With the European Accessibility Act (EAA) coming into force in June last year, Malta must subtitle broadcast media for inclusion purposes. Dr Giselle Spiteri Miggiani, an academic who trains students at the University of Malta to become qualified subtitlers, believes that Malta should begin subtitling a minimum quota of media before eventually providing subtitles on most or all productions.
Speaking to The Malta Independent on Sunday, Spiteri Miggiani said that due to this active EU Directive, media productions need to be made accessible to individuals who are d/Deaf and hard of hearing through the use of subtitles. The European Accessibility Act requires all digital products and services to be accessible to persons with disabilities.
For local broadcasters, media houses, and digital service providers, non-compliance with the EAA may lead to administrative fines, remedial measures or service withdrawal.
She said that Malta now has the necessary human resources - via qualified professionals - to subtitle television productions, and so "there is no excuse" to not add quality subtitles, in Maltese or English, on all filmed productions.
"The major players who create media content in Malta need to start providing at least subtitles. I am enthusiastically supportive of the Maltese language dubbing initiatives as well, even though it would be highly preferable for stakeholders to engage formally trained dubbing translators and adapters, to ensure alignment with established industry standards," she said.
Spiteri Miggiani believes it is not feasible to transition from zero to 100% in terms of the amount of television content that should be produced with subtitles. She is proposing a mandatory minimum quota to determine how much content should be subtitled as this practice slowly starts becoming the norm for local television broadcasts in Malta.
"We need to start with at least a minimum quota of local broadcasts, especially the public broadcasting network. An incremental approach, beginning with a defined minimum quota, is both viable and timely, given the availability of a specialised human resource pool capable of delivering high-quality audiovisual translation," she said.
The academic stated that with a "small" minimum quota, the volume of subtitled content can increase slowly over time. She said that this quota can either mark a set percentage of all programmes on television, or perhaps focus on the type of content, or the type of programme, or on works targeted towards certain audiences.
Spiteri Miggiani said that this approach would also help academics like her carry out more research on how subtitles are received while further uncovering local audiences' preferences. This research assists them to ameliorate subtitles for local viewing, through a user-centred approach.
To the UM academic, the end goal here is for people to be able to watch any local or imported production with Maltese or English inclusive subtitles, should they wish. She remarked that Spanish television has been fully accessible via subtitling on all broadcasts "for years". Inclusive subtitles are adequate for persons with hearing loss and go beyond just transcribing what is being said on-screen; on top of the spoken dialogue, inclusive subtitles indicate which character is speaking and feature descriptions of relevant sounds and music (for example, phone buzzing).
There are differences in norms and conventions between subtitles made for the general public and subtitles designed for the d/Deaf and hard of hearing. Spiteri Miggiani is advocating for a single hybrid format of subtitles in Malta that caters to both audiences at once.
"This hybrid approach adopts a 'universal design' philosophy catering to a diverse viewer spectrum, from persons with hearing loss and non-Maltese speakers to those who simply find captions helpful in noisy environments or when audio is muted. It bridges the gap for viewers struggling with difficult accents or articulation, while simultaneously serving as a vital tool for the successful export of local Maltese-language productions to international audiences overseas," Spiteri Miggiani said.
The so-called closed captions or subtitles for the d/Deaf and hard of hearing were originally devised for accessibility purposes, though have since grown in popularity worldwide to the point that even people without hearing loss now prefer watching films and series with subtitles on; this counts for when the media is produced in a language the viewer is fluent in and not. According to Netflix, as of 2022, 40% of all its global users always use subtitles, while 80% use subtitles at least once a month.
Spiteri Miggiani said that according to local studies, over 90% of Maltese respondents claim to watch media with same-language subtitles, though this varies by age bracket; the younger the generation, the more likely that person is to access content with subtitles. This also depends on respondents' preferred mediums to watch films and series; subtitles are seldom offered on Maltese television but are present by default on Netflix and are easily available on other streaming platforms.
Increasing local subtitling has many perks, Spiteri Miggiani stated. Apart from providing sensory access to persons who are d/Deaf and hard of hearing, they can boost language learning and language proficiency as they are a "very powerful didactic tool". Hence, incorporating quality Maltese subtitles could simultaneously serve as a means to promote the Maltese language.
Spiteri Miggiani said that for persons with hearing loss, simply incorporating on-screen sign language interpretations is not enough. She stated that in pre-recorded storytelling entertainment, that is, films and TV series, having a sign language interpreter at the corner of the screen may impinge on the immersive experience and is not adequate for that media, as it is for reported news or live non-fiction programmes. Secondly, she noted that not all persons with hearing loss know sign language, making subtitles a more inclusive solution that caters for a wider audience. Both modalities should coexist harmoniously, she added.
Spiteri Miggiani said that subtitles can be provided either in the same language as what is spoken on screen (intralingually), for example, English subtitles over English dialogue, or in a different language (interlingually), for example, Maltese subtitles over English dialogue or other foreign languages.
