Comments received on ICT report

[Amar Jain]

Dear all,

I am in receipt of the comments provided by various stakeholders on the ICT report submitted by us. Request each member to go through the same and submit your recommendations latest by Monday morning.

We had to finalise our report by 12th September but I have got the comments just now from the department. Hence requested for short extension.

Thank you.

Regards,

Amar Jain

[Bhavani Shankar R]

Thanks Amar..

Kindly request you to attach the report on the email or a google drive
link so that it would be helpful for review

Thanks a lot again for all the good work

Regards,


--
Bhavani Shankar
Ubuntu Developer | www.ubuntu.com
https://launchpad.net/~bhavi

[Amar Jain]

Due to file size limitations the report did not come through. Please see
attached a compressed report.

Regards,
Amar Jain

[Bhavani Shankar R]

On Thu, Sep 11, 2025 at 3:32 PM Amar Jain <amar...@amarjain.com> wrote:
>
> Due to file size limitations the report did not come through. Please see
> attached a compressed report.
>

Thanks a lot..

[Bhavani Shankar R]

On Thu, Sep 11, 2025 at 3:44 PM Bhavani Shankar R
<right2b...@gmail.com> wrote:
>
> On Thu, Sep 11, 2025 at 3:32 PM Amar Jain <amar...@amarjain.com> wrote:
> >
> > Due to file size limitations the report did not come through. Please see
> > attached a compressed report.
> >
>
> Thanks a lot..
>

Dear Amar and everyone,

Thank you again for providing us the document for review..

I have gone through the record for the Draft Accessibility Standards
for ICT Products and Services and the annexures.

In the first instance, I wish to express appreciation for the
considerable work taken to draft these guidelines, demonstrating an
immense commitment to inclusive digital transformation.

These are my own reflections and proposals, articulated simply and
clearly, because I am of the opinion that clarity and precision are
cardinal when designing something as fundamental as accessibility
norms:

Mandatory Quality Certification:
It’s a no-brainer that any website or application serving the public
should undergo standardized quality certification under MeitY or BIS
frameworks. This prevents subjective interpretations of accessibility
and raises the accountability bar across the board.

Born Accessible, Stay Accessible:
Accessibility is not an afterthought. The draft rightfully emphasizes
that content must be “born accessible.” However, we need stronger
enforcement on preserving accessibility throughout the entire content
lifecycle. Every update, patch, or migration should explicitly mandate
re-validation of accessibility features.

Same Language Captions (SLC):
In a multilingual country like India, mandating SLC isn’t just
necessary; it’s inevitable. Without this, we fail the very people we
are trying to empower. The draft does well to specify this, but I
strongly suggest removing any ambiguity around terminology by
uniformly using "Same Language Captions" in all legal documents.

Clarity on Applicability:
The term “any other products based on ICT” is far too vague. Let’s add
an annexure listing examples (ATMs, e-learning portals, biometric
devices, etc.) so no one can misinterpret scope or dodge
responsibility.

Penalties and Incentives:
I would personally argue for a transparent, graded penalty system
illustrating ranges based on severity and context. But also, let’s
encourage voluntary corrections by providing a window before
enforcement hits hard. That’s how real compliance culture is built.

ACR Visibility & Machine-Readable Formats:
Mandating machine-readable formats (JSON/XML) for Accessibility
Conformance Reports (ACRs) will hugely facilitate real-time monitoring
of compliance. Small MSMEs can be hand-held here I think on a personal
note, and therefore, a toolkit or automated ACR generator to be
released by BIS can be a game-changer.

Extraterritorial Enforcement:
A special mention: ICT services that are accessible from India but
originate from abroad must be explicitly covered. Let’s clarify this
in the rules to prevent loopholes, making sure that global players
don’t escape accountability.

Feedback Loops:
A strong recommendation from me: The final draft should
institutionalize a mechanism for continuous feedback, corrections, and
iterative improvements based on actual user experience from Persons
with Disabilities (PwD) groups.

Technical Standards Evolution:
We cannot lock into WCAG 2.1 forever as I believe personally that the
standards must incorporate a clause for automatic or periodic review
against future WCAG versions on a rolling basis for forward
compatibility and backward fallback, particularly 2.2 and the upcoming
WCAG 3.0.

In summary, it provides an opportunity for building a benchmark for
the world at large by creating an inclusively digital world that moves
beyond the level of compliance and mainstream accessibility into the
very architecture of digital India.

Thank you for your hard work for a more inclusive world. I am happy at
any moment to address these issues more or help where I can in my own
small way.

Warm regards,