Audio description
for TV commercials,
in plain language.

Short answer: the FCC does not require audio description on a TV commercial today. The ADA does not specifically require it on a hosted commercial either. But every major agency QA pipeline, brand procurement contract, and WCAG-compliance vendor now asks for it — so most of the work is happening anyway, voluntarily.

Audio description (AD) is a separate narration track, written and recorded so a blind or low-vision viewer gets the same information a sighted viewer does. It plays in the natural pauses between dialogue or VO. For a 30-second spot, that means roughly 15–40 words of description packed into the gaps.

Do I have to add audio description to a TV commercial?

Not under federal law. The FCC's audio description rule, 47 CFR § 79.3, covers "video programming" — defined to exclude advertisements of five minutes or less. The Communications and Video Accessibility Act (CVAA) extension at 47 CFR § 79.4 covers captioning, not AD. Neither rule reaches a typical :30 or :60 brand spot.

Two notes worth keeping. First, 47 CFR § 79.3(b) requires Top-4-affiliated stations in the top 110 designated market areas (DMAs) to air 87.5 hours of described programming per quarter — but that is measured against long-form programs, not against commercials. Second, 47 CFR § 79.105 is an apparatus rule, not a content rule; it requires consumer devices to decode a secondary audio stream, but does not require advertisers to produce AD.

ADA Title III does not name audio description as a specific requirement for a commercial hosted on a brand site. The general "effective communication" obligation, 42 U.S.C. § 12182, still applies to public-facing video, but the case law has focused on captions; AD enforcement on short-form commercials remains thin.

If AD isn't required, why are agencies still adding it?

Three reasons. First, large brand procurement contracts increasingly cite WCAG 2.1 Level AA conformance, which includes criterion 1.2.5 requiring AD on all prerecorded synchronized media — including commercials living on the brand's own site. Second, agency QA pipelines now flag spots without AD as non-compliant by default. Third, several broadcasters (NBCUniversal, CBS) "recommend" AD on commercials inserted into described programming, and ad-delivery vendors charge to add it after the fact.

The risk model has flipped. Five years ago, AD was an optional add-on requested by accessibility advocates. Today it is the default ask on most enterprise spots, and the conversation in production is about who pays for it and when in the schedule it slots in — not whether to do it.

How do you actually add audio description to a :30 spot?

Four steps. Write the AD script against locked picture. Cast and record a voice talent. Mix the AD audio against the original master. Deliver the mixed master plus a separated AD-only audio stem.

Script: present tense, third person, ~160 wpm

AD script writing follows conventions published by the American Council of the Blind (ACB) Audio Description Project and the DCMP tip sheet: present tense, active voice, third person, voice descriptions before or during visuals (never after), and a pacing ceiling of about 160 words per minute. On a 30-second spot that is an absolute upper bound of ~80 words, but in practice you have far less — description only fits in the gaps between existing dialogue and SFX, which means a typical :30 carries 15–40 words of AD.

Voice: studio recording, broadcast spec

Voice talent records to picture, usually in a treated booth with a producer driving timing against the visible cue list. For broadcast delivery, the final mixed master must hit −24 LKFS per ATSC A/85 (the CALM Act reference standard for US digital TV). Do not confuse this with EBU R128's −23 LUFS European target — ad-delivery vendors will reject a spot mixed to the wrong standard.

Mix and deliver

The final deliverable is typically two files: a mixed master that contains original audio plus AD blended (the version that will air or stream), and a separated AD-only stem for archival and reuse. Some delivery vendors (notably XR / Extreme Reach) carry AD as channels 3–4 on the master upload rather than as a sidecar — meaning the audio layout matters in the deliverable.

How many words of description can fit in a 30-second spot?

Realistically 15 to 40 words. The 160 wpm ACB ceiling is the upper bound for AD narration pace, but the constraint is not narration speed — it is the gap budget. AD only plays in the spaces between existing audio. A music-only spot has more gap; a fast-talking VO spot has almost none.

Practical implication: AD writers do their job before the VO is locked, not after. The right time to think about AD is when the spot is being scripted — if the VO has no gaps, AD becomes essentially impossible, and a brand that has committed to WCAG 2.1 AA will need to recut the spot.

What does AD cost for a commercial?

Public-rate vendors price AD between $7.25/min (3Play Media, standard turnaround) and $36/min (Gotham Lab, broadcast-ready, NYC). All-in cost for non-union production typically lands in the $45–$105/min range when you include script, talent, and mix. Add SAG-AFTRA voice talent on a commercial use cycle and the per-minute figure can climb to several hundred dollars by the time use fees are paid.

The SAG-AFTRA 2025 Audio Commercials Contract sets an off-camera principal session fee around $618 for a recording session, before any use fees. National-cable 13-week use fees add roughly $3,075; 52-week national use fees add roughly $10,125. Pension and health load another ~20% on top. None of those numbers are a per-minute rate — they are a per-session and per-use number that amortizes brutally on a 30-second spot, which is why most non-broadcast and most in-house corporate AD work is non-union.

What deliverables should you expect from an AD vendor?

A finished AD vendor package includes four files: a timecoded AD script (PDF or CSV), an AD-only audio stem (broadcast-spec WAV, 48 kHz / 24-bit, mono or stereo), a mixed master containing original audio plus AD audio blended (WAV, broadcast loudness), and an MP3 reference. File naming is not standardized industry-wide, but the practical norm at most agencies is something like SPOT-NAME_AD_STEM_v01.wav and SPOT-NAME_AD_MIX_v01.wav.

If the spot will run through Extreme Reach (XR) for broadcast distribution, the AD audio sits on channels 3–4 of the master upload in their stereo-plus-AD layout. CTV delivery via VAST tags handles AD differently — the IAB VAST 4.1 spec models captions as sidecars but does not have a standard slot for AD audio, so most CTV ads carry AD as an alternate mixed master rather than a separated track.

Three things to do before your next spot

Set the WCAG floor with your client, write the script with AD in mind, and price AD into the production budget at the bid stage rather than as a post-delivery add-on.

1. Confirm the obligation with the client up front. Most national brand procurement contracts now reference WCAG 2.1 AA conformance. If yours does, audio description is part of the deliverable. Get this on the call sheet before shoot day — not after the spot is approved.
2. Build VO scripts with AD gaps. The cheapest way to add audio description is to leave 3–5 seconds of natural pause across the spot for description to land. Asking the VO to slow down by 5–10% gains the same effect. Locking a wall-to-wall VO and then trying to add AD makes the work two to three times harder.
3. Get the AD vendor on the schedule at color-correct. The script can be drafted as soon as picture is locked. Voice talent can record to a near-final mix. Waiting until final delivery means an extra week of rush charges and a real risk of missing the air date.

Editor's note. Prepared by The Slate, Editorial. Published 11 May 2026. This article reflects the FCC's audio-description framework current as of writing (47 CFR §§ 79.1, 79.3, 79.4, 79.105), the SAG-AFTRA 2025 Audio Commercials Contract Year 2 rate sheet, ATSC A/85 loudness practice, and ACB / DCMP audio-description guidance. It is not legal advice. Brand and agency procurement contracts increasingly impose obligations stricter than federal rules; consult counsel for contract-specific terms.