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.