mon, Sep 13 2021 12:55PM
Subject: Re: EN 301 549 Video requirements discussion
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On 13/09/2021 15:46, Jonathan Avila via WebAIM-Forum wrote:
> Hi all,
>
> EN 301 549 criterion 7.1.5 indicates that subtitles and captions need to be spoken. This requirement is aimed at making sure that foreign language subtitles are available to people who are blind or visually impaired. The requirement seems to use the word "sub titles" in the heading but in the actual criterion seems to state "captions" and also uses the word "captions" in Appendix C for test steps. This would seem to indicate that spoken captions could be interpreted as needed for all web content that has captions or subtitles under EN 301549 V3.1.1 (and that are programmatically available ).
>
> Is there any different interpretations of this requirement for web sites? Even if the requirement is for sub-titles only it would seem that you'd have to implement some approach where the sub-titles could be announced either through a button to speak them in an audio track or by using a live region to have the screen reader announce them. The latter being difficult in some situations due to timing.
>
> Also criterion 7.1.4 indicates that captions need to be adjustable to user settings - the criterion lists some items that can be used to contribute to meeting the criterion - but doesn't clearly state what is or is not actually required to meet it. While all of the items listed are useful including being able to change the font outline, color, size, background, and opacity - it fails to state explicitly if all of those are actually required. So it would seem that all web video players would need to support some level of customization to meet this criterion but there may be inconsistency in how it is interpreted.

Have to admit that these criteria feel very much like they were crafted
for actual operating systems/hardware devices, and not much time was
spent hammering out what the repercussions for web-based content would
be...sigh.

P
--
Patrick H. Lauke

https://www.splintered.co.uk/ | https://github.com/patrickhlauke
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From: Steve Green
Date: Mon, Sep 13 2021 4:52PM
Subject: Re: EN 301 549 Video requirements discussion
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The solution to all these issues would be to use open captions because there are exemptions for captions that are "displayed as unmodifiable characters". Of course that would be a terrible solution, but the bad drafting of the standard forces you down that route if you want to claim full compliance.

I thought that only clause 9 applied to websites, but I can't find anything to support that assertion even though it would seem to be obvious. It is possible that other legislation that refers to EN 301 549 only requires websites to comply with clause 9. That said, the UK public sector website accessibility regulations contain no such restriction, yet the Government Digital Service interpret them as only requiring conformance with WCAG 2.1 AA.

Steve Green
Managing Director
Test Partners Ltd

From: David Engebretson Jr.
Date: Mon, Sep 13 2021 5:38PM
Subject: Re: EN 301 549 Video requirements discussion
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Curious; do captions offer the ability to put a span around words with a language change?

For instance; if someone changes languages during a video, can plain text captions inspire a change in the TTS that may be voicing the captions?

Thanks for your expertise,
David

From: Jonathan Avila
Date: Mon, Sep 13 2021 8:57PM
Subject: Re: EN 301 549 Video requirements discussion
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Beyond Chapter 7, there are many generic requirements from Chapter 5 that apply as well (from the standards without looking at this from the lens of national law). Even a few from Chapter 11 software would apply to web based software (e.g. 11.7, etc.), and other chapters as well. Refer to table A.1 for a mapping of what's covered under web. Unfortunately there also seems to be a disconnect between what some organizations consider applicable and what is listed in Table A.1 because the wording in the standard is less restrictive than the mappings.

Jonathan

From: Detlev Fischer
Date: Mon, Sep 13 2021 10:34PM
Subject: Re: EN 301 549 Video requirements discussion
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Hi Jon,
In version 3.1.1 of the EN 301 549, 7.1.5 and 7.1.4 are not referenced in Annex A of the EN as applicable to either web content (clause 9) or software (clause 11) so I don't see that they would apply at all?
Best,
Detlev

Sent from phone

> Am 14.09.2021 um 00:52 schrieb Steve Green < = EMAIL ADDRESS REMOVED = >:
> The solution to all these issues would be to use open captions because there are exemptions for captions that are "displayed as unmodifiable characters". Of course that would be a terrible solution, but the bad drafting of the standard forces you down that route if you want to claim full compliance.
>
> I thought that only clause 9 applied to websites, but I can't find anything to support that assertion even though it would seem to be obvious. It is possible that other legislation that refers to EN 301 549 only requires websites to comply with clause 9. That said, the UK public sector website accessibility regulations contain no such restriction, yet the Government Digital Service interpret them as only requiring conformance with WCAG 2.1 AA.
>
> Steve Green
> Managing Director
> Test Partners Ltd
>
>
>

From: Steve Green
Date: Tue, Sep 14 2021 1:45AM
Subject: Re: EN 301 549 Video requirements discussion
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7.1.5 and 7.1.4 have been added to table A1 in EN 301 549 version 3.2.1, which is the latest version.

Steve