India - Draft Rights of Persons with Disabilities (Amendment) Rules, 2026 – Digital Accessibility Framework
An ISOC LIVE Summary
Publication: The Gazette of India (Extraordinary), Part II, Section 3(ii)
Notification: 16 July 2026 - Gazette Publication: 20 July 2026
Overview
The Ministry of Social Justice and Empowerment, through the Department of Empowerment of Persons with Disabilities (Divyangjan), has published draft amendments to the Rights of Persons with Disabilities Rules, 2017 that would create one of the world’s most comprehensive regulatory frameworks for digital accessibility. The proposal replaces the existing ICT accessibility provisions in Rule 15(1)(c) with a detailed, enforceable compliance regime covering websites, software, digital content, mobile applications, hardware, public digital services, assistive technologies, and ICT procurement.
The amendments were prompted by a November 2024 Supreme Court judgment (Rajive Raturi v. Union of India, Writ Petitions (Civil) Nos. 243 of 2005 and 228 of 2006) directing the Union Government to delineate non-negotiable rules under Section 40 of the Rights of Persons with Disabilities Act, 2016, separating them from the expansive guidelines in Rule 15, and observing the need for uniformity and clarity across sectoral standards.
Objections and suggestions may be sent to Shri Ram Charan Meena, Under Secretary, Department of Empowerment of Persons with Disabilities, Room No. 11A, 5th Floor, Pandit Deen Dayal Antyodaya Bhawan, CGO Complex, Lodhi Road, New Delhi 110003, or by email to rcmeena.79@gov.in. The window runs for thirty days from the date on which copies of the Gazette carrying the notification are made available to the public.
Expanded Definitions
The draft introduces several legal definitions that determine how the rules operate.
A “major change” is defined broadly as any upgrade, addition, or modification that materially alters a product’s functionality, performance, user interface, design, usability, appearance, or accessibility features to an extent that it could affect compliance. This definition is significant because it determines when accessibility testing must be repeated.
An “Accessibility Conformance Report” (ACR) becomes the primary compliance document. It records the extent to which a covered item conforms to India’s accessibility standards and documents the testing methodology used.
The draft also defines “archived content” - content clearly identified as archived, not intended for active public use or update, and retained only for record purposes - and establishes that turnover calculations include the consolidated turnover of the establishment together with any establishment that controls it, is controlled by it, or is under common control with it, where such establishments make covered items available to persons in India, including through platforms or intermediary systems.
Broad Scope of Coverage
The proposed rules apply to every establishment that manufactures, designs, develops, exercises decisive technical control over, or makes available, directly or indirectly, covered items to persons in India for public or consumer use - whether the establishment is located inside or outside India.
Covered technologies include:
Websites, mobile applications, tablet applications, and other touch-based applications.
Software, including documentation and support services.
All digital content, content formats, and electronic documents including non-web documents.
ICT-based public facilities and services, including services used by the public in urban and rural areas.
Hardware-based ICT with two-way voice communication capability.
Hardware-based ICT with video-based communication capability.
All other ICT-based hardware and electronic goods and equipment intended for everyday use.
ICT-based consumer products.
ICT-based accessories for general use by persons with disabilities.
ICT-based products used as part of public facilities and services.
The scope provision expressly extends to automated systems enabling user interaction with ICT, recognising the increasing role of automated digital platforms.
Mandatory Technical Standards
Every covered item must comply with:
IS 17802 (Part 1): 2021, notified 24 December 2021
IS 17802 (Part 2): 2022, notified 4 May 2022
These Bureau of Indian Standards documents, as amended from time to time, become the baseline legal requirements.
Where a sectoral regulator or competent authority - such as one governing banking, telecommunications, transportation, or healthcare - imposes accessibility requirements, establishments must comply with those as well. In the event of inconsistency, the higher or more stringent requirement prevails.
Accessibility Conformance Reports Become Mandatory
The most significant operational requirement is the mandatory Accessibility Conformance Report.
Every covered item must have an ACR regardless of whether it was:
developed in-house,
procured from suppliers,
commissioned from developers, or
otherwise made available by the establishment.
