The over-the-top (OTT) platforms, working in alignment with industry bodies the Internet and Mobile Association of India (IAMAI) and the Indian Broadcasting & Digital Foundation (IBDF), have raised concern over the Ministry of Information and Broadcasting’s draft accessibility guidelines for streaming services.
While the sector supports the government’s objective of improving content accessibility for persons with disabilities, the OTT platforms said the proposed rules are impractical, financially onerous, and risk hurting India’s rapidly expanding digital video market.
The ministry issued the Draft Guidelines for Accessibility of Content on Online Curated Content Platforms on October 7. In their submissions, the platforms such as Netflix, Prime Video, SonyLIV and ZEE5, argued that the draft guidelines do not adequately account for how digital content is produced, licensed and delivered, nor for the operational complexity of large, multilingual content pipelines that refresh daily.
Under the proposed rules, all new content on a streaming platform must carry at least one accessibility feature, including closed or open captions, audio description (AD), or Indian Sign Language (ISL) in two phases.
Platforms said this is unworkable for daily or fast-turnaround episodes and technically infeasible for their vast legacy libraries. They highlighted that creating accessibility files is resource-intensive, with AD or captioning costing between Rs 15,000 and Rs 20,000 per episode, and costs rising significantly across multiple languages. Although artificial intelligence (AI) tools can assist, accuracy remains a concern.
The platforms also flagged the aggressive timelines laid out. The rules require all new content to be made accessible within six months of notification and mandate full retrofitting of existing libraries within 24 months.
The OTT players said this is neither operationally nor financially viable, given the size of catalogues, the rights constraints on licensed content, and the tight production-to-publishing schedules for daily programming. They warned that mandatory retrofitting could hit smaller and regional platforms the hardest, reduce content diversity, and divert investment away from original programming and innovation.
A key argument raised by the platforms is that the Rights of Persons with Disabilities Act places responsibility for ensuring accessible media on the government and local authorities, not private streaming services.
They pointed out that the UN Convention on the Rights of Persons with Disabilities uses language such as “urging” and “encouraging” private entities rather than mandating direct compliance. Imposing accessibility obligations through subordinate legislation, they said, exceeds the legislative intent of the RPwD Act.
To make the framework workable, platforms proposed a more flexible and phased roadmap. They recommended applying obligations only to “baseline” new content produced two years after notification and allowing OTT services to choose from a menu of accessibility options based on feasibility.
They also sought flexibility to offer accessibility features in at least one language — such as the original language or English — rather than across all audio tracks.
For smoother rollout, they suggested piloting accessibility standards through a regulatory sandbox, potentially in partnership with public broadcaster Prasar Bharati, for one to two years before enforcement.
They also requested clearer exemptions for live sports, reality and award shows, music content, archived libraries, long-running daily shows, advertisements and third-party licensed titles.
The platforms urged the government to create a centralised support mechanism to help produce subtitles, captions, AD and ISL files, and asked for deletion of Clause 4.2, which mandates retroactive accessibility for entire content libraries.
The OTT platforms said they remain committed to improving accessibility but emphasised that the guidelines must be recalibrated to remain practical, proportionate and sustainable for India’s digital streaming ecosystem.
While the sector supports the government’s objective of improving content accessibility for persons with disabilities, the OTT platforms said the proposed rules are impractical, financially onerous, and risk hurting India’s rapidly expanding digital video market.
The ministry issued the Draft Guidelines for Accessibility of Content on Online Curated Content Platforms on October 7. In their submissions, the platforms such as Netflix, Prime Video, SonyLIV and ZEE5, argued that the draft guidelines do not adequately account for how digital content is produced, licensed and delivered, nor for the operational complexity of large, multilingual content pipelines that refresh daily.
Under the proposed rules, all new content on a streaming platform must carry at least one accessibility feature, including closed or open captions, audio description (AD), or Indian Sign Language (ISL) in two phases.
Platforms said this is unworkable for daily or fast-turnaround episodes and technically infeasible for their vast legacy libraries. They highlighted that creating accessibility files is resource-intensive, with AD or captioning costing between Rs 15,000 and Rs 20,000 per episode, and costs rising significantly across multiple languages. Although artificial intelligence (AI) tools can assist, accuracy remains a concern.
The platforms also flagged the aggressive timelines laid out. The rules require all new content to be made accessible within six months of notification and mandate full retrofitting of existing libraries within 24 months.
The OTT players said this is neither operationally nor financially viable, given the size of catalogues, the rights constraints on licensed content, and the tight production-to-publishing schedules for daily programming. They warned that mandatory retrofitting could hit smaller and regional platforms the hardest, reduce content diversity, and divert investment away from original programming and innovation.
A key argument raised by the platforms is that the Rights of Persons with Disabilities Act places responsibility for ensuring accessible media on the government and local authorities, not private streaming services.
They pointed out that the UN Convention on the Rights of Persons with Disabilities uses language such as “urging” and “encouraging” private entities rather than mandating direct compliance. Imposing accessibility obligations through subordinate legislation, they said, exceeds the legislative intent of the RPwD Act.
To make the framework workable, platforms proposed a more flexible and phased roadmap. They recommended applying obligations only to “baseline” new content produced two years after notification and allowing OTT services to choose from a menu of accessibility options based on feasibility.
They also sought flexibility to offer accessibility features in at least one language — such as the original language or English — rather than across all audio tracks.
For smoother rollout, they suggested piloting accessibility standards through a regulatory sandbox, potentially in partnership with public broadcaster Prasar Bharati, for one to two years before enforcement.
They also requested clearer exemptions for live sports, reality and award shows, music content, archived libraries, long-running daily shows, advertisements and third-party licensed titles.
The platforms urged the government to create a centralised support mechanism to help produce subtitles, captions, AD and ISL files, and asked for deletion of Clause 4.2, which mandates retroactive accessibility for entire content libraries.
The OTT platforms said they remain committed to improving accessibility but emphasised that the guidelines must be recalibrated to remain practical, proportionate and sustainable for India’s digital streaming ecosystem.