The Broadcast Committee of Advertising Practice (BCAP) has announced an important step towards making television commercials accessible for people with sight loss who rely on audio description (AD) to watch audio-visual content.
But what does the BCAP announcement mean in practice, and does it go far enough?
In their announcement the BCAP made it clear that even though the committee is maintaining its current position of not requiring all commercials to be audio described, it has amended its existing statement on access services.
Addition to the existing guidance for access services:
“Ads which omit material information, making it difficult for consumers to make informed decisions about a marketer’s product or service, are likely to breach the misleading advertising rules in the CAP and BCAP Codes, which require that ads must not mislead by hiding material information or presenting it in an unclear, unintelligible, ambiguous or untimely manner. Limited time does not influence the requirement to provide that information in a clear and intelligible manner: it should be delivered at a pace that allows it to be easily understood.”
The percentage of AD on content produced for broadcast on linear TV and online platforms has grown substantially over the years. However, this growth has not translated into accessible advertising on TV which has continued to remain inaccessible for blind and partially sighted people.
It should be noted that during a focus group on accessible advertising at RNIB last year, most participants who were existing and regular users of AD acknowledged that it wasn’t necessarily the lack of AD that frustrated them the most, which they agreed could be tricky considering the format and short duration of ads, but the lack of understanding among advertisers that they could remove most barriers through intelligent and inclusive design in the first place. Such as by voicing the name of the brand and/ or product being advertised, in the original voiceover and prioritise the information delivered in audio in order of importance for the consumer.
RNIB welcomes this change in the guidance and hopes that UK advertisers will be encouraged by this to reconsider their approach and make their TV ads easier to understand for consumers with sight loss with or without audio description.
However, the question is: could the BCAP have done more? Could they have mandated AD?
The main challenge here is the substantial use of text on screen for the delivery of information such as disclaimers and/or qualifying text often used in ads from the telecom or financial sector. The high word count of these announcements, which are there in the first place to protect consumers, also make it difficult for the ad to be audio described.
The alternative discussed was to signpost consumers to another service such as a freephone number or a website to get more information and explore the deals offered by the advertisers. The regulatory bodies that responded to the call for evidence highlighted the legal and regulatory risks of this alternative which are in place to protect the consumers such as information not readily and immediately available to consumers.
It can be argued that the information in its current form is inaccessible to blind and partially sighted consumers and has been so for many years.
However, RNIB understands the requirement to comply with the UK’s consumer law framework and will continue to monitor that this change in the BCAP guidance will have on the accessibility of TV ads over the coming period.
If you want to find out more, the BCAP’s website has further information on the call for evidence and the alternatives that were discussed. It is available for download from the BCAP website.
If you want to speak to us about this development or AD in general, get in touch with us by calling 0303 123 9999 or email [email protected].