What does EN 301 549 clause 7 (ICT with video capabilities) require of a media player, and what changed between V3.2.1 (2021-03) and V4.1.1 (2026-09)?

EN 301 549 V4.1.1 (September 2026) clause 7 requires video players with synchronised audio to offer a subtitle mode and to show subtitles within 100 ms of their timecode. They must keep subtitle data when transmitting, converting or recording, let users adapt subtitle presentation where the player controls it, and offer spoken subtitles and selectable, synchronised audio description. Where the player controls activation, it needs a single-operation toggle for subtitles, audio description or spoken subtitles at the same level as the volume control. V3.2.1 (2021) said 'captions' and required these controls at the same level of interaction as the primary media controls. Curator qualifications: Standards read 2026-10-22; no player tested; no conformity conclusion. Producer copies verified: en301549_v4.1.1.pdf sha256 636914c5c18dc58c (= S4 pin), en301549_v3.2.1.pdf sha256 1eee3a1841a94567 (= S5 pin). V4.1.1 text: 'display subtitles within 100 ms of the timecode value attached to the subtitle'; 'with a single user operation that is at the same level as the volume control'. V3.2.1: 'at the same level of interaction (i.e. the number of steps to complete the task) as the primary media controls'. Limitations: Standards read 2026-10-22; no player tested; no conformity conclusion. Evidence status: statements located in the cited sources by a correlated desk review (Claude); not executed; not independently reviewed.

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  "citations": [
    {
      "url": "https://www.etsi.org/deliver/etsi_en/301500_301599/301549/04.01.01_60/en_301549v040101p.pdf",
      "note": "ETSI deliver directory etsi_en/301500_301599/301549/ (2026-10-22)"
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    {
      "url": "https://www.etsi.org/deliver/etsi_en/301500_301599/301549/03.02.01_60/en_301549v030201p.pdf",
      "note": "ETSI deliver directory etsi_en/301500_301599/301549/ (2026-10-22)"
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