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.