What if you used excerpts from Shakespeare for subtitles, regardless of the video's actual content?
By this measure, I'd expect SUBtitles to be under the damn video, not overlaid on it.
https://www.w3.org/WAI/WCAG21/quickref/?versions=2.0#qr-medi...
Failure F8 seems relevant to the loophole: https://www.w3.org/WAI/WCAG21/Techniques/failures/F8.html
If there are some mistakes (due to sloppy or autogenerated speech to text) it might work but not if it's totally wrong