Introduction
On February 6, 2026, the Ministry of Information and Broadcasting (“MIB“) issued the Guidelines for Accessibility of Content on platforms of Publishers of Online Curated Content (OTT Platforms) for Persons with Hearing and Visual Impairment (“OTT Guidelines“). The OTT Guidelines were issued for ensuring access to recreational content and providing an enabling framework to support the development of a culture and practice of accessibility of content by publishers of the same, for persons with hearing and visual impairment.
Previously, via the Code of Ethics under The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (“IT Rules“), publishers of online curated content (“Publishers of OCC“) were directed to take reasonable efforts, to the extent feasible, to improve the accessibility of online curated content (“OCC“) transmitted by it to persons with disabilities (“PwDs“) through the implementation of appropriate access services. However, the new OTT Guidelines introduce mandatory compliance requirements for Publishers of OCC, including over-the-top streaming platforms (“OTT Platforms“), as discussed below. The OTT Guidelines reflect a broader shift towards embedding inclusivity within the architecture of digital services.
Regulatory Background
The MIB issued the OTT Guidelines in furtherance of the legal framework under the Rights of Persons with Disabilities Act, 2016 (“PwD Act“). Under Section 42 of the PwD Act, the appropriate government is directed to take measures to ensure that PwDs have access to: (i) information and communication technology in a manner that all contents available in audio, print and electronic media are in accessible format; (ii) electronic media by providing audio description, sign language interpretation and close captioning; and (iii) all electronic goods and equipment which are meant for everyday use are available in universal design. The MIB has also, by way of an advisory dated April 22, 2025, directed Publishers of OCC to comply with the provisions of the PwD Act and the Code of Ethics under the IT Rules. However, following the introduction of the OTT Guidelines, Publishers of OCC are hereby mandated to improve accessibility of OCC to PwDs, as discussed below.
Applicability of the OTT Guidelines
The OTT Guidelines apply to all ‘Publishers of OCC (OTT Platforms)’. Under the IT Rules, “publishers of online curated content” means a publisher that performs “a significant role in determining the online curated content being made available, makes available to users a computer resource that enables such users to access online curated content over the internet or computer networks, and such other entity called by whatever name, which is functionally similar to publishers of online curated content but does not include any individual or user who is not transmitting online curated content in the course of systematic business, professional or commercial activity[1].” The OTT Guidelines therefore apply to all OTT Platforms, with an exclusion only for individuals or users not transmitting OCC in the course of any systematic business, professional or commercial activity.
The OTT Guidelines further exempt certain categories of content from its regulation, namely: (i) live and deferred live content; (ii) audio content such as music, podcast etc.; and (iii) short-form content including advertisements, etc.[2]. In the case of short-form content, this exemption is applicable to standalone content only and does not cover multiple individual episodes/segments of content[3].
Key Compliances for Publishers of OCC
A summary of key compliances for Publishers of OCC under the OTT Guidelines is given below:
- Accessibility under the OTT Guidelines:
Under the OTT Guidelines, accessibility of audiovisual media services made available by Publishers of OCC includes accessibility of the audiovisual content itself, and that of user interface components, onscreen information and interaction mechanisms[4].
- Accessibility Standards:
The OTT Guidelines lay down accessibility standards for audio-visual content published by Publishers of OCC. This includes: (a) audio descriptions of audio-visual content in a concise yet comprehensible format without causing distraction[5]; (b) ensuring complete, accurate and synchronised closed and open captioning, in a legible colour positioned without blocking important visual content[6]; and (c) providing accurate, synchronised Indian Sign Language (“ISL“) interpretation by interpreters in picture-in-picture mode, conveying a clear message such that both the hands and the facial expressions of the interpreters are visible[7] (each, an “Accessibility Feature“).
- Implementation Schedule:
Within 36 (Thirty-Six) months of the date of publication of the OTT Guidelines, Publishers of OCC must: (a) ensure that all newly published content contains at least one Accessibility Feature for its hearing impaired (i.e., closed/open captioning and ISL interpretation) and visually impaired (i.e., audio description) viewers ; (b) prominently display, at the time of release, content descriptors indicating such Accessibility Features including for promotional audio-visual material; and (c) integrate and make functional the Accessibility Features across user interfaces of their platforms[8]. Publishers of OCC have further been encouraged to, on a best efforts basis, provide at least one Accessibility Feature to the content in their content libraries for its hearing impaired (i.e., closed/open captioning and ISL interpretation) and visually impaired (i.e., audio description)[9].
