Overview of the draft “Rules on Compliance with Accessibility Standards for Information Communication Technology Products and Services”

India is prepared to make major advancements in digital accessibility after the Supreme Court's decision in the 2024 case of Rajive Raturi v. Union of India (2024 INSC 858). Under Section 40 of the Rights of Persons with Disabilities Act, 2016 ("RPwD Act"), the Supreme Court urged the Union Government to create legally binding laws and aim to ensure that all digital goods, services, and communication channels are accessible to individuals with disabilities. This mandate comes at a time where there is increasing awareness of the inaccessibility of technology, research, media, consumer services, and finance. In Rajive Raturi vs. Union of India (2024 INSC 858), the Supreme Court specifically directed that the NALSAR Centre for Disability Studies (“CDS-NALSAR”) was to be involved in this process of delineating mandatory accessibility rules. The Indian government’s Department for Empowerment of Persons with Disabilities (“DEPWD”), jointly with CDS-NALSAR, invited expressions of interest from organisations and individuals who wanted to be part of this exercise.

On 25 June 2025, the DEPWD and CDS NALSAR released “Rules on Compliance with Accessibility Standards for Information Communication Technology Products and Services” (“Draft”). Comments to the Draft maybe submitted within 30 days of its publication to aic-depwd@gov.in.

Evaluating digital accessibility:

CDS-NALSAR collaborated with DEPWD to establish a Core Group on Information Communication Technology ("ICT Core Group") Accessibility. This group aimed to evaluate the situation and develop an action plan. During their first meeting, the ICT Core Group presented existing issues and potential solutions based on input from the relevant ministries. In subsequent review sessions, the Chairperson looked at ongoing developments and discussed ways to address remaining gaps. After consulting with numerous ministries and regulatory bodies, the team identified systemic problems, including inaccessible banking platforms, point-of-sale devices, media content without captions, challenging-to-use websites, geospatial tools with usability problems, and consumer goods with ambiguous packaging. The Draft was released after these consultations for public comments.

Overview of the Draft:

From a policy standpoint, this Draft draws inspiration from international practices. The European Union, Canada, the United Kingdom, and the United States have implemented phased, standards-based accessibility rules based on WCAG, linked to enforceable audit and certification frameworks. India's move to adopt similar standards aligns with global best practices, shifting from intent to accountability.

The Draft proposed new rules to establish a binding and consistent accessibility framework for all ICT interfaces that interact with the public.

1. Who will the rules apply to?

   These rules will apply to all organisations, both public and private, involved in creating, developing, or sharing digital content, applications, websites, software, hardware, or ICT-supported consumer products.

   
   

2. What obligations will they have? 

   • Every digital product or service must produce an Accessibility Conformance Report ("ACR") as per the Indian Standards IS 17802 (Parts 1 & 2).

   • The product's degree of accessibility support is explained in this technical report.  It should be kept up-to-date and accessibility conformance must be tested whenever there is any “substantial upgrade”. A “substantial upgrade” refers to any major revision to a product, service, or content that materially changes its functionality, performance, or compatibility, including but not limited to version upgrades, platform migration, or integration of new modules. Questions as to whether the upgrade is substantial or not will be interpreted in favour of ensuring maximum accessibility for persons with disabilities.

   • These reports must be publicly available and in a recognised format, such as the Voluntary Product Accessibility Template ("VPAT").  The ACR should be available free of cost on the app, website, or digital channel, along with any product and service document to help consumers make informed decisions about the accessibility compliance of the product, service, or content.

3. What are the proposed compliance timelines? 

   Organisations need to ensure that their current digital resources and systems are compatible.

   • Websites, applications, and digital documents must adhere to a minimal "non-negotiable" standard and achieve WCAG 2.1 Level A criteria within six months of notification.

   • Other items, such as consumer electronics, interactive kiosks, and video content, should comply with the full Indian Standards IS 17802 within two years.

4. What are the proposed penalties? 

   To ensure compliance, the rules impose strict measures. Non-compliance can lead to penalties under RPwD Act, including the withholding, suspension, or cancellation of certifications by the Bureau of Indian Standards ("BIS"). Even approvals for mobile applications and websites can be revoked if they do not meet the established standards.

Authors: Avishi Vats, intern, SheSR and Shambhavi Ravishankar, Consultant, SheSR