With Malta being a bilingual country with Maltese and English, these subtitles can be done locally in either official language.
In her view, subtitles for local content could be offered in Maltese if the media is targeted for native audiences, while English subtitles should be heeded if the media is intended to reach as many people as possible, including the non-native communities across the Maltese islands, such as for urgent public announcements, like the daily Covid-19 updates during the pandemic.
"Prioritising interlingual subtitles would maximise audience reach and include non-Maltese speakers, but intralingual subtitles would also be a useful starting point to enhance local accessibility and engagement," she said.
In the case of future emergency situations, where statesmen must issue press conferences to declare precaution, like what happened during Storm Harry and during the Covid-19 pandemic, Spiteri Miggiani noted that subtitles can potentially be delivered through live captioning or, alternatively, provided within minutes of a broadcast by a qualified translator and subtitler. Maltese-to-Maltese speech-to-text tools are also currently being worked on at the University of Malta that could ameliorate these processes.
In this regard, Spiteri Miggiani also noted that politicians should incorporate subtitles into all their pre-recorded political announcements posted onto social media.
She said that adding subtitles to social media content will reach more people not only for the accessibility reasons already mentioned, but because it will cater to all the people who may view the video with their devices muted.
Maltese television is predominantly produced in Maltese which, at the present moment, is not understood by the growing number of foreigners living in the country. Interlingual inclusive subtitles could bridge this gap, she noted.
She added that intralingual inclusive subtitles, for example, subtitles in Maltese paired over a local production in Maltese, through its enhanced sensory access, could also be helpful for people on the autism spectrum.
Local reception studies have found that Maltese speakers enjoyed using Maltese subtitles more than they initially expected. Warren Taliana (2021) had asked Maltese speakers if they would choose to watch Netflix's hit La Casa de Papel (commonly known as Money Heist) with Maltese subtitles, if they had the choice. Initially, a third of respondents (33%) said they wouldn't. However, after watching the series' pilot episode with Maltese inclusive subtitles, this percentage dropped to just 20%.
Through reception studies, Spiteri Miggiani and the IAM Research Lab, which she founded, have been learning about Maltese user preferences for subtitles and watched media. Leveraging this research, she developed a framework for inclusive subtitling tailored to the Maltese national context, aimed at facilitating linguistic, cultural, and sensory access to media content. These published guidelines offer a standardised approach for media accessibility in both official languages.
One recent study (Cutajar and Spiteri Miggiani, 2026) found that Maltese audiences prefer when vulgar language is toned down or omitted from subtitles, instead of fully respecting the source audio. The tolerance towards vulgar language decreased the older the audience was. In this study, the preferred approach to capture blasphemous language in subtitles was to completely omit them from the shown text.
Spiteri Miggiani specialises in audiovisual translation and media accessibility. As a senior lecturer, she trains her students at the University of Malta's Department of Translation, Terminology and Interpreting Studies to become qualified audiovisual translators skilled in subtitling, dubbing, voice over and accessibility. In collaboration with local stakeholders, including Heritage Malta, as well as students and alumni, she also leads museum accessibility projects that create inclusive audio guides for cultural heritage sites and museums. These audio guides are designed to cater to both blind and partially sighted visitors, as well as the general public.
She stressed that to have functional and high-quality audiovisual translation and accessibility services, it is vital for these to be done by formally trained professionals, such as the University students she trains in the Audiovisual Translation Specialisation stream within the Master in Translation and Terminology. This programme also offers training in technical, literary and tourism-oriented translation, as well as terminology and intercultural communication. She emphasised that being bilingual in Maltese and English is not sufficient to ensure high-quality translations, including subtitles; this principle applies to generally all translation works. She said that quality (or lack thereof) significantly impacts viewers' and readers' immersive experiences and their engagement with the content.
"It's not just a matter of translating from Maltese to English and just sticking a bunch of words on screen. There are certain criteria, linguistic and technical parameters, and you need trained professionals to do this," Spiteri Miggiani said.
Qualified subtitlers ensure quality standards in subtitling by ensuring that subtitles are legible, that reading speeds are adequate, and that the translated content is linguistically and culturally accurate.
Spiteri Miggiani said that if certain quality parameters and guidelines aren't followed while creating subtitles, then "the subtitles are not going to be functional, they're not going to be useful" and "automatically, you're going to break the experience for the viewer - it's a make-or-break situation". Having low quality subtitles makes it difficult for the audience to follow what is being said and what is happening on screen and renders the linguistic and sensory access they are meant to provide as fruitless. Some of her former audiovisual translation students have also established the AVTMA Association (Audiovisual Translators Malta Association) to raise awareness about this vital practice and service.
She continued that if users have bad experiences with subtitles, then they will be put off from using them again in the future to avoid repeating this "unpleasant, stressful" experience. The same can be said for dubbing, voice-overs, and so on, as "it's not something that can be improvised".