1.1 Ofcom’s statutory duties require it, amongst other things, to have regard to the needs of persons with disabilities when carrying out its duties. In particular, Ofcom is required to provide guidance to broadcasters on how they should promote the understanding and enjoyment of their services by people with sensory impairments, including people with hearing impairments
1.2 Given these duties, and continuing complaints about the quality of live subtitling, Ofcom consulted in May 2013 (see footnote 1) on proposals to incentivise broadcasters and access service providers to identify and act upon areas for improvement. Following this consultation, Ofcom published a statement in October 2013 explaining that we would ask broadcasters to measure and report on the key dimensions of the quality of live subtitling, and to report on how many pre-recorded programmes had to be broadcast with live subtitles because they were delivered late.
1.3 Shortly thereafter, Ofcom began a two year programme to measure the quality of live subtitling, with a view to identifying areas for improvement and encouraging broadcasters to act upon these. For this purpose, using samples of live subtitling selected by Ofcom from programmes broadcast in October and November 2013, we asked broadcasters to measure the following dimensions of quality