Short form video captions: UK accessibility basics

What to take away

Short form video captions are a practical accessibility measure, but UK law does not prescribe them for every video.

What the Equality Act 2010 means for captions

The Equality Act 2010 contains no captioning rules. It sets duties not to discriminate and to make reasonable adjustments for disabled people. For service providers that duty sits in Part 3; for employers, Part 5. The Equality Act 2010 is a starting point rather than a checklist.

The Act sets no technical caption standard, and Ofcom's broadcast rules do not apply to every social video. WCAG provides a technical benchmark for digital accessibility; the relevant public-sector rules and caption criterion are set out below.

What counts as reasonable depends on the size of the organisation, the cost of the fix and the resources available. Auto-captions with a manual tidy-up are usually cheap enough to be reasonable. Doing nothing is harder to defend.

For service providers, the EHRC's Services, Public Functions and Associations: Statutory Code of Practice explains how the reasonable-adjustment duty works.

This is general guidance. Individual cases need a qualified adviser, usually a discrimination or employment solicitor.

Where Ofcom fits, and where it does not

Ofcom sets accessibility requirements for television and some on-demand programme services it regulates. For television, its Code on Television Access Services covers subtitles, signing and audio description; Ofcom also has accessibility rules for on-demand programme services. A small firm posting Reels or TikToks sits outside that regime.

Platform tooling is a separate question. TikTok, Instagram and YouTube all generate automatic captions. Accuracy shifts with accent, background noise and technical vocabulary such as product codes. Treat them as a draft, not a finished accessibility feature.

What to produce for a vertical video

Most UK small teams can start with two of these: burned-in captions for the vertical edit, plus a transcript on the page where the video is embedded. Vertical framing leaves less room for text, so shorter caption lines work better on a phone. If you also film product footage, the guide to short-form video product demos for UK ecommerce explains how to script the visual steps that captions then describe.

Advertising and data protection when you caption

Captions are part of an advertisement when they promote something. The CAP Code applies to non-broadcast marketing communications, including social posts, while the BCAP Code covers broadcast advertising. The ASA regularly rules on unclear pricing and qualifications, so keep prices and deadlines on screen long enough to read.

Data protection bites when a caption carries personal data. A first name at the edge of frame or a visible order number counts. The ICO's guide to UK GDPR explains lawful bases and individual rights. Permission to film someone is not automatically a lawful basis for that data.

A caption workflow for a small team

The stage that saves the most time is the first. Teams that plan caption lines while writing short-form video scripts for UK brands tend to spend less time fixing auto-caption errors later.

Common questions

Does the Equality Act 2010 require captions on every video?

No. It requires reasonable adjustments where a disabled person would otherwise be at a substantial disadvantage. A short internal clip may need nothing; a public information video with speech usually needs captions.

Do platform auto-captions meet accessibility standards?

WCAG 2.2 Success Criterion 1.2.2, “Captions (Prerecorded)”, is a useful benchmark for prerecorded video with audio. It is not, by itself, a universal legal rule for every social post. Public-sector websites and mobile apps are subject to the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018, which use EN 301 549; its web requirements draw on WCAG 2.1 AA. Auto-captions that mangle key words are not a reliable way to meet the benchmark, even when the platform supplies them.

Does the law differ across the UK?

The Equality Act 2010 covers England, Scotland and Wales. Northern Ireland has separate disability discrimination law, including the Disability Discrimination Act 1995, so check the position there before you publish a UK-wide campaign.

What should a small business caption first?

Start with videos that carry instructions, prices or safety information. Those are the clips where a viewer who cannot hear the audio loses the most.