EFHOH’s latest report highlights critical gaps in implementing Article 7 of the Audiovisual Media Services Directive (AVMSD), a cornerstone of EU initiatives and the European Strategy for Rights of Persons with Disabilities. 

After concluding the legislative process in 2018, member States were required to transpose the AVMSD into national legislation by September 2020. Throughout this process, EFHOH played an active role, collaborating with broadcasters and environmental NGOs to advocate for stronger accessibility provisions under Article 7. 

EFHOH has also previously conducted two reports on the state of subtitling in Europe. The first report on the state of subtitling access in the EU was published in 2011 and the second report followed in 2015. 

To assess the involvement of hard of hearing organizations in the consultation during the transposition of the directive, EFHOH conducted a new survey from October to December 2024 among its members and experts across seven European countries. The findings revealed that hard of hearing organizations were largely excluded from national consultations.  

Over 80% of respondents reported inaccessible consultation processes, with minimal provisions like real-time captioning or assistive listening systems. This lack of engagement has contributed to inconsistent improvements in television accessibility across Europe, with many countries falling short of ensuring meaningful progress. 

The lack of consultation with EFHOH members on access services and innovative technologies, combined with the absence of minimum accessibility standards, is a serious concern. 

EFHOH calls for stronger enforcement of accessibility standards and greater inclusion of the hard of hearing community in shaping policies that impact their lives, such as the AVMSD. Read the full report here: AVMSD Implementation in Europe