Hi all. As you know, the MIB has issued the OTT accessibility guidelines today. Unfortunately, however, these guidelines are a real setback for the disability rights movement. They have been significantly diluted compared to the draft version circulated in October 2025 and are almost entirely toothless. I have therefore made a draft communication for you to send to the Ministry of Information and Broadcasting to express your anguish and displeasure with the guidelines, should you agree with me. I am sharing the email IDs of the concerned officials along with a draft communication below. Please reply to this message once you have done so. Let us send out at least 50 representations.
email IDs: Send Mail Link [email protected], Send Mail Link [email protected], Send Mail Link [email protected], Send Mail Link [email protected], Send Mail Link [email protected], Send Mail Link [email protected] communication draft: To The Secretary Ministry of Information and Broadcasting Government of India *Subject:* Representation regarding implementation timelines under the *Guidelines for Accessibility of Content on platforms of publishers of Online Curated Content (OTT Platforms) for Persons with Hearing and Visual Impairment* Respected Sir, I am a person with a *visual / hearing [insert as applicable] disability*. At the outset, I wish to place on record my appreciation for the Ministry’s initiative in issuing the *Guidelines for Accessibility of Content on platforms of publishers of Online Curated Content (OTT Platforms) for Persons with Hearing and Visual Impairment*, notified vide Office Memorandum dated 06.02.2026. The formulation of accessibility standards for OTT platforms is a long-awaited and important step towards ensuring equal access to digital entertainment and cultural content for persons with disabilities. However, I wish to respectfully point out a serious concern with respect to the *implementation framework* under the final notified guidelines, which, in their present form, has rendered compliance substantially toothless*, diluted and discretionary*. In this regard, it is submitted that *Clause 4 of the draft guidelines (dated 07.10.2025)* contemplated a *robust and time-bound implementation schedule*, including: - Mandatory compliance for *new content* within *six months* of notification; - A *progressive but mandatory roadmap for existing content libraries*, requiring: - at least 30% accessibility within 12 months, - 60% within 18 months, and - *100% of the content library within 24 months*; and - A clear obligation to submit *quarterly progress reports* to enable monitoring and enforcement from the date of the guidelines being issued. In stark contrast, *Clause 4 of the final notified guidelines (dated 06.02.2026)* provides that: - Publishers shall comply with accessibility requirements for *newly published content* *only upon expiry of thirty-six (36) months* from the date of publication of the guidelines, and that too *in a phased manner [a term which has not been defined anywhere in the guidelines]; and* - With respect to *existing content libraries*, publishers are merely *“encouraged”* to provide accessibility features on a *“best effort basis”*, with no mandatory timelines, milestones or enforceable obligations. The net effect of this shift is that: - Persons with disabilities have *no enforceable right to accessible OTT content for at least three years* even for new releases; and - Accessibility of vast existing content libraries—constituting the overwhelming bulk of OTT content—has been rendered *entirely discretionary*. This approach is inconsistent with *Section 46 of the Rights of Persons with Disabilities Act, 2016*, which mandates that all service providers shall comply with notified accessibility standards *within a period not exceeding two years* from the date on which the accessibility standards are notified. The statutory framework does not contemplate indefinite postponement or optional compliance, particularly in sectors that directly implicate equality, dignity, and participation in cultural life. It is also pertinent to note that these guidelines have been issued *almost a decade after the enactment of the RPwD Act*, and yet prescribe an exceptionally lax implementation framework. Under Rule 15 of the RPwD Rules, accessibility guidelines had to be issued by this Ministry by December 2017, so we are already running 8+years too late. The cumulative effect is that persons with disabilities continue to be excluded from OTT platforms—now a primary mode of entertainment and information—long after such exclusion was statutorily impermissible. While industry stakeholders may have expressed feasibility concerns, such concerns could not have justified a *complete dilution of mandatory timelines*, particularly *without meaningful consultation with disability groups on the issue of implementation and enforceability*. Accessibility is not a matter of charity or convenience, but a statutory and constitutional obligation flowing from Articles 14 and 21 of the Constitution and India’s commitments under the UNCRPD. In these circumstances, I most respectfully request the Ministry to *reconsider and revisit the implementation provisions* of the final guidelines, particularly with a view to: 1. Aligning the compliance timelines with *Section 46 of the RPwD Act, 2016*; 2. Restoring a *mandatory, time-bound roadmap* for accessibility of existing content libraries; and 3. Ensuring that phased implementation remains *meaningful, enforceable and subject to oversight*, rather than discretionary. I remain hopeful that the Ministry will take corrective steps to ensure that the promise of accessibility is realised in practice and not deferred indefinitely. Thanking you for your consideration. Yours sincerely, [Name] -- Disclaimer: 1. Contents of the mails, factual, or otherwise, reflect the thinking of the person sending the mail and AI in no way relates itself to its veracity; 2. AI cannot be held liable for any commission/omission based on the mails sent through this mailing list.. Search for old postings at: http://www.mail-archive.com/[email protected]/ --- You received this message because you are subscribed to the Google Groups "AccessIndia" group. To unsubscribe from this group and stop receiving emails from it, send an email to [email protected]. 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