Obligation to address insufficient quality of subtitling services

The Finnish Transport and Communications Agency Traficom has reprimanded Sanoma Media Finland Ltd for its failure to meet the quality requirements concerning the obligation to provide subtitling services on the television channel Nelonen. According to law, subtitles must be sufficiently clear and easy to understand for viewers. Traficom has the duty to promote the availability of accessible media services for special groups.

Providing subtitles for television programmes in Finnish and Swedish is important to enable those with impaired hearing to follow the programmes. Subtitles are useful for other viewers as well, including older people and those learning the language. Subtitles must be provided in the original language of the programme, i.e. in Finnish for Finnish-language programmes and in Swedish for Swedish-language programmes. The quality of subtitling services must be high enough to ensure that subtitles are sufficiently clear and easy to understand. The obligation to provide subtitles applies to the Finnish Broadcasting Company (Yle) and the channels MTV3 and Nelonen.    

Major quality issues in subtitles on Nelonen

Traficom requested reports from all operators subject to the obligation. With respect to the channel Nelonen, Traficom detected fundamental problems with equivalence between the subtitles and programme content, the linguistic correctness of the subtitles as well as the readability and comprehensibility of the subtitles. There were also issues with lagging subtitles. 

Based on its investigations, Traficom considers Sanoma Media Finland Ltd to have violated the Act on Electronic Communications Services that requires the implementation of the subtitling service to be of high quality so that the subtitling is adequately clear and comprehensible for the user.

Traficom requires Sanoma Media Finland Ltd to ensure that in future the subtitling service on its channel Nelonen is of high quality. Traficom requires the company to report by 5 August 2022 which measures it has taken following the decision, how the measures have improved the quality of subtitles in practice and how the changes have affected the production of programmes and thereby the quality of the service from the viewers’ perspective.


The Act on Electronic Communications Services was amended at the beginning of 2021 with respect to the provisions concerning programming accessible to people with a visual or hearing disability. The previous quantitative subtitling requirements were supplemented with a qualitative requirement.

Traficom issued guidelines on the accessibility of audio-visual content services on 1 October 2021. The guidelines present the minimum criteria that Traficom considers essential to high-quality subtitling. 

Link to the decision (in Finnish) (External link)


Eliisa Reenpää, Legal Counsel, tel. +358 29 539 0418, eliisa.reenpaa@traficom.fi

Tiina Aaltonen, Senior Specialist, tel. +358 29 539 0526, tiina.aaltonen@traficom.fi