Done. On Tue, 10 Feb 2026 at 11:45, Shiva Kumar R C <[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]> 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 > <https://groups.google.com/a/accessindia.org.in/d/msgid/accessindia/CAAdLfM0ETbPvr01E8a-iToaW7rym0GrShFt%3DqHypakvVDxGwkA%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/CAB0hRFUYtgTWVGz%2BN-x_9TOCTdEzOZFUfHGeeohJ73xwmNexNw%40mail.gmail.com.
