Does EU Accessibility Compliance Require Swahili Captions? What the Law Actually Says About Language

Short version: the EU Accessibility Act doesn't hand you a list of required languages. Instead it requires captions and audio description to be provided in the language of the market you're serving - which means the real question isn't "does the EAA require Swahili," it's "who is your actual audience, and what language do they need."

The Act doesn't name specific languages

We covered the core EU Accessibility Act requirements in an earlier post. One detail worth its own explanation: Directive (EU) 2019/882 doesn't publish an exhaustive list of "these are the required caption languages." The obligation is per-market: accessibility features need to be available in the official language(s) of each EU member state where the product or service is actually offered, and the requirement follows the audience, not the language the content happened to be produced in originally.

What this means in practice

If you're a Kenyan organization publishing content that reaches an EU audience - an NGO with EU donors and partners, an education platform selling into Europe, a media outlet with an EU-based diaspora audience - the compliance question isn't really about Swahili as a language in the abstract. It's about whichever EU market you're actually reaching and what that audience needs to use your content. A French audience needs accurate French captions; that obligation doesn't disappear just because your original recording is in Swahili or English.

Where Swahili does become directly relevant: reaching the actual Swahili-speaking population inside the EU (a real and growing diaspora audience), or under Kenya's own Persons with Disabilities Act, 2025, which is a separate law with its own separate obligations for anyone broadcasting inside Kenya.

The one requirement that doesn't change by language

Whatever language you're captioning into, the EAA's quality bar is the same: captions and audio description must be synchronized, accurate, and user-controllable - "auto-generated" isn't automatically good enough if the accuracy is low. That part of the law doesn't get more or less strict depending on which language is on screen, which is exactly why a human-review step matters as much for a French caption track as it does for a Swahili one.

FAQ

Do I need Swahili captions to be EAA-compliant?

Only if Swahili speakers are part of the actual audience you're serving in the EU. The Act follows the market and the audience, not a fixed language list - talk to a lawyer covering your specific market if this is a real compliance question for your organization, not just a blog post.

Does this apply differently to Kenya-based organizations?

The EAA applies based on the market you reach, not where you're incorporated - see our earlier post for how it interacts with Kenya's own Persons with Disabilities Act, 2025, which is the law that actually governs broadcasting inside Kenya.