OTT players urge MIB for sandbox rollout of accessibility norms, cite UN’s voluntary approach

India’s streaming industry has raised alarm over potential cost escalations arising from the government’s draft accessibility guidelines, warning that mandatory retrofitting of entire content libraries could strain balance sheets and disrupt smaller players. The Ministry of Information and Broadcasting’s proposal to make 100% of OTT content accessible within two years, platforms say, would require significant investment in production, technology, and manpower.

MIB has released draft Guidelines for Accessibility of Content on Platforms of Publishers of Online Curated Content (OTT Platforms). The draft, issued on October 7, 2025, seeks to ensure that persons with hearing and visual impairments can access and enjoy online content through features like closed captions, audio descriptions, and Indian Sign Language (ISL) interpretation.

Public comments on the draft have been invited until November 7, 2025. But even as the consultation process begins, several OTT platforms have voiced sharp concerns, calling parts of the proposal “impractical,” “financially prohibitive,” and “disproportionate” to the sector’s current capacity.

Call for Regulatory Sandbox and Phased Rollout

To make the rollout more feasible, OTT platforms have urged the Ministry to adopt a regulatory sandbox approach. This would involve pilot testing of accessibility standards on a limited scale before making them mandatory across the sector.

“It would be pragmatic for the MIB to first collaborate with public broadcasters or select large platforms to pilot accessibility standards,” one executive suggested. “This will help assess real-world feasibility, costs, and technology requirements before extending them industry-wide.”

The industry has proposed that instead of quarterly progress reports, platforms should file an annual self-certification confirming compliance with baseline requirements for new content. “Quarterly reports make sense for large-scale regulatory monitoring, but accessibility is a gradual process,” said another platform executive. “An annual self-declaration would balance accountability with operational flexibility.”

Industry Flags Compliance Burden

The major contention raised by OTT platforms is Clause 4.2 of the draft guidelines, which requires platforms to make 100% of their existing content libraries accessible within 24 months of the guidelines’ publication. OTT platforms say that while they support the principle of accessibility, the proposed schedule is unworkable given the volume and diversity of content on digital platforms.

“Transforming thousands of hours of existing content to meet accessibility standards within two years is operationally impracticable and financially unviable,” said a senior executive at a leading global streaming platform, requesting anonymity. “Unlike new productions, legacy content—especially licensed titles—does not have the rights or assets to add features like captions or audio descriptions.”

Industry stakeholders also argue that a one-size-fits-all approach could have “a cascading adverse impact” on the digital content ecosystem. Smaller and regional players, particularly those focused on short-format or micro-drama content, are unsure if the guidelines would apply to them and say blanket compliance requirements could disrupt their operations.

A senior executive of an Indian regional OTT platform noted, “The guidelines are well-intentioned, but the cost and operational load will hit smaller platforms the hardest. Without a graded rollout or financial support mechanism, compliance could threaten the viability of niche players.”

“Cost of Compliance Could Be Prohibitive”

According to industry estimates, implementing accessibility features across large content libraries could run into crores of rupees annually, factoring in vendor costs for transcription, ISL interpretation, and audio description, alongside additional infrastructure requirements.

“Accessibility implementation is not a plug-and-play exercise—it demands specialized workflows, quality checks, and human oversight,” said an executive from an international OTT major. “For smaller Indian players with limited budgets, this could be a significant compliance cost.”

Platforms have also sought clarity on the applicability of guidelines to archival content and the extent of retroactive implementation. Many players argue that retrofitting old content should not be mandatory and that the focus should remain on new releases.

UN Convention Cited, Voluntary Approach Urged

Several platforms also pointed out that the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD)—which India is a signatory to—follows a facilitative rather than binding approach. The Convention uses terms like “shall take appropriate measures” and “encouraging participation,” implying that governments should lead through incentives and collaboration rather than compulsion.

“The spirit of the UNCRPD is about encouraging accessibility, not imposing uniform mandates. The MIB should reflect that by framing the guidelines as an enabling framework, not an enforcement tool,” said an OTT legal expert.

For the government, the initiative is part of its broader push toward inclusivity and accessibility in the digital domain. The MIB has cited Article 14 of the Constitution and the Rights of Persons with Disabilities (RPwD) Act, 2016, which obligate the state to promote barrier-free access to information and communication systems.

The Ministry has proposed forming a monitoring committee, chaired by a Joint Secretary-level officer, to oversee enforcement, address grievances, and ensure consistency in implementation. The draft aligns with India’s Accessible India Campaign (Sugamya Bharat Abhiyan) and draws from international benchmarks such as the Web Content Accessibility Guidelines (WCAG).

Under the proposed framework, accessibility implementation will be divided into two phases.

Phase I, beginning six months after notification, mandates that all new content include at least one accessibility feature—captioning, audio description, or ISL interpretation.

Phase II sets targets for existing content libraries—30% accessibility in 12 months, 60% in 18 months, and full coverage within two years.

The Ministry has also proposed exemptions for live and short-form content, acknowledging the technical limitations of real-time accessibility integration.

MIB Should Be Practical

While the MIB’s initiative marks a major step toward inclusivity in India’s booming digital entertainment sector, the pushback from industry signals a challenging road ahead.

“Everyone agrees on the importance of accessibility,” said a member from the Internet and Mobile Association of India (IAMAI). “The question is how to balance ambition with feasibility. India needs accessibility standards that are both progressive and practical.”

The public consultation process will conclude on November 7, 2025, following which the Ministry will finalize the guidelines. Industry insiders say the government may need to revisit timelines and consider a staggered rollout to ensure compliance without stifling innovation.

“Accessibility is a shared responsibility,” said a senior OTT industry representative. “We’re ready to collaborate—but the framework must be achievable.”

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