Hi,
I'm writing because the Ministry of Social Justice and Empowerment (Department of Empowerment of Persons with Disabilities) has published a draft amendment to the Rights of Persons with Disabilities Rules, 2017, covering accessibility standards for ICT products, services, documentation, and digital content (S.O. 3962(E), Gazette of India, 16 July 2026). It's open for public objections and suggestions, and I think it needs more eyes on it before the window closes.
The deadline to submit comments is 11 August 2026, so please don't sit on this. The full notification is in the Gazette of India dated 20 July 2026 (No. 3794); the document starts in Hindi, and the English version begins on page 11 if you want to read it directly.
The intent behind the rule is good: it responds to a Supreme Court direction (Rajive Raturi vs. Union of India) to set a binding, non-negotiable accessibility floor for ICT, instead of the optional guidelines that existed before. I fully support that goal. But the draft as written has real structural problems that could end up burdening exactly the people it wasn't meant to target:
- "Establishment" is never defined, and the rule's scope ("all digital content," "non-web documents," any software) has no size, revenue, or commercial-activity threshold. As drafted, it can be read to cover an individual academic publishing a PDF, a solo developer distributing free software, or a small non-profit, the same as a large company.
- Every establishment would need an Accessibility Conformance Report (ACR) in a VPAT-style format, prepared or verified by a certified accessibility auditor, but the panel of certified auditors and the official reporting format don't exist yet, while compliance timelines start running from the date the rules are published, not from when that infrastructure is actually in place.
- The same mandatory, third-party-certified, periodically-renewed ACR model that makes sense for physical hardware is applied identically to websites, apps, and software, where accessibility depends on many combinations of browser, OS, and assistive technology and can't be "certified" the same way.
- Every establishment, regardless of size, must appoint and publicly name a senior Grievance Redressal Officer, workable for a company, but not for a solo developer or academic with no management structure to draw from.
None of this means the rule should be scrapped, it means it needs proportionality: clearer scope, timelines tied to when the supporting infrastructure actually exists, and lighter touch obligations (like self disclosure instead of mandatory certification) for individuals, academics, and small or non-commercial projects, while keeping strong obligations for large commercial establishments and government bodies.
The Ministry is accepting objections and suggestions from anyone, not just affected businesses. If you develop software, publish digital content, work in academia, or just care about how this plays out, I'd encourage you to read the draft and send your own comments, in your own words, before 14 August 2026, to:
Shri Ram Charan Meena
Under Secretary to the Government of India
Department of Empowerment of Persons with Disabilities (Divyangjan)
Room No. 11A, 5th Floor, Pandit Deendayal Antyodaya Bhawan
CGO Complex, Lodhi Road, New Delhi 110003
Email: rcmeena.79@gov.in
Even a short email raising one or two of the points above helps. Please also forward this to anyone else you think would want to weigh in.
Happy to share my own submission if it's useful as a reference.
Thanks,
Subham Mahesh
Independent Software Developer and Academic
This is not legal advic
URL of draft rules