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Ministry of Culture and Heritage Media Reform for New Zealand

Posted in Submission, Regional; Tagged Accessibility, Relationships, Parks and recreation; Posted 11 months ago by DPA Less than a minute to read

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To: Ministry of Culture and Heritage
Date: March 2025

 

Purpose

This submission’s core purpose is to advocate for legislative and systemic changes that ensure all media content is fully accessible to disabled people, particularly in light of technological shifts from linear to streaming platforms. DPA aims to address issues of digital exclusion, promote compliance with international and national disability strategies, and ensure the voices and access needs of disabled people are central to the future of media in Aotearoa New Zealand.

Summary of DPA submission

DPA recognises that changes are necessary within the media space due to evolving technology, funding issues, and the need to streamline media regulation and funding. It agrees that ensuring the continuing accessibility of various media formats is essential, especially as the transition occurs from linear to streaming-based broadcasting platforms, to include audiences who experience digital exclusion. DPA highlights that disabled and D/deaf people are primarily affected by digital exclusion, constituting 17% of New Zealand's population. DPA welcomes proposals to mandate captioning and audio description, believing these will help address digital exclusion and are vital for media to be truly accessible to everyone. They view proposals relating to captioning and audio description as the most important.

However, DPA points out that New Zealand is an outlier for having no legislation mandating captioning and audio description, which if implemented, would make New Zealand compliant with the UNCRPD. DPA identifies significant barriers to successful implementation, such as the technology not being fully available on TVNZ+ compared to Netflix. They note that TVNZ and other free-to-air broadcasters currently do not use audio description for live events, leading blind and low vision viewers to miss access to national commemorations and sporting events. DPA also expresses concern about the variability of captioning and audio description quality on streaming services, especially the inaccuracy of AI-generated captions for New Zealand English and Te Reo Māori. They recommend that the need for captioning and audio description enabling technology be addressed by building assistive technology into future procurement contracts. DPA recommends a target of 100 percent of all media content, especially local content, on terrestrial television channels and streaming services, should be stipulated in law, rather than providing access only for stereotypically disability-related content. DPA also does not support the idea of captioning and audio description only being available between certain hours, as this would limit content and perpetuate inequities.

Furthermore, DPA does not support the amalgamation of Crown content funders, specifically recommending that Te Māngai Paho remain an autonomous but parallel media funding body to meet the Crown’s Te Tiriti o Waitangi obligations towards Māori. DPA also expresses disappointment that social media sites, which host user-created content, are not covered by the proposed media regulation.

 

Key Recommendation/Finding:

DPA's primary recommendation is that Government introduce legislation mandating that 100 percent of all media content, especially local content, be available in captioned and audio described formats by 2030.

 

Supporting Statement 1:

Implementing such a provision would ensure New Zealand becomes compliant with the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD), particularly articles 8, 9, 11, 20, 21, and 30, which relate to accessible media information.

 

Supporting Statement 2:

At a practical level, this mandate would enable blind, low vision, and D/deaf people to have equitable access to media, allowing them to fully participate and engage with broadcast and streamed content.

 
 

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DPA Submission 2503 Ministry of Culture and Heritage Media Reform for New Zealand (DOCX)

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