- Additional Requirements:
Publishers of OCC must furnish an ‘Accessibility Conformance Report’ in respect of compliance of newly published content on their platforms, the first of which shall be furnished within 36 (Thirty-Six) months of the date of publication of the OTT Guidelines, and thereafter, the same must be furnished on a quarterly basis[10]. Furthermore, Publishers of OCC are obligated to make sure accessible content is discoverable on their libraries through the use of indicators, filters or suitable thumbnails, and to actively publicise the availability of such accessible content[11]. The OTT Guidelines further encourage Publishers of OCC to collaborate and work with the organizations working in the field of accessibility of content for PwDs[12].
Grievance Redressal Mechanism
The OTT Guidelines introduce a three-tier grievance redressal mechanism for grievances made by complainants in relation to Publishers of OCC, namely:
- Level 1 – Self-regulation by Publishers of OCC:
Any person with a grievance (“Complainant“) regarding accessibility of OCC may furnish such grievance in writing or by email (to the respective publisher of such OCC). In such a case, the Publisher of OCC must acknowledge such grievance within 24 (Twenty-Four) hours of receipt[13], and inform the Complainant of its decision within 15 (Fifteen) days of the registration of the grievance[14]. The grievance shall be escalated to Level 2 below if: (i) the Publisher of the OCC does not render its decision within the aforesaid 15 (Fifteen) day timeline[15]; or (ii) the Complainant is not satisfied with the decision of the publisher and prefers an appeal to Level 2[16].
- Level 2 – Self-regulation by the self-regulating bodies of the Publishers of OCC:
As discussed above, grievances that are not resolved by the Publisher of OCC, or which are contested by the Complainant, are escalated to Level 2, i.e., to the self-regulating body of the concerned Publisher of OCC. Such self-regulating body shall address the grievance of the Complainant and render its decision in the form of an advisory to the Publisher of the OCC and inform the Complainant of its decision within 15 (Fifteen) days[17].
- Level 3 – Monitoring mechanism by the Central Government:
At Level 3, grievances are raised before the Monitoring Committee to be established by the MIB under Clause 7.1 of the OTT Guidelines, with the objective of monitoring the implementation of the OTT Guidelines and redress grievances pertaining to accessibility of content on OTT platforms. Grievances may be escalated by the Complainant to the Monitoring Committee under Level 3 by way of an appeal by the Complainant. Such appeal must be filed by the Complainant within 15 (Fifteen) days of the decision rendered by the self-regulating body of the Publisher of OCC under Level 2[18].
Conclusion
The OTT Guidelines represent an important development in India’s digital regulatory landscape, signalling a shift towards embedding inclusivity within the design and delivery of online content. They establish a framework that recognises accessibility as a core component of platform responsibility, while also reflecting a pragmatic approach to implementation, with a 36 (Thirty-Six) month timeline for compliance, i.e., by February 2029. Therefore, the OTT Guidelines mark a decisive move towards a more inclusive digital media ecosystem.
[1] Rule 2(u) of the IT Rules
[2] Clause 6.2 of the OTT Guidelines
[3] Explanation to Clause 6.2 of the OTT Guidelines.
[4] Clause 1.4 of the OTT Guidelines
[5] Clause 3.1 of the OTT Guidelines.
[6] Clause 3.2 of the OTT Guidelines.
[7] Clause 3.3 of the OTT Guidelines.
[8] Clause 4.1 of the OTT Guidelines.
[9] Clause 4.2 of the OTT Guidelines.
[10] Clause 5.1 of the OTT Guidelines.
[11] Clause 5.2 of the OTT Guidelines.
[12] Clause 5.3 of the OTT Guidelines
[13] Clause 7.3 of the OTT Guidelines
[14] Clause 7.4 of the OTT Guidelines.
[15] Clause 7.4 of the OTT Guidelines.
[16] Clause 7.5 of the OTT Guidelines.
[17] Clause 7.5 of the OTT Guidelines.
[18] Clauss 7.6 of the OTT Guidelines.
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