CAP and BCAP recently engaged stakeholders to understand developments in advertising accessibility and the challenges faced by disabled audiences. One of the key themes that emerged from those discussions was the importance of considering accessibility at the start of the creative process, rather than attempting to retrofit accessibility provisions once an ad has been created.
Accessibility provisions such as audio description, closed captions and signing can help make advertising accessible to a wider audience. Where advertisers choose to use such provisions, they should ensure that any material information communicated in an ad is also communicated through those provisions.
This article explains how the CAP and BCAP Codes apply to accessibility provisions in advertising, outlines when information should be communicated through those provisions and highlights resources available to support advertisers in developing accessible campaigns.
What are accessibility provisions in advertising?
Accessibility provisions help a wider range of people understand advertising content. They can make ads more accessible to people with hearing or visual impairments and may include audio description, closed captions and signing.
Audio description
An additional narration track that describes key visual elements, such as actions, settings, body language and on-screen text.
Closed captions
Time-synchronised text that displays dialogue and important non-speech audio, including sound effects, music cues and speaker identification.
Signing
The use of sign language to communicate spoken content and other important audio information.
Where the communication of accessibility provisions misleads, harms or seriously offends audiences, it is subject to ASA regulation under the CAP and BCAP Codes.
The challenges surrounding accessibility provisions have primarily been considered in relation to broadcast audiovisual advertising and audio description. However, accessibility provisions may also be relevant to other audiovisual advertising media covered by the CAP and BCAP Codes, including on-demand programme services (ODPS), cinema advertising, online advertising and some forms of outdoor advertising.
Clearcast offers advice on TV and ODPS advertising, while CAP Copy Advice can provide guidance on ODPS and other non-broadcast audiovisual advertising. The examples below illustrate when information presented in an ad may also need to be communicated through accessibility provisions.
Material information and accessibility provisions
The key consideration is whether information presented in an ad amounts to material information. Material information is information that the average consumer needs in order to make an informed transactional decision about a product, service or offer.
If information is material to a consumer’s decision about whether to respond to an ad, it should be communicated through any accessibility provisions used in that ad. Consumers using accessibility provisions should have access to the same material information as other members of the audience.
For example, if on-screen text contains material information that a consumer needs in order to understand an offer, that information should also be communicated through audio description, signing or any other relevant accessibility provisions included in the marketing communication. If the information does not amount to material information, it is unlikely to be required by the Codes.
The same considerations apply to closed captions. Where material information is communicated through a voiceover, closed captions should also communicate that information.
Hypothetical examples
A useful way to consider this principle is to look at how it might apply in practice with the following hypothetical examples.
Ad 1
The narrator states: “New phone, £199” and prominent text clarifies that the offer is subject to a “48-month contract and 20GB data cap”.
If the ad’s audio description omitted the material information in the second quotation, the ad would likely mislead visually impaired members of the audience.
Ad 2
An ad for a laptop purely involving a price comparison includes superimposed text stating “laptop of your dreams” and “340 stores nationwide”.
As the laptop is available nationwide and the text does not communicate material information that is needed to understand the offer, excluding the information in the superimposed text from the audio description would be unlikely to mislead visually impaired members of the audience.
Stakeholder engagement and what we learned
In 2019, BCAP explored whether it was justified to allow advertisers to provide qualifying information given in on-screen text by alternative means, such as a telephone number with a pre-recorded message, because of time constraints in audio-described TV advertising. Feedback indicated that while blind and visually impaired audiences welcomed greater inclusion through audio description, it was important that they had access to the same material information as other members of the audience at the same time.
In 2025, CAP and BCAP revisited this work and engaged with stakeholders with expertise in access services and the challenges faced by disabled people. The aim was to understand how the landscape had developed and ensure that regulation was not hindering efforts to improve accessibility in advertising.
One of the strongest themes that emerged from those discussions was the importance of accessibility by design. Stakeholders emphasised that accessibility provisions are more effective when they are considered at the beginning of the creative process, rather than being retrofitted after an ad has been created. Taking this approach is more likely to ensure that accessibility provisions can be delivered effectively.
The ASA system has due regard to the Public Sector Equality Duty (PSED), which includes advancing equality of opportunity and fostering good relations between people who have a protected characteristic and those who do not. While the ASA system cannot require marketers to make advertising accessible, it encourages advertisers to consider accessibility from the outset of the creative process.
Stakeholders also highlighted challenges associated with providing audio description within the time constraints of audiovisual advertising. In some cases, claims made in an ad require qualifications that are typically presented in on-screen text. Depending on the nature of the claim, these qualifications can be extensive. However, discussions suggested there may be misconceptions about what qualifications are required in particular circumstances. Advertisers should therefore consider seeking advice from Clearcast or CAP Copy Advice where they are unsure what information needs to be communicated.
Mandating accessibility
Some stakeholders expressed the view that accessibility in advertising should be mandated. However, the ASA system is not in a position to require advertisers to make their advertising accessible.
There is currently no legislative requirement for accessible advertising. Were such a requirement to be introduced, it would more appropriately be established through legislation.
The ASA system stands ready to play its part in facilitating greater accessibility should Parliament choose to explore such measures. In the meantime, and consistent with its due regard to the Public Sector Equality Duty (PSED), the ASA system encourages advertisers to consider accessibility from the outset of the creative process.