The ACR must be supplied free of cost along with other supplied documentation, and published on the establishment’s website or mobile application so that consumers can make an informed choice about accessibility compliance before using a product.
Detailed Reporting Requirements
The ACR itself must contain far more than a simple compliance declaration.
It must:
state the extent of conformance with IS 17802 (Part 1): 2021, as tested under IS 17802 (Part 2): 2022;
provide a detailed statement of conformance for each applicable requirement, using the categories and terminology of IS 17802;
include supporting explanations referencing specific test results, methods used, or sufficient examples to enable verification;
disclose whether testing was automated, manual inspection, and/or assistive technology testing;
describe the scope and limitations of the methodology;
follow a recognised reporting format such as VPAT or another structured format specified under IS 17802.
Supporting explanations must be requirement-specific. Generic or blanket statements of conformance are explicitly excluded.
Human- and Machine-Readable Compliance
The proposal introduces an unusual transparency requirement.
Every ACR must be published in two forms:
a human-readable accessible format such as HTML or accessible PDF; and
a machine-readable structured format such as JSON or XML, or another format facilitating monitoring and automated verification.
Failure to publish both versions constitutes non-compliance.
If inconsistencies exist between the two versions, the human-readable version prevails, without prejudice to the establishment’s obligation to ensure both versions are accurate and consistent.
Supplier Responsibility
Establishments cannot simply rely on vendor claims.
Before deployment or launch of any covered item, the establishment must review and verify each ACR for:
accuracy,
completeness,
conformance with the most recent BIS standards.
Any identified non-conformities must be corrected before release. Reliance on a supplier’s or developer’s ACR without such due diligence does not absolve the establishment of liability.
Continuous Compliance
Accessibility becomes a continuous obligation rather than a one-time certification.
Whenever a covered item undergoes a major change that may affect accessibility, the establishment must:
re-test conformance against the most recent versions of IS 17802,
update the ACR, clearly indicating the date of revision,
complete this work before deployment of the upgraded or modified item.
Where an establishment concludes that a modification is not a major change, it must maintain records of that assessment and produce them for inspection on request. Failure to maintain or produce such records is itself deemed non-compliance.
Even without major changes, every ACR must be freshly reviewed, tested, and updated at least once every two years from the date of the last ACR.
Content Management and User-Generated Content
The draft distinguishes between accessibility of content and accessibility of the systems that create content.
For content management systems, video publishing workflows, authoring tools, and document generation systems, the ACR obligation applies to the underlying platform rather than every individual item of content - provided content generated through that system is made accessible in accordance with the notified standards.
For user-generated content platforms, the obligation similarly applies to the platform itself rather than every user upload.
Platforms must nevertheless provide the capability to embed accessibility features, including:
captions,
transcripts,
alternative text,
audio description,
accessible formats for documents,
structured or tagged content,
logical reading order.
Platforms must also take reasonable steps to inform and guide users at the time of upload to generate accessible content, and must disclose in their ACR the measures and tools they provide. Where such capability is not fully available at commencement, it must be implemented within six months of notification.
Qualified Accessibility Experts
Accessibility assessments cannot be performed by unqualified personnel.
ACRs must be prepared, reviewed, or verified by individuals or organisations with demonstrable domain expertise in accessibility evaluation and testing, including:
familiarity with the referenced BIS standards,
familiarity with assistive technologies used by persons with disabilities,
knowledge of recognised accessibility testing methodologies,
relevant training, professional experience, or recognised certifications issued by nationally or internationally recognised bodies.
Their contact details and credentials must be published as part of the ACR.
The Bureau of Indian Standards must notify the official reporting format, as part of IS 17802, within ninety days of notification of the rules.
Compliance Schedule
The draft establishes phased implementation based on organisational size.
Establishments with turnover of ₹500 crore or more must comply with the Schedule I clauses (for websites, applications, software, digital content, electronic documents, and ICT-based public facilities and services) and the Schedule II clauses (for hardware, consumer products, accessories, and public-facility products) within one year of publication.
Establishments below that threshold receive eighteen months.
