IAMAI seeks sector-specific, phased framework for draft RPwD accessibility rules

The Internet and Mobile Association of India (IAMAI) has urged the government to reconsider the proposed uniform application of accessibility obligations under the draft Rights of Persons with Disabilities (RPwD) (Amendment) Rules, 2026, and instead adopt a sector-specific, proportionate and phased framework.

In a submission to the Department of Empowerment of Persons with Disabilities (DEPwD) under the Ministry of Social Justice and Empowerment (MSJE), IAMAI said the digital ecosystem supports the objective of making digital content, products and services accessible to persons with disabilities, but argued that the same set of obligations cannot be applied uniformly across sectors, technologies and business models.

IAMAI has proposed that the Draft Rules prescribe the baseline, non-negotiable accessibility obligations contemplated by the Supreme Court, while detailed requirements for individual sectors are developed and implemented by the relevant ministries and regulators.


The industry body pointed to the accessibility framework already developed by the Ministry of Information and Broadcasting (MIB) for Online Curated Content Providers (OCCPs) and television as an example of a sector-specific approach. According to IAMAI, the framework reflects a calibrated understanding of the streaming and broadcasting sector developed over time.

IAMAI has also raised concerns about how the proposed rules would interact with existing sectoral frameworks. It specifically flagged Rule 15(1)(c), which states that the “higher or more stringent accessibility requirement shall prevail” where a sectoral regulator has issued its own requirements. It also pointed to Rule (E)(4), which states that the Draft Rules would prevail “to the extent of such inconsistency”.

IAMAI said these provisions, read together, could result in the Draft Rules taking precedence over existing sectoral frameworks where those frameworks prescribe a more stringent standard. It has therefore recommended that the interplay between the provisions be examined further to preserve the primacy of existing sectoral guidance.

The association also raised concerns over the proposed compliance timelines. It said the MIB framework adopted phased milestones, taking into account the time and producer cooperation required to make existing content libraries accessible. In contrast, the Draft Rules prescribe compliance within one year for large entities and two years for full compliance, with a narrowly drawn exemption for “archived content”.

IAMAI said digital content, software, applications, platforms, hardware and consumer products differ significantly in their operation, underlying technology, degree of control over content and interfaces, and the accessibility solutions available to them.

It argued that a one-size-fits-all approach across India's diverse digital ecosystem could create undue burdens, stifle innovation and overlook practical constraints faced by service providers in different sectors.

The association cited hardware as an example. It said the accessibility of the viewing experience depends not only on a platform's application but also on device hardware, operating systems and assistive technology controlled by third-party manufacturers. Hardware engineering, silicon design and manufacturing supply chains also operate on multi-year development cycles, making it technically unfeasible to retrofit existing hardware architectures and legacy back-catalogues, IAMAI said.

IAMAI has urged the MSJE and DEPwD to adopt a proportionate sectoral framework that sets broad principles and objectives, while leaving detailed obligations to the relevant sectoral regulators and ministries, following the model already in place for television and OCCPs under MIB.

Before prescribing such requirements, IAMAI has recommended that the Bureau of Indian Standards (BIS) and relevant authorities undertake a market and technology assessment covering technical feasibility, implementation costs, availability of accessibility solutions and reasonable timelines, followed by detailed consultations.

The association said a phased approach would advance accessibility while allowing requirements to keep pace with technology and the practical realities of India's diverse digital ecosystem.