Mumbai: The Internet and Mobile Association of India (IAMAI) has cautioned that the Ministry of Information and Broadcasting’s (MIB) newly issued “Draft Guidelines for Accessibility of Content on Platforms of Publishers of Online Curated Content (OCCPs) for Persons with Hearing and Visual Impairment” could significantly challenge regional and smaller OTT players due to the heavy operational, technical, and financial demands they impose.
While welcoming the Government’s intent to enhance inclusivity for persons with disabilities, the IAMAI highlighted that the cost of implementing the guidelines — especially for platforms with limited scale — could, in many cases, exceed their total revenues, making continued operations commercially unviable.
The association noted that the Draft Guidelines’ prescriptive and retrospective obligations would require extensive retrofitting of thousands of hours of existing content, as well as continuous reverification. Such requirements, IAMAI stated, would sharply escalate compliance costs in a high-cost, price-sensitive market like India. Platforms would also need to revisit legacy licensing agreements to confirm rights availability, which may lead to complexities, renegotiations, or even withdrawal of older library titles. IAMAI therefore recommended a best-effort approach for existing catalogues rather than mandatory compliance.
Further, the submission flagged several provisions — including strict rules on caption font size, colour, and placement — as overly rigid and exceeding the expectations set by the Rights of Persons with Disabilities (RPwD) Act.
IAMAI also pointed out that a substantial portion of OTT content comprises licensed material, including regional films, foreign content, and syndicated programming for which platforms often do not possess modification rights. Imposing blanket accessibility obligations in such cases, the association argued, would create legal conflicts and operational roadblocks.
The Draft Guidelines, IAMAI observed, go beyond global standards. International frameworks such as the EU Accessibility Act (2025) and the UK Media Act (2024) differentiate between content creators and streaming platforms, focusing primarily on enabling platforms to support accessibility features rather than mandating retroactive creation for third-party content.
To address these challenges, IAMAI has proposed that the Government adopt a regulatory sandbox approach. In collaboration with Prasar Bharati, the MIB could pilot accessibility standards on a limited scale to assess technical, financial, and operational feasibility. Publishing the results as a status report would further help the industry prepare for future obligations logically and sustainably.
IAMAI also recommended a flexible framework that allows OCCPs to choose from a set of approved accessibility services based on content libraries, rights structures, and audience needs, rather than enforcing a uniform compliance mandate. Additionally, it urged the Government to move toward a phased implementation roadmap to support smooth industry-wide transition.
