Creating Subtitles: A Step-by-Step Guide to Accessible Videos

Since 28 June 2025, the Barrierefreiheitsstärkungsgesetz (BFSG, Germany's Accessibility Strengthening Act) has applied in Germany and the Barrierefreiheitsgesetz (BaFG, the Austrian Accessibility Act) in Austria. Both implement the European Accessibility Act (Directive (EU) 2019/882). This does not create a subtitle obligation for every corporate video, but it does for many: businesses that let consumers conclude contracts online - from web shops to booking flows - must make videos embedded in those services accessible. Subtitles are a central requirement.

Even so, many companies have not yet made the switch. Often it is not the will that is lacking, but the knowledge: which subtitles are “accessible”? Which format do I need? And how do I create them efficiently, without editing every video by hand?

This guide walks you through the entire process - from the legal requirements to the finished subtitle file.

What the BFSG and BaFG mean for videos

Since 28 June 2025, the BFSG (Germany) and BaFG (Austria) have required accessible digital offerings for certain consumer-facing services - especially online shops and other services through which consumers conclude contracts online. Videos published after the cut-off date as part of such a service need subtitles. At AA, relevant visual information not conveyed by the soundtrack must also be made accessible through audio description. In practice, EN 301 549 with WCAG 2.1 (conformance level AA) serves as the guiding benchmark.

The Accessibility Strengthening Act transposes the European directive (EU) 2019/882 (the European Accessibility Act) into German law. In Austria, this is done through the Accessibility Act (BaFG). For companies, then, the abbreviation matters less than the practical implementation: digital services must be usable by people with disabilities. In practice, the technical benchmark is EN 301 549 with WCAG 2.1, conformance level AA; the applicable national legal requirements remain binding.

For typical media content, the following WCAG criteria are particularly relevant:

• Subtitles for prerecorded synchronized media with spoken content (WCAG 1.2.2, Level A)
• Audio description for relevant visual information that cannot be inferred from the soundtrack (WCAG 1.2.5, Level AA; at Level A, WCAG 1.2.3 also permits a media alternative)
• Text alternatives for prerecorded audio-only content, and a text alternative or audio track for video-only content (WCAG 1.2.1, Level A)

A full transcript is highly useful, but it is not automatically a separate Level AA requirement for every synchronized video.

The laws cover the consumer services they list - in practice, especially e-commerce: online shops, booking and ordering flows, banking, telecommunications and passenger transport services, and e-book providers. Purely informational company websites without an ordering or booking function, B2B-only offerings, internal videos and videos published before 28 June 2025 are not covered. If an old video is materially revised and published as a new version, the exemption should be reassessed rather than assumed. Microenterprises with fewer than ten employees and no more than €2 million in annual turnover or balance-sheet total are exempt as service providers.

In Germany, violations can carry fines of up to €100,000 (§ 37 BFSG), and competition-law warnings may also be considered. In Austria, administrative penalties can reach €80,000, capped at €50,000 for small and medium-sized enterprises (§ 36 BaFG). Separately, the Austrian Federal Disability Equality Act may apply if publicly offered goods or services are not equally accessible because of a digital barrier; claims for damages may then be possible.

Standard subtitles vs. accessible subtitles

Standard subtitles only reproduce the spoken text. Accessible subtitles (SDH) additionally describe relevant sounds, music, speaker changes and the emotional tone. Only accessible subtitles meet the WCAG requirements and thus the requirements for accessible video offerings.

Not every subtitle meets the requirements for accessible video offerings under the BFSG or BaFG. Platforms like YouTube generate automatic subtitles - these are generally not sufficient for legal compliance. The difference lies in the detail:

• Standard subtitles only reproduce the spoken text. They help with low sound or a foreign language, but are incomplete for deaf people.
• Accessible subtitles (SDH) additionally describe relevant sounds ([doorbell], [applause]), music ([suspenseful music]), speaker changes and the emotional tone. They make the entire acoustic context accessible.

WCAG requires accessible subtitles. That means: speaker identification, synchronous display, description of non-speech audio content and sufficient reading time per display.

