Access and the law: Entertainment without barriers is a right, not a favour

In 2024, India produced over 130,000 hours of General Entertainment Content (GEC), of which 95% was first produced for television, 3% for film, and 2% for OTT (FICCI-EY, 2025). However, a significant volume of all content ultimately becomes available on OTT.

Any accessibility standards for India's media and entertainment (M&E) sector must contend with the complexity of content produced in 22 official languages and numerous dialects. This content is distributed through three modes – 900 television channels, 60 Over-The-Top (OTT) platforms, and 10,000 cinema screens nationwide – and consumed on a wide range of devices such as TVs, mobile phones, computers, and tablets.

In 2024, India produced over 130,000 hours of General Entertainment Content (GEC), of which 95 per cent was first produced for television, 3 per cent for film, and 2 per cent for OTT (FICCI-EY, 2025). However, a significant volume of all content ultimately becomes available on OTT.

Well over a billion people in India consume hours of entertainment content every day. In terms of reach, 85% of the population — or 1.2 billion people —have access to television. Video-on-Demand (VOD) reaches 40% of Indians or 550 million viewers. Cinema theatres, meanwhile, are accessible to just 11% of Indians, or about 150 million people.

Under the Rights of Persons with Disabilities (RPwD) Act, 2016, the Ministry of Information and Broadcasting took a laudable step by framing the Accessibility Standards (AS), 2019, for television. These recommend that half of all general entertainment content should be made accessible by 2025 to Deaf and Hard of Hearing (DHH) persons— by adding captions or Indian Sign Language (ISL). While the standards for television are yet to be formally notified, they have led to 84 TV programmes being telecast with Same Language Captions (SLC). This is a notable start but amounts to less than 5% compliance across television.

On the film front, MIB framed and notified the Cinematograph Rules (CR), 2024 —a bold policy that demonstrates the government’s commitment to media access. By September 2024, all films certified in two or more languages, a proxy for big-budget films, had to be made accessible to the hearing and visually impaired. This was a direct outcome of three blind and one deaf persons suing Yash Raj Films and winning to make the superhit film Pathaan accessible by adding SLC and Audio Description (AD). March 2026 onwards, all 1,500 annually certified films in India will need to be ‘born’ accessible.

With the partial policy success of media access on TV and the comprehensive mandate on films, disability rights groups now have OTT in their crosshairs. In December 2024, the Delhi High Court asked MIB to address the issue of media access on streaming. In response, MIB issued an advisory to OTTs recently that they must “fully comply with the RPwD Act, 2016, and the Code of Ethics prescribed under IT Rules, 2021”, and “ensure that content published on OTT platforms is fully compliant with various provisions of applicable laws of the land.” MIB’s advisory to OTTs is a step in the right direction but falls short of setting accessibility standards, as in the case of films.

The IT Code of Ethics, 2021, uses watered-down language (emphasis added): “Every publisher of online curated content shall, to the extent feasible, take reasonable efforts to improve the accessibility of online curated content transmitted by it to persons with disabilities through the implementation of appropriate access services.” But the MIB advisory asks for full compliance with the RPwD Act, 2016, which mandates that “persons with disabilities have access to electronic media by providing audio description, sign language interpretation and close captioning.”

The inherent contradiction is that the Code of Ethics asks OTTs to put in “reasonable efforts” while the Act mandates media accessibility in specific ways. The self-regulatory bodies of OTT platforms would be served better in the long run by setting a reasonable timeframe, after which all content on OTTs would be accessible to the hearing and visually impaired.

Across the M&E sector, it may be simpler for MIB to frame one unifying accessibility standard for video-based content, rather than separate ones for TV, films, and OTT. Start by changing the core definition of video from ‘audio’ plus ‘visuals’ to additionally include ‘text’, where text is the verbatim dialogue or lyrics in the same language as the audio. Not translation but transliteration.

AI tools can then leverage the time-coded text layer of any video to automatically create media access features like captions, AD, sign language(s), translation and dubbing.

Every professionally produced video content generally starts out as a script, but producers rarely maintain that script to its logical end, perfectly matching the final audio. M&E producers can start by maintaining, for every new film, episode, or show, a verbatim final script and making that final script an integral part of the content’s package of files for licensing and distribution. For the life of the video then, on any distribution platform or consumption device, accessibility features can easily be incorporated cost-effectively and turned on/off as needed. Importantly, video then becomes fully searchable with an underlying time-coded text layer.

Mumbai hosted the inaugural World Audio Visual and Entertainment Summit (WAVES) 2025 recently. India is rightfully taking its place as a leader in the M&E sector. As India emerges as a global hub of content creation, it is also in our DNA to be a champion of inclusive design and accessible content. When all content is born accessible, we all win.

(The writer is an adjunct professor at IIT-Delhi’s School of Public Policy and leads the Billion Readers initiative)