Atten­tion indie film­mak­ers: Your bud­get isn’t near­ly big enough and it just got a lot hard­er to get into iTunes. Why? Acces­si­bil­i­ty, lan­guage, and rat­ing requirements.

1) As of March 2014, Apple iTunes (and pre­sum­ably oth­ers) will require your film to have Closed Cap­tion­ing. It could get bounced out if you don’t comply.

2) For­eign ter­ri­to­ries will now require the film and all trail­ers to have sub­ti­tles, and all art­work and meta­da­ta to be ful­ly in that language.

3) You have to now get your movie rat­ed if you want to dis­trib­ute in the Unit­ed King­dom, Ire­land, Aus­tralia, and New Zealand.

And this is going to cost you…

First­ly, let me just say that I am not at all com­plain­ing about acces­si­bil­i­ty require­ments. I think they are a good and nec­es­sary thing. I just hadn’t giv­en it much thought as a hard require­ment for self-distribution.

Closed Captioning

These new terms came about in part because of an NAD vs Net­flix law­suit and the CVAA.

The NAD (Nation­al Asso­ci­a­tion of the Deaf) filed the law­suit against Net­flix to get 100% of the library avail­able to hearing-impaired view­ers and it seems that Net­flix has been pret­ty good about it.

This was fol­lowed up by the CVAA, or the 21st Cen­tu­ry Com­mu­ni­ca­tions and Video Acces­si­bil­i­ty Act. This was sup­posed to be in full effect by Sep­tem­ber 30, 2013, to have all pre-recorded pro­gram­ming for inter­net dis­tri­b­u­tion con­tain closed cap­tion­ing. It looks like things have slid to March of 2014, at least for iTunes, with full com­pli­ance by June 2015.

Oh, and the price? If you are unable to do it your­self, expect anoth­er expense in the $800 range. And do not rely on auto­mat­ic machine-translations unless you want non­sense and gib­ber­ish. Watch this video to see how bad it will be.

Subtitles and Artwork

Death To Prom SubtitlesThere just is no sim­ple solu­tion for sub­ti­tles. It is time con­sum­ing and will cost you mon­ey if you need more than one or two lan­guages for your film. On TRIUMPH67 we were able to call in some favors and have Ara­bic and French trans­la­tions done, but we had access to native-speakers who had time on their hands. It will be chal­leng­ing regard­less because even if you find vol­un­teers, do you have a sec­ond per­son to do a qual­i­ty check and ver­i­fy the work? Will your slang, idioms, and col­lo­qui­alisms actu­al­ly make sense?

Do you actu­al­ly have all the art­work lay­outs and project files? If you had some­body else do the posters, trail­ers (with burned-in sub­ti­tles), post­cards, discs, and the like, expect to ask them once again to do more work (either for pay or trade). Or, you will have to do it all yourself.

What about doing it lat­er? If these cap­tions and lan­guages are just a text file, couldn’t you just add them as you need them? Maybe, maybe not. It appears from sites like VHX and Dis­tri­fy that there are meth­ods of adding them as-you-go, but with iTunes it isn’t yet clear. I have been told in the past that adding sub­ti­tles after you are already list­ed in iTunes might require you to go through the entire sub­mis­sion & qual­i­ty check process once again (along with the costs), but then I’ve recent­ly been told that as long as you have all the assets it might be just anoth­er $50–200 per coun­try (note: await­ing 2nd con­fir­ma­tion on this).

Film Ratings

In terms of get­ting your film rat­ed by an offi­cial film board (i.e.: G, PG, PG-13, R, etc), you do not cur­rent­ly have to do this in the U.S. or Cana­da, but it is required in the U.K. ($400), Ire­land ($300-$1100), Aus­tralia ($700), and New Zealand ($80-$900). This will also take a cou­ple of weeks more time in your sched­ule. And do you have to pay full price to resub­mit if you need to appeal the rating?

Are there any valid alter­na­tives? I wish there were. Cer­tain­ly some very good and accu­rate rat­ings are being done over at Com­mon Sense Media. I have two chil­dren and these rat­ings are so much more use­ful than MPAA rat­ings. Plus, when con­sid­er­ing what my two chil­dren watch, I per­son­al­ly find a cuss word or the sight of a breast a lot less offen­sive than see­ing 400+ peo­ple be killed in 90 min­utes.

A start-up that hasn’t seen much trac­tion yet is VoMeR, a free and open-source sys­tem of Volun­tary Media Ratings (hence the name). I’ve seen some peo­ple com­plain that we shouldn’t even have to do this, that it is a form of self-censorship (on some lev­el, yes). But it is help­ful, in the same way that food ingre­di­ent labels are help­ful, should you choose to actu­al­ly read them. You prob­a­bly should know what you put into your brain as well as your body.

What about the notion that we should just be able to declare our films “unrat­ed” and release them into the world? I tend to agree with this idea. But then if you are rely­ing on this approach, under­stand that your film could be cor­doned off into the “unrat­ed” sec­tion of iTunes (or oth­er plat­forms) and parental con­trols that set restric­tions for view­ing could mean your film, inno­cent as it may be, won’t be seen by your audi­ences since it is lumped in with graph­ic torture-porn films that get released unrat­ed (for example).


The best thing to do, at this point, is to plan anoth­er 3–4 months of post-production once your film is fin­ished, with the nec­es­sary bud­gets, to pro­duce the mate­ri­als required. Or get savvy about how to do it your­self. Take your final cut of the movie and load it into the free AegiSub and make a native-language tran­scrip­tion. This result­ing text file can be sent to your multi-lingual team for trans­la­tions. Once com­plete the sub­ti­tles will need to be an .SRT file and the cap­tions will need to be an .SCC file. If you want one soft­ware tool to do it all, spend the mon­ey ($370) and get Anno­ta­tion Edit.


Jere­my Wilk­er is the co-director/producer and cin­e­matog­ra­ph­er of Death To Prom. His oth­er film projects include TRIUMPH67 and Type­face. Fol­low him @tweak.