make available to persons with disabilities the accessibility services “shall (including, but not limited to, subtitles for the deaf and hard of hearing, audio description, spoken subtitles and sign language interpretation) provided by the audio-visual media service provider, for user access, selection, control, and personalisation and for transmission to assistive devices”. Additionally, concerning TVs, two key requirements are missing. Firstly, user controls to activate access services shall be provided to the user at the same level of prominence as the primary media controls. And secondly, the product shall provide a means for effective wireless coupling with sate of the art hearing technologies, such as hearing aids, telecoils, cochlear implants, and assistive listening devices. Section IV on additional accessibility requirements related to specific services: On audiovisual services, the Council text that the accessibility reads “ensuring features of the audiovisual media services as referred in Article 7 of Directive This is completely incorrect because article 7 of the Audiovisual 2010/13/EU…”. Media Services Directive (both the current one in place and the positions of the co-legislators in the ongoing revision) do not include or refer to any particular accessibility feature whatsoever. To solve this, EDF proposes to directly mention the four main access services as in the requirements for TVs, namely subtitles for the deaf and hard of hearing, audio description, spoken subtitles and sign language interpretation. On banking services, EDF would like to stress the importance of adding a requirement to facilitate the understandability of these services, often very complex not only for persons with disabilities and particularly with intellectual disabilities, but for everybody else. Thus, EDF suggests requiring a language which complexity does not exceed primary education level. EDF regrets the exclusion of specific requirements for transport services (Commission proposal Section V), which had been significantly improved in the position. Parliament’s This will make it even more difficult for the provisions on transport services to be implemented and monitored by the Market Surveillance Authorities. EDF notes the inclusion of the new Annex IV on the assessment of disproportionate burden, and hopes that this clarification would help to avoid any misuse of the exemptions provided in Article 12.
“shall make available to persons with disabilities the accessibility services (including, but not limited to, subtitles for the deaf and hard of hearing, audio description, spoken subtitles and sign language interpretation) provided by the audio-visual media service provider, for user access, selection, control, and personalisation and for transmission to assistive devices”. Additionally, concerning TVs, two key requirements are missing. Firstly, user controls to activate access services shall be provided to the user at the same level of prominence as the primary media controls. And secondly, the product shall provide a means for effective wireless coupling with sate of the art hearing technologies, such as hearing aids, telecoils, cochlear implants, and assistive listening devices. Section IV on additional accessibility requirements related to specific services: On audiovisual services, the Council text reads “ensuring that the accessibility features of the audiovisual media services as referred in Article 7 of Directive 2010/13/EU…”. This is completely incorrect because article 7 of the Audiovisual Media Services Directive (both the current one in place and the positions of the co-legislators in the ongoing revision) do not include or refer to any particular accessibility feature whatsoever. To solve this, EDF proposes to directly mention the four main access services as in the requirements for TVs, namely subtitles for the deaf and hard of hearing, audio description, spoken subtitles and sign language interpretation. On banking services, EDF would like to stress the importance of adding a requirement to facilitate the understandability of these services, often very complex not only for persons with disabilities and particularly with intellectual disabilities, but for everybody else. Thus, EDF suggests requiring a language which complexity does not exceed primary education level. EDF regrets the exclusion of specific requirements for transport services (Commission proposal Section V), which had been significantly improved in the Parliament’s position. This will make it even more difficult for the provisions on transport services to be implemented and monitored by the Market Surveillance Authorities. EDF notes the inclusion of the new Annex IV on the assessment of disproportionate burden, and hopes that this clarification would help to avoid any misuse of the exemptions provided in Article 12.