Dun with regards shivakumar r c. first division assistant department of treasury Government of Karnataka. mob/watsapp 9060720937
On Mon, 9 Feb, 2026, 11:30 pm 'Rahul Bajaj' via AccessIndia, < [email protected]> wrote: > 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]. > To view this discussion visit > https://groups.google.com/a/accessindia.org.in/d/msgid/accessindia/CAL6V9AgFu7%2B%2Bkc2UxZgsH5oZgHkpy8u1ncYoAdPuAK86tnhYnA%40mail.gmail.com > <https://groups.google.com/a/accessindia.org.in/d/msgid/accessindia/CAL6V9AgFu7%2B%2Bkc2UxZgsH5oZgHkpy8u1ncYoAdPuAK86tnhYnA%40mail.gmail.com?utm_medium=email&utm_source=footer> > . > -- 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]. To view this discussion visit https://groups.google.com/a/accessindia.org.in/d/msgid/accessindia/CAAdLfM0ETbPvr01E8a-iToaW7rym0GrShFt%3DqHypakvVDxGwkA%40mail.gmail.com.
