I'd just leave it out of the audio section.

I agree with Ace and KinoNiki.

Quoting T!M:

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But it is available outside of the PiP-feature: although not selectable through the normal "Subtitles" menu, I can flick through the subtitles using the "Subtitle" button on my remote, and as such, I can watch the film without the PiP-stream on, but with it's subtitle stream.

Subtitles which can be selected with the "Subtitle" button (and audio tracks which can be selected with the "Audio" button) while playing the main feature should generally be profiled.

Of course there are exceptions: for example partial subtitles which translate the signs  seen in the film.

Quoting T!M:

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Quoting KinoNiki:

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It's a special feature and we don't list audio tracks for special features.

Except that it's a commentary and we usually do list the audio track for that.

We do list the audio tracks for audio commentaries. Which is why when I see such a listing I would expect to find a normal audio commentary, not a PiP video commentary that can't be listened to unless I select the PiP feature first. And even when a PiP feature is present, there might still be normal audio commentaries on the same disc (Alien for example.) Whenever the same information can mean different things it starts to be confusing. Do we really want to prevent people from knowing which type of commentary it is without checking the disc themselves? It seems better to me if the audio tracks remain reserved for audio commentaries, not secondary video features.

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And I wouldn't tick the subtitle unless the commentary was available as a normal subtitle outside of the PiP feature.

But it is available outside of the PiP-feature: although not selectable through the normal "Subtitles" menu, I can flick through the subtitles using the "Subtitle" button on my remote, and as such, I can watch the film without the PiP-stream on, but with it's subtitle stream.

In that case I believe the subtitle commentary check box could be ticked. But again, it's not clear what it actually means. Is it a subtitled audio commentary? Is it a text only commentary? No, in this case it's a subtitled PiP commentary. I don't like it, but I believe it is allowed within the rules (of course they were written before PiP features existed so I don't know how much that actually means).

Maybe it's time the rules started to address these new features directly instead of trying to patch them into the existing rules for DVDs that don't even have secondary audio and video features.

Quoting T!M:

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But it is available outside of the PiP-feature: although not selectable through the normal "Subtitles" menu, I can flick through the subtitles using the "Subtitle" button on my remote, and as such, I can watch the film without the PiP-stream on, but with it's subtitle stream.

Had you mentioned this in the OP, I am sure the answers would have been different.  While the rules are not specific, I treat subtitles the same as I do audio track...include them when they are selectable via the disc menu, the player's Audio Track selection button or Autoplay when the content is started.

Quoting widescreenforever:

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Can you make mention of this  feature in -  Other Features??

I'd say no, since it can be covered by the Commentary (and/or PIP) check box. 

Per the Rules:  Use the Other free text box for Extras that do not have a specific indicator.