Regardless of size, all establishments must comply with the referenced accessibility standards in their entirety within two years of publication, for the purposes of Section 46 of the Act. Where the rules and any guidelines or standards are inconsistent, the rules prevail.
Archived content is exempt, provided it is clearly identified as archived and is not intended for active public use or update.
Government Procurement
Accessibility is integrated directly into public procurement.
No government establishment may procure, deploy, upgrade, or renew covered items, directly or indirectly, unless those items comply with the required accessibility standards.
Within ninety days, every government establishment must review and revise:
procurement policies,
tender documents,
requests for proposals,
contracts,
related processes,
to incorporate accessibility as mandatory conditions, technical specifications, and evaluation criteria rather than an optional consideration.
Enforcement Framework
The proposal creates multiple layers of enforcement.
Establishments that fail to comply may face:
fines under the Rights of Persons with Disabilities Act, without prejudice to action under other laws;
inquiry by the Chief Commissioner or State Commissioner for Persons with Disabilities, with fines under Section 89 of the Act;
additional penalties, sanctions, or corrective measures from sectoral regulators where non-compliance continues;
mandatory remediation, including an updated ACR, within ninety days of the competent authority’s order.
Any ACR furnished under the rules must be signed by the designated nodal officer or, in other establishments, by a person at not less than Director or designated partner level, who is responsible for its accuracy and completeness.
Where an ACR is not furnished, or is found false, misleading, or materially inaccurate, the concerned ministry, department, statutory authority, or sectoral regulator may initiate action under the applicable law governing that establishment.
Escalating Penalties
If establishments fail to remedy violations within the prescribed period, enforcement escalates.
Possible consequences include:
enhanced fines under the Act;
suspension or cancellation of registration;
suspension or cancellation of certification;
suspension or cancellation of authorisation or approval,
acted on by the sectoral regulator or concerned ministry either on its own motion or on the recommendation of the Chief Commissioner or State Commissioner for Persons with Disabilities.
Where a covered item is subject to licensing, registration, certification, approval, or any regulatory clearance, the relevant authority must require an ACR or accessibility compliance undertaking as a condition of grant, renewal, or continuation. Where no such licensing regime exists, the establishment must disclose an ACR with supplied documentation or on its website or app.
Quality Control Orders
Quality control orders issued by the respective ministries must be modified within ninety days of publication to incorporate compliance with these rules and the standards prescribed in them, wherever applicable.
Grievance Redressal
The draft establishes a three-tier complaint mechanism.
Every establishment must designate a sufficiently senior officer from its management as Grievance Redressal Officer, to oversee implementation and address complaints of inaccessibility. That officer’s name and contact details must be disclosed in the ACR.
Every ministry, department, statutory authority, or sectoral regulator of the Central Government must designate a Deputy Nodal Officer at not below Director rank and a Chief Nodal Officer at not below Joint Secretary rank, whose names, designations, and contact details must be prominently published on the relevant website within ninety days of notification.
The Deputy Nodal Officer examines escalated complaints and undertakes fact-finding, may seek information or records and issue directions for corrective action, monitors compliance by regulated establishments, and must dispose of referred complaints within forty-five days.
The escalation path runs as follows. An aggrieved person first approaches the establishment’s Grievance Redressal Officer, who must respond within thirty days. If the complaint is unresolved within that period, or the person is aggrieved by the decision, they may complain to the Deputy Nodal Officer within thirty days. A further appeal lies to the Chief Nodal Officer within thirty days, who hears appeals, reviews systemic or recurring issues, issues policy or compliance directions, and must dispose of appeals within forty-five days. Beyond that, a complaint may be filed with the Chief Commissioner or State Commissioner for Persons with Disabilities under the Act, without prejudice to any other remedy.
Complaints and appeals must, as far as practicable, identify the complainant, the establishment, product, service, or content concerned, describe the accessibility barrier, state the date or period of the barrier, attach supporting evidence where available, state the relief sought, and - for appeals - include the original complaint and any decision received together with the grounds of appeal.
