Two ministries, one blind spot: OTTs grapple with conflicting accessibility rules

The government's push to make streaming content accessible to persons with hearing and visual impairment has run into an unusual problem — two arms of the government appear to be regulating the same industry with different definitions, different timelines and different enforcement teeth, leaving OTT platforms, production houses and international streamers caught in the middle.

On one side is the Ministry of Information & Broadcasting (MIB), which on February 6, 2026 issued its "Guidelines for Accessibility of Content on platforms of publishers of Online Curated Content (OTT Platforms) for Persons with Hearing and Visual Impairment." 

On the other is the Department of Empowerment of Persons with Disabilities (Divyangjan) under the Ministry of Social Justice and Empowerment, which recently notified draft amendments to Rule 15(1)(c) of the Rights of Persons with Disabilities Rules, 2017—a far more technical, BIS-standard-driven framework covering all ICT products and services, including digital content.

Both instruments trace their authority to the Rights of Persons with Disabilities Act, 2016, and both were shaped, directly or indirectly, by the Supreme Court's November 2024 verdict in Rajive Raturi vs Union of India, which directed the Centre to carve out "non-negotiable" accessibility rules under Section 40 of the Act. Yet the two frameworks diverge sharply on substance, creating what industry executives describe as a compliance minefield.

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"We now have two ministries telling us to do the same thing, in two different ways, on two different clocks," said a senior compliance head at a leading Indian streaming platform, speaking on condition of anonymity. 

"MIB gives us 36 months and calls our back catalogue 'best effort.' DEPwD's draft says the stricter rule wins wherever there's a conflict. Nobody has told us which back catalogue definition we're actually supposed to build our roadmap around."

The archival content problem

The sharpest friction point is the treatment of a platform's back catalogue. MIB's guidelines are built around newly published content. Under Clause 4.1, platforms get 36 months to ensure new releases carry at least one accessibility feature for hearing-impaired viewers and one for visually impaired viewers.

Existing library content is addressed only in Clause 4.2 — platforms are "encouraged" to retrofit it "progressively... on best effort basis," with no firm deadline or penalty.

DEPwD's rules take a narrower route, exempting only "archived content" — defined as content "clearly identified as archived," "not intended for active public use or update," and "retained only for record purposes." 

A title sitting in an OTT platform's live, streamable catalogue arguably fails that test outright, since it is being actively served to subscribers. DEPwD's rules also state that wherever there is "any inconsistency between these rules and sectoral standards/guidelines, the higher or more stringent accessibility requirement shall prevail" — a clause that could override MIB's softer library carve-out entirely.

"Our legacy library runs into tens of thousands of hours," said a policy and regulatory affairs executive at a large media conglomerate. "If that gets reclassified as non-archived under DEPwD's definition, we're not talking about a phased retrofit anymore — we're talking about a compliance sprint with a one-year clock and financial penalties attached. That's a completely different budget conversation with our board."

Production houses versus platforms

MIB's guidelines place the obligation on "publishers" — the platforms — even though much of what streams on OTT is made by production houses, often for linear television first, under MIB's separate 2019 television accessibility standards, before being uploaded to OTT weeks or months later. 

TV-grade captioning or signing does not automatically satisfy OTT-specific requirements, such as MIB's mandate that Indian Sign Language interpretation appear in picture-in-picture mode with the interpreter's face and hands both visible.

"A show gets captioned for its TV telecast, then it lands on our platform and later we're told it doesn't meet OTT standards," said a content operations lead at a mid-sized streaming service. 

"We didn't shoot it, we don't own the raw assets, and the production house has already moved on to its next project. But the accessibility liability sits with us the moment it's on our app."

DEPwD's rules attempt a partial fix by pinning the reporting obligation on the "underlying system, platform, content management system, video publishing workflow, or authoring tool" rather than each title — but neither framework directly obligates production houses themselves, leaving platforms to absorb the retrofit cost by default.

The international OTT problem

A third fault line runs through India's relationship with global streaming majors, whose accessibility pipelines are built around international norms — US and EU standards, WCAG-based frameworks — that do not natively include India-specific ISL interpretation or conformance with BIS standard IS 17802.

"Our global content ops team builds captions and audio description to a template used across 190 markets," said an executive at an international streaming platform's India unit. 

"India is asking for something layered on top of that — a specific PIP-format sign language track, tested against an Indian standard. For licensed international titles, we often don't even hold the source files needed to add that. We'd have to go back to the studio that owns the IP, and there's no guarantee they'll fund a single-market retrofit."

Parallel enforcement, unresolved questions

The two frameworks also run separate grievance machinery — MIB's three-tier self-regulatory structure culminating in a Monitoring Committee, versus DEPwD's statutory, penalty-backed track running through Nodal Officers to the Chief Commissioner for Persons with Disabilities. 

"If the same lapse can be pursued under both, which one actually decides the outcome?" asked one platform executive. "Right now, that's anyone's guess."

With DEPwD's amendment still in draft form and open for public comment, industry bodies are expected to push for harmonised definitions, aligned timelines, and a single enforcement pathway before the rules are finalised. Until then, platforms remain answerable to two ministries pursuing the same goal by different, and at times conflicting, routes.