By not providing a full subtitling service, Irish TV stations could be contravening the Equal Status Act, according to Mr Brian Merriman, head of communications at the Equality Authority. The Act outlaws discrimination in the provision of goods and services on the grounds of, among other things, disability.
The Act mandates that service providers, which include RTE, TG4 and TV3, are obliged to provide a TV service that is accessible to all, including deaf and hard of hearing people.
However, if it was found that the cost for the TV stations of providing access for deaf and hard of hearing people through subtitles was greater than what was considered a "nominal cost", then they might be exempt from doing so, said Mr Merriman.
He said that in the cases of RTE and TV3 it would not be known what a nominal cost would be for them unless a case was taken against them under the Act.
"The nominal cost to a small service provider would be very different to that of a big service provider," he added.
Some may argue that if RTE is awarded a substantial increase in the TV licence fee, the nominal cost for the station of providing improvements to the subtitling service would not be excessive.
In its campaign for amendments to the Broadcasting Bill, the National Association for Deaf People is requesting a minimum quota of 50 per cent of all the broadcasting output of Irish TV stations to be subtitled immediately, to rise to 100 per cent by 2006. This would include five hours' broadcasting a day with sign language.
However, the Irish Deaf Society, which is also campaigning on the issue of TV subtitling, says the demand should be for a 100 per cent subtitling and a 5 per cent Irish sign language service on a phased basis.