National Accessibility ICT Committee
The Department of Empowerment of Persons with Disabilities must constitute a National Accessibility ICT Committee within ninety days of notification, comprising representatives of concerned ministries, departments, statutory authorities, and sectoral regulators, with not less than fifty per cent persons with disabilities.
The Committee’s functions include:
coordinating uniform implementation across ministries, departments, statutory authorities, and sectoral regulators;
reviewing compliance trends from ACRs, complaints data, and nodal officer inputs, and identifying systemic gaps;
issuing binding directions to remedy systemic gaps in accessibility conformance;
issuing directions and standard operating procedures to guide implementation;
laying down standards and frameworks for certification and empanelment of accessibility professionals, auditors, and testing agencies;
approving and maintaining a panel of accessibility professionals, auditors, testing agencies, and organisations, and periodically reviewing, updating, or withdrawing empanelment;
identifying and publishing indicative tools, methodologies, and practices for accessibility evaluation and testing;
facilitating resolution of inter-jurisdictional or cross-sectoral issues;
promoting capacity-building and awareness initiatives;
submitting an annual implementation report to the Central Government.
The Committee must meet at least quarterly, and its proceedings, recommendations, directions, and advisories must be published on the Department’s website.
Periodic Review
The rules must be reviewed every three years to determine whether amendments are needed, or at the time of any modification to the referenced BIS standards.
The Schedules
Schedule I sets out the non-negotiable clauses of IS 17802 (Part 1): 2021 applying to websites, applications, software, digital content, electronic documents, and ICT-based public facilities and services. It is presented as a four-column table mapping requirements across Web (Section 9), Non-Web Documents (Section 10), Software with Open Functionality (Section 11), and Software with Closed Functionality (Section 11) - roughly thirty rows covering the perceivable, operable, understandable, and robust requirement families, with a small number of cells marked as not applicable.
Schedule II sets out the non-negotiable standards for hardware and consumer items: Section 6 of IS 17802 (Part 1): 2021 for hardware with two-way voice communication capability, Section 7 for hardware with video-based communication capability, and Section 8 for the remaining hardware, consumer product, accessory, and public-facility categories.
Both Schedules specify that clause references are to be read as references to the latest version of the standard, including any revision, amendment, or replacement notified by BIS.
Overall Significance
The proposed amendments move India’s digital accessibility policy from guidance to enforceable regulation. Rather than requiring accessibility only at the point of product release, the rules establish obligations throughout the ICT lifecycle - from design, procurement, testing, documentation, and deployment to ongoing maintenance, periodic reassessment, public transparency, complaint handling, and regulatory enforcement.
They also introduce unusually detailed requirements for publicly available accessibility documentation, machine-readable compliance reporting, procurement controls, executive accountability, a standing coordination committee with binding-direction powers and majority representation of persons with disabilities, and a defined empanelment route for accessibility professionals and testing agencies - making accessibility an integral component of ICT governance rather than a standalone technical requirement.
For organisations publishing archives of recorded events, two provisions are worth noting together: the exemption for content clearly identified as archived and not intended for active public use or update, and the platform-level obligations on user-generated content systems to provide captions, transcripts, audio description, and logical reading order.
RESOURCES
Department of Empowerment of Persons with Disabilities — the notifying department; objections to rcmeena.79@gov.in within thirty days
Rajive Raturi v. Union of India (2024 INSC 858) — the Supreme Court judgment that held Rule 15 ultra vires
IS 17802 (Part 1): 2021 — the accessibility requirements the draft rules make non-negotiable
IS 17802 (Part 2): 2022 — the conformance determination procedures referenced throughout
Bureau of Indian Standards — must notify the ACR reporting format within ninety days
Office of the Chief Commissioner for Persons with Disabilities — enforcement jurisdiction under Section 89
ITI Voluntary Product Accessibility Template — the VPAT format the draft names as an acceptable ACR structure
ThePrint on the draft rules — coverage of the extraterritorial reach and licence risk
Diversity and Equal Opportunity Centre — earlier commentary on drafting the non-negotiable standards
Disability Rights Through Courts — analysis of the Raturi ruling and its Section 40 directions
Very timely post. Considering a panel at the upcoming IGF2026 in Nairobi Kenya.