As the use of audio description (AD) becomes increasingly common as an additional narration track provided alongside audio-visual media services, the ASA has recently provided clarity that the CAP and BCAP codes (together the Codes) apply to all aspects of advertisements within their remit; including AD or any additional content to improve accessibility such as signing and subtitling.

AD is used to articulate what is happening on-screen for the benefit of blind and partially sighted audience members.  CAP and BCAP understand that it is now becoming more common to use AD in advertising, particularly in broadcast media, and therefore it is important to ensure the regulatory status of AD is clear and the rights of blind and visually impaired members of the TV audience are respected.  

Whilst it is not a requirement for all advertisements to use AD at present, the ASA provides that if AD is used any essential visual elements should be included, for example on-screen text which qualifies spoken claims. Due to this, not all ads may be suitable for AD (for example, if there is a lot of qualifying on-screen text) as the limited time of the advertisement does not negate the requirement to provide all material information which, when using AD, should be delivered in a clear and intelligible manner at a pace that allows it to be easily understood.  Advertisements using AD which omit material information or deliver it in an unclear, unintelligible or untimely manner are likely to breach the misleading advertising rules in the Codes.

AG Comment

When using a form of AD in advertisements, care should be taken to avoid providing unnecessary detail at the expense of material information, ensuring that consumers can make informed decisions about a marketer's products or service.  It should be noted that if a complaint is made to the ASA about an ad using a form of AD by or on behalf of a blind or partially sighted audience member, the ASA may assess only the AD and other audio elements, and not the visuals, against the Codes.  Each element, taken on its own merits, should not therefore mislead, harm or offend.  

Advertisers are advised by the ASA to discuss the addition of audio description to broadcast advertising with Clearcast and to non-broadcast advertising with CAP's Copy Advice team.