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________________________________
From: [email protected] <[email protected]> on behalf 
of Omkar Pawaskar <[email protected]>
Sent: Tuesday, February 10, 2026 12:19:49 PM
To: [email protected] <[email protected]>
Subject: Re: [AI] OTT Accessibility Guidelines

Hello sir I have also sent the email. Thanks and regards. Omkar Pawaskar.

On Tue, 10 Feb, 2026, 11:45 am Shiva Kumar R C, 
<[email protected]<mailto:[email protected]>> wrote:
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]<mailto:[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]<mailto:[email protected]>,
Send Mail Link [email protected]<mailto:[email protected]>,
Send Mail Link [email protected]<mailto:[email protected]>,
Send Mail Link [email protected]<mailto:[email protected]>,
Send Mail Link [email protected]<mailto:[email protected]>,
Send Mail Link [email protected]<mailto:[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]





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