OTT accessibility push: Experts flag gaps in regional content, app design, legacy library

As India moves towards a more formal accessibility regime for digital platforms, the bigger challenge for OTT companies may no longer be understanding what the rules require, but figuring out how to implement them across India's vast and diverse content ecosystem.

The Ministry of Information and Broadcasting's (MIB) proposed accessibility guidelines for OTT platforms and the Department of Empowerment of Persons with Disabilities' (DEPwD) proposed amendments to the Rights of Persons with Disabilities Rules, 2017 have already raised questions around overlapping obligations, timelines and enforcement mechanisms. 

The next layer of the debate is now shifting to implementation—particularly regional-language programming, live content, older content libraries and the accessibility of apps themselves.

New disability rules and compliance clock. Read more

A recent white paper by KPMG in collaboration with Svayam, Does Accessibility Make Economic Sense?, adds another dimension to the debate: digital accessibility is not only a rights or compliance issue, but also represents a sizeable economic opportunity.

The report estimates that 262 million Indians face substantial digital accessibility challenges, after accounting for overlaps among persons with disabilities, older adults, people with chronic or mobility conditions and those facing temporary or situational barriers. 

Read more: Two ministries, one blind spot

These groups are estimated to have about 30% lower digital engagement than typical users, primarily because of usability barriers, inaccessible design and limited adaptive technologies.

For the OTT sector, the finding is significant because entertainment platforms are among the digital services where accessibility gaps remain particularly visible. The report notes that while accessibility standards for emerging domains such as OTT streaming, digital media and fintech are still developing, implementation remains uneven. It also flags a shortage of developers, designers, testers and content creators with specialist accessibility skills.

Jiostar, Netflix go beyond captions

This is particularly relevant for India's streaming industry, where accessibility has to work across multiple languages, formats and devices.

“Regional-language content, live programming and legacy libraries require particular attention. Accessibility must be built into production and product design from the outset, not retrofitted later. Platforms have the technology and reach to make this happen; what is needed now is clear accountability to ensure digital content is genuinely accessible, inclusive and independently usable by all,” said Uttam Kumar, CEO, Sense International India.

Regional content could be the biggest blind spot

Regional content could be the biggest blind spot

India's OTT market is increasingly driven by regional programming, with platforms commissioning and acquiring content in languages ranging from Bengali, Marathi and Odia to Punjabi, Tamil, Telugu, Malayalam and Kannada.

This creates a substantially more complicated accessibility problem than simply translating subtitles.

Sminu Jindal, Founder-Chairperson of accessibility organisation Svayam and Chairperson, CII-IBDN (India Business Disability Network), said India's linguistic diversity makes scale both a challenge and an opportunity.

“India's diversity makes scale both the challenge and the opportunity. For regional-language content, captions and audio descriptions need more than translation—they require linguistic accuracy, cultural context and quality control. Live programming adds the challenge of delivering accessibility in real time,” Jindal said.

The MIB guidelines require OTT platforms to work towards audio descriptions, closed or open captioning and Indian Sign Language interpretation. They also require platforms, after the implementation period, to make accessibility features functional across their user interfaces.

But the quality of these services matters as much as their presence.

The guidelines say captions should accurately reflect dialogue as well as relevant non-speech sounds, be synchronised with speech, run through the content and remain legible without obscuring important visual information. Audio descriptions are expected to be clear, comprehensive and concise enough to fit within the available gaps in dialogue.

Experts say these requirements become harder to meet consistently when content is produced in multiple Indian languages.

Audio descriptions, in particular, are commonly seen in English and Hindi programming, while content in several regional languages has limited availability of such services.

This can create a second layer of exclusion: a platform may technically be accessible, but its accessibility may not extend to the content a user actually wants to watch.

One practical constraint is the availability of trained audio describers who understand both the language and the cultural context of the programme.

AI can scale accessibility, but humans remain critical

Jindal said technology can play an important role in solving the scale problem.

“Older content libraries present another opportunity for phased accessibility. Platforms can prioritise high-demand content while ensuring that accessibility becomes part of the production process for new content. Technology, including AI, can help accelerate captioning, translation and content description, but human review remains important for accuracy and context,” she said.

This could become particularly relevant for OTT platforms that have accumulated thousands of hours of catalogue content.

Retrofitting an entire library at once could be expensive and operationally difficult. A phased approach—starting with high-demand titles, new releases and content with sustained viewership—could make the transition more manageable.

The MIB guidelines require accessibility features for newly published content after the implementation period, while encouraging platforms to progressively add such features to their existing libraries on a best-effort basis.

The guidelines also require accessible content to be discoverable, through accessibility indicators, suitable thumbnails and potentially search filters. This means accessibility is not intended to stop at the production of an audio-described or captioned version; users should be able to identify and select it.

