International comparisons

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United Kingdom

The United Kingdom’s approach to media access regulation is widely viewed as international best practice.

This approach has seen television access services (including captioning, audio description, and signing) become commonplace over the past fifteen to twenty years, with very high levels of captioning and significant levels of audio description on all major channels.

Through Ofcom, the UK’s media and communications regulator, the UK uses a licensing system whereby statutory (legislated) and regulator-determined targets are built into broadcasting licences.

A breach of access condition is necessarily a breach of licence conditions in much the same way as the broadcast of age-inappropriate material before the watershed is a breach of licence conditions.

The UK uses two mechanisms to ensure that the appropriate targets are required of different broadcasters:

  • An audience threshold of 0.05% of total viewers is required before a broadcaster is required to meet access obligations; and
  • Not more than 1.0% of income is required to be spent to meet those obligations.

The regulations are often increased as the broadcaster becomes more established.

For more information, see our page on access regulation in the United Kingdom.

United States

The United States has taken a quite different approach to regulating access to electronic media, particularly regarding digital technology.

Through Section 508 of the Rehabilitation Act of 1973, the US Federal Government has exploited its large market share by requiring its agencies to purchase accessible information and communications technology equipment. Over time manufacturers have increasingly made their products accessible leading to mainstream access.

This approach has recently been emphasised with the enactment of the Twenty-First Century Video and Communications Accessibility Act of 2010.   

For more information, see our page on access regulation in the United States.

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