European Accessibility Act with Smart TV applications
On the 28th of June 2025, the European Accessibility Act (EAA), governing accessibility for a large range of products and technical offerings, will be taken into effect. As Smart TV applications fall under The Act, you’ll need to ensure that your application implements all the mandated accessibility features. For that reason I’ve asked my colleague, Tom van den Berg, heading up the accessibility department within our team, for some insights on how to best approach the implementation and what to look out for.
What does the European Accessibility Act mean for TV applications?
Tom: “With the European Accessibility Act becoming enforced on June 28th, all applications with end-users in the EU, will need to be made accessible for anyone not able to use applications in a standard way. Whether it is for near-sightedness, being hard-of-hearing, having (color) blindness or any other disability, you should be able to use the application without problems.”
Matthijs: “What type of implementations are we then talking about, when ensuring users with a disability can still use the application?”
Tom: “There are many implementations you can think of, with different implementations covering different disabilities. For those with a hard-of-hearing disability, you for example want to ensure you have subtitles and closed captions so they can still follow the content. With regards to the application itself, we’re more talking about things like text to speech for those with visibility and blindness disabilities, and clear contrast and iconography for a clearer understanding of application functionality.”
Which implementations are mandatory?
Tom: “The EAA is broad and covers a lot of topics about handling different disabilities. What I would recommend, especially for Smart TV applications (but also web and mobile), is to follow WCAG (2.2), or Web Content Accessibility Guidelines. This is a set of guidelines that covers almost all of the EAA, and because it is defined for web content, directly translates into actual technical implementations.
Matthijs: “You mention WCAG 2.2 covers almost all of EAA, what part does it not cover?”
Tom: “Arguably the biggest part of handling the EAA, especially for TV, is text to speech. While on web and mobile most devices have a screen reader built-in, that is not the case on most Smart TV platforms, so it isn’t really a part of WCAG. For TV applications, we need to take extra care and ensure that especially for people with blindness, the text to speech functionality is implemented properly.”
Matthijs: “What aspects does WCAG 2.2 cover that we should be mindful of?”
Tom: “WCAG 2.2 is split up into different levels, A, AA and AAA, which each level adding increasingly accessible options, but also adding extra implementation complexity. In most cases, Level A covers the minimum requirements for the EAA. We personally implement Level AA, to give end users that extra level of accessibility. In many cases it is a very small extra step from Level AA compared to Level A, and we do want all users to be able to use the applications we develop without problems.
Level A goes about most of the basics of accessibility, and some you might already be familiar with through your normal development work. Things like using semantic HTML (H1, H2, nav) for better screen reader support and using alt-texts for descriptive images are part of this level. But also being able to navigate through a website or application with a keyboard is part of Level A.
The next level, AA, expands on the previous level. Where Level A talks about keyboard navigation, Level AA requires a focus indicator to be visible for the currently focused item. Something that Smart TV applications luckily use by default, so that one is easy. A different example is with error messaging. Level A talks about having clear error messages, while Level AA also asks for error-handling solutions to be show to end users. This also applies to level AAA, which yet further enhances the accessibility to a next level.”
You can find all WCAG 2.2 implementation levels and requirements here: https://appt.org/en/guidelines/wcag
Are there any difficult parts with accessibility and Smart TV?
Tom: “Something we’ve mentioned several times now is text to speech. It is the most impactful accessibility implementation, but also the most difficult. As you know, there are many different TV brands that we support applications for, Samsung Tizen, LG WebOS, Titan OS, VIDAA, Android TV, you name it. The unfortunate part is that all of these platforms have slightly different implementations for text to speech, making it difficult to create a standardised approach. While one brand might support all ARIA labels we need for the implementation, another brand might lack suppor for one or two of them. Some brands even have no support for ARIA labels at all, requiring us to find a different solution with for example the Web Speech API.”
Matthijs: “What about creating an accessible design for TV applications?”
Tom: “Most of our applications are actually already largely accessible by default. Our designers have a strong understanding of typical TV design. Things like clear focus indicators, logical TV-remote input, and proper use of text sizes and contrast are already important for TV applications because of the way TVs are used. You’re not sitting directly in front of a screen, so you already need to ensure users can see what they need to see from a bigger distance. It’s definitely something you need to take care of, but in our case it sort of comes standard out of the box.”
How to get ready for the European Accessibility Act?
Tom: “With the EAA becoming mandatory very soon, it’s important for applications (not just TV, but also web and mobile) to be ready. We try to manage that, by executing audits on the applications we develop. Based on an extensive list of criteria, we go through the applications on all support platforms. We mark all of the topics that do and do not follow the required accessibility implementation, and based on that decide on a way forward. In most cases you’ll see that text to speech needs to be properly implemented, but also some contrast things might still have slipped through. Regardless, we use this audit result to define all the required application changes.”
Matthijs: “And then you implement them?”
Tom: “Yes, based off of this list we implemented the required changes that are mandatory with the EAA. After the implementation is finished, we do another audit on every platform to ensure all of the criteria are met.”
Concluding
In conclusion, getting ready for the European Accessibility Act (EAA) is a fantastic opportunity to make sure our Smart TV applications, along with web and mobile platforms, are welcoming and usable for everyone, regardless of their abilities. By diving into the WCAG 2.2 guidelines, we can ensure we’re covering all the bases and making our apps as inclusive as possible. It’s not just about ticking boxes, it’s about creating a better experience for all users, regardless of their disability.
Implementing accessibility features like text-to-speech might be difficult. Each platform, from Samsung Tizen to Android TV, has its quirks, but with a bit of patience and creativity, we can find solutions that work for every platform. And with the European Accessibility Act coming into effect shortly, now is the time to… act ;)
Want to learn more?
Check out some these blogs for more insights!