For experts, this distinction is crucial.

A film with an audio-description track has little practical value if a visually impaired viewer cannot find it in the platform's catalogue or activate it independently.

The economic case for fixing the digital gap

The KPMG-Svayam report suggests that the business case for addressing these barriers could extend well beyond the population formally classified as persons with disabilities.

The report estimates that making digital platforms and devices fully accessible could increase digital engagement among affected groups by up to 37%. It estimates that fully accessible ICT systems could unlock more than Rs 3.11 lakh crore, in annual economic value, through higher digital transactions, workforce productivity and participation in digital commerce, services and governance.

While the estimate covers the wider ICT ecosystem rather than OTT alone, the implication for digital platforms is clear: accessibility can expand the addressable user base rather than simply adding a compliance expense.

For streaming platforms, that could translate into greater engagement among users who currently face barriers in discovering content, navigating apps or consuming audiovisual programming.

The app itself can become the accessibility barrier

While much of the public discussion has focused on captions and audio descriptions, experts say the accessibility of the platform's application can be just as important.

A user may have access to an audio-described film but still be unable to find or activate it if the OTT application's menus, buttons, search functions or navigation are not compatible with assistive technologies.

Khandu Bhandare, Training and Accessibility Specialist, Deputy Manager, SBI Foundation, said the existing rules do not go far enough in addressing accessible application design.

“There is still a significant gap, particularly in the accessible design of applications. Accessibility features are not consistently available across all OTT platforms. One important point that policymakers should consider is accessibility during application updates,” Bhandare said.

The concern is that accessibility can be lost during an otherwise routine software update.

“Whenever an app or website is updated with new features, the new version often becomes inaccessible, making it difficult for users with disabilities to navigate and use the platform independently. Therefore, accessibility should be treated as a priority at every stage of product development, including when updating existing applications or introducing new features. Accessibility should be built into the design and testing process rather than being addressed after the product is launched,” he said.

The MIB guidelines specifically require OTT websites, mobile applications, smart-TV applications and desktop software to be designed for compatibility with assistive technologies.

The DEPwD draft rules go further by defining a “major change” as an upgrade, addition or modification that materially alters functionality, performance, user interface, design, usability, appearance or accessibility features in a manner that could affect compliance.

This makes a strong case for accessibility testing to become part of the product-development lifecycle rather than an audit conducted after launch.

Live programming remains a difficult frontier

Live programming presents another unresolved challenge.

Recorded content can be captioned, translated and audio-described before release. Live programming requires these services to be delivered in real time, often with little room for correction.

The MIB guidelines exempt live and deferred-live content from their accessibility requirements, citing practical and operational difficulties associated with real-time captioning and audio description. Audio content and standalone short-form content, including advertisements, are also exempt.

For accessibility advocates, however, the exemption highlights the difference between making content technically accessible and ensuring that persons with disabilities have comparable access to the wider entertainment experience.

Sports, news events, awards shows, reality programming and other live formats can constitute a significant part of a platform's offering.

Jindal's observation that live programming requires accessibility “in real time” points to a likely future area of technological investment, particularly in automated captioning and speech-to-text systems.

But even here, experts say automation can improve scale and speed, while human intervention remains necessary where accuracy, context and meaning are critical.

Harmonized standards required

The industry's concern over the two regulatory frameworks is therefore not simply about compliance costs.

Kumar said the intent behind both initiatives is welcome, but the government needs to make the frameworks work together.

“The intent behind the MIB guidelines and DEPwD draft rules is welcome, but differing definitions, timelines and obligations can create complexity. We need harmonised standards, clear benchmarks and a single, coordinated enforcement pathway,” he said.

The concern also mirrors the broader ICT findings in the KPMG-Svayam report, which says enforcement of accessibility requirements remains fragmented and inconsistent across ministries, states and the private sector. The report also flags the absence of a centralised, real-time system to monitor and publicly report accessibility progress.

For OTT companies operating across the digital ecosystem, a common set of definitions, testing standards and reporting requirements could therefore be as important as the accessibility features themselves.

The implementation test

For OTT platforms, the test will therefore be whether accessibility becomes part of content production, product design, software testing and user experience, rather than a compliance layer added at the end.

“Technology can provide tools, but understanding the user's actual experience is what makes the solution effective,” Jindal said.

That may ultimately become the defining test for India's emerging accessibility regime: not whether platforms can demonstrate that they have added an accessibility feature, but whether a person with a disability can actually use the service independently.

For India's OTT industry, that represents a shift from accessibility as a regulatory checkbox to accessibility as part of the product and content experience itself.