Creating subtitles: step by step

The most efficient path leads through an AI-assisted transcription as the basis, which is then adapted for subtitle purposes. The workflow consists of five steps:

• 1. Prepare the audio: Extract the soundtrack from your video or upload the video file directly into a transcription tool. Common formats like MP4, MOV, MP3, WAV and M4A are supported by most services. The better the audio quality, the more accurate the transcription - background noise and reverberation significantly reduce the recognition rate.
• 2. Have the transcription created: Depending on the language, audio quality, dialect and number of speakers, modern AI models can produce a useful first draft within minutes. Make sure the tool supports speaker diarization - for videos with several people, identifying who is speaking is important whenever a speaker change or identity is needed to understand the content. The result is a time-stamped transcript with speaker changes.
• 3. Post-process the transcript: Check the AI transcript for errors, especially with proper names, technical terms and abbreviations. Add descriptions for relevant sounds and music in square brackets. Follow the target platform's style guide for line length, block size and display duration. Two lines at most is often a useful editorial rule; the key is a readable display synchronized with the audio.
• 4. Export the subtitle file: Export the edited transcript as an SRT or VTT file. Both contain timestamps and text. SRT is accepted by many platforms and editing tools; WebVTT is designed for HTML5 <track> elements. Which format you choose depends on the intended use (see the next section). In scryp, you can review the transcript in the editor - with automatic speaker diarization available in Pro and Ultra - and export it as SRT or WebVTT without using a second tool.
• 5. Embed the subtitles: Upload the subtitle file to your video platform or burn the subtitles permanently into the video. For websites, the toggleable variant (closed captions) is recommended, so that users can activate the subtitles themselves.

SRT, VTT or burned-in: which format when

The choice of subtitle format depends on where and how you use the video:

• SRT (SubRip): A simple, widely used interchange format. It contains a sequence number, start/end time and text and is accepted by many video platforms and editing tools. It is well suited to platform uploads and handoffs.
• VTT (WebVTT): The web standard for HTML5 video. It additionally supports styling options such as font color, positioning and CSS classes. Recommended if you embed videos in your own player on your website and want to control the presentation.
• Burned-in (open captions): The subtitles are rendered permanently into the video and are always visible. This gives consistent presentation on social media, but users cannot switch them off or customize them. Many platforms also offer their own caption features, with varying support and export options. Correcting burned-in captions requires a new render.

For HTML5 video on your own website, WebVTT through the<track> element is recommended. SRT is particularly useful for platform uploads. Burned-in captions can complement these options, but they do not always replace switchable, customizable captions.

Common mistakes with subtitles

Even well-intentioned subtitles fail the accessibility requirements when typical mistakes creep in:

• Missing speaker identification: For videos with several people, it must be clear who is speaking. Without identification, discussions, interviews and dialogues cannot be followed.
• Display too fast: Subtitles that are visible for only half a second cannot be read. WCAG does not prescribe one universal character-per-second limit; use the target platform's style guide and test the captions with real users.
• Insufficient contrast: White text on a light background is illegible. WCAG requires a contrast ratio of at least 4.5:1. A semi-transparent black bar behind the text solves the problem.
• No sound descriptions: If an alarm sounds or someone laughs and that is relevant to the context, it must be described - otherwise deaf viewers lack a crucial piece of information.
• Automatic subtitles without correction: AI-generated subtitles contain errors. Proper names, technical terms and numbers are regularly misrecognized. Without human review, the subtitles are not reliable.

Data protection when creating subtitles

Corporate videos often contain confidential information - product announcements, internal training, customer testimonials or employee interviews. Anyone who hands the audio track over to an external service for transcription should check where the data is processed and stored.

The GDPR sets clear requirements for processing: a data processing agreement, a processing location within the EU and adequate technical safeguards. For confidential content in particular, client-side encryption offers the strongest protection: the file remains client-side encrypted throughout the workflow.

Checklist: accessible subtitles under the BFSG/BaFG

• All videos with spoken content have subtitles
• Subtitles reproduce the spoken text completely and correctly
• Speaker changes are identified
• Relevant sounds and music are described in square brackets
• Subtitles are synchronous with the audio (no noticeable offset)
• Display duration and reading speed follow the target platform's style guide and have been tested in practice
• The text is legible (adequate size, contrast at least 4.5:1)
• Subtitles are available as a toggleable SRT/VTT file or are permanently burned in
• Automatic transcription has been manually reviewed and corrected
• Data protection is ensured during transcription (DPA, EU processing, encryption)

Conclusion

The BFSG and BaFG make accessible subtitles a genuine compliance topic for many corporate videos - and that is more than a bureaucratic hurdle. Accessible videos reach a wider audience, improve the user experience and strengthen findability in search engines. The most efficient path leads through AI-assisted transcription with subsequent manual review and export as an SRT or VTT file. What matters is that the subtitles do not merely reproduce the text, but make the entire acoustic context - speakers, sounds, mood - accessible to everyone.

With scryp, the workflow can be handled end to end: upload a video or audio file, correct the transcript in the audio-synchronized editor, optionally use automatic speaker diarization in Pro or Ultra, add sound descriptions, and export SRT or WebVTT. The file remains client-side encrypted throughout and is processed in Austria. Even confidential training or product videos remain protected. Eligible new customers can try any plan free for 14 days.

Note: This article serves general information purposes and is no substitute for legal advice in individual cases.