Accessibility Guidelines Issued to OTT Platforms

The Ministry of Information and Broadcasting (“MIB”) issued the Guidelines for Accessibility of Content on Platforms of Publishers of Online Curated Content (OTT Platforms) for Persons with Hearing and Visual Impairment on February 6, 2026. The guidelines apply to the “publishers of online curated content” as defined under Section 2(u) of the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. The guidelines are intended to strengthen accessibility of digital content for persons with disabilities and align India’s OTT ecosystem with its commitments under the United Nations Convention on the Rights of Persons with Disabilities (“UNCRPD”), the Rights of Persons with Disabilities Act, 2016, and the Sugamya Bharat Abhiyan (Accessible India Campaign).

The framework also builds upon the Accessibility Standards for Persons with Disabilities in Television Programmes issued in 2019 by the MIB, the Code of Ethics for online curated content under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and an advisory issued in April 2025 urging OTT platforms to comply with the provisions of the Rights of Persons with Disabilities Act, 2016. The guidelines provide an enabling framework to support the development of a culture and practice of accessibility of content by publishers of online curated content. They are not restricted only to the content itself but also extend to the information and other support needed by persons with disabilities to access and enjoy such content.

The guidelines prescribe specific accessibility standards, including the provision of audio descriptions in a concise and comprehensible format, as well as captions that are accurate, synchronized, and complete, with proper spelling and grammar. Requirements relating to caption colour, positioning, and formatting have also been specified. Additionally, Indian Sign Language interpretation must be provided through interpreters in a picture-in-picture format, ensuring clarity and accuracy.

Recognizing practical and operational challenges, certain exemptions have been provided. These include live and deferred live content, audio-only content such as music and podcasts, and short-form stand-alone content, including advertisements. Platforms have been granted a period of 36 months from the publication of these guidelines before the implementation commences. Following the expiry of this 36-month period, publishers are required to progressively implement the guidelines in a phased manner. From the end of the 36-month period, publishers must also begin submitting a quarterly Accessibility Conformance Report detailing compliance with the accessibility requirements for newly published content. Publishers are further encouraged to raise awareness about accessibility features and collaborate with organizations working in the field of disability inclusion.

To oversee implementation, the MIB will establish a monitoring committee chaired by an officer not below the rank of Joint Secretary. The committee will monitor compliance and address grievances through a three-tier structure consisting of self-regulation by publishers, oversight by self-regulatory bodies, and monitoring by the central government. The committee will meet quarterly.

The guidelines also prescribe clear timelines for grievance redressal and appeals: grievances must be acknowledged within 24 hours, publishers must respond within 15 days, appeals may be filed before the self-regulatory body within 15 days, and such body must respond within 15 days. A further appeal may be made to the monitoring committee within 15 days thereafter.

From a practical standpoint, the guidelines raise significant operational concerns for publishers of online curated content. The implementation of audio descriptions, accurate and synchronised captions, and Indian Sign Language interpretation in picture-in-picture format entails substantial investment in specialised production infrastructure, technology upgrades, and engagement of trained personnel and third-party vendors. These costs are likely to disproportionately burden smaller OTT platforms with limited resources. Notably, the guidelines do not prescribe any penalties or consequences for non-compliance following the expiry of the 36-month preparatory period, nor do they specify repercussions for failure to submit the quarterly Accessibility Conformance Report. The absence of an express enforcement mechanism raises questions regarding the effective enforceability of the framework and may dilute the urgency of compliance among regulated entities.