Every new OTT title will need captions or sign language plus an audio description, thirty-six months from the guidelines' publication

Every title an Indian OTT platform publishes will have to carry two access services: one of closed captioning, open captioning or Indian Sign Language for hearing-impaired viewers, and an audio description for visually impaired ones ^[13]. Content descriptors indicating those accessibility features have to be prominently displayed at the time of release, including for promotional audio-visual material ^[13]. The features themselves have to be integrated and made functional across the user interfaces of the platform ^[13].

Captions must carry music and non-speech sounds as well as dialogue, stay synchronised with speech at a readable speed, run from start to end, use mixed case rather than capitals, and sit clear of key visuals without overlapping or running off screen ^[4]. Indian Sign Language has to be delivered in picture-in-picture mode, with the interpreter's hands and facial expressions both visible ^[4]. An audio description is narration of visual elements such as scenes, settings, actions and costumes, delivered in the gaps in the dialogue ^[8]. Websites and mobile, smart-TV and desktop applications all have to be compatible with assistive technologies ^[4].

The obligation begins thirty-six months after the date the guidelines were published, and the document that carries it is dated 6 February 2026 ^[13]. Section 4.1 says the requirement applies in a phased manner and names no phase other than that single trigger ^[13].

The ministry's draft, published for comment on 7 October 2025 with comments solicited by 22 October, set the same obligation at six months ^[9]. The draft also gave the back catalogue a schedule: not less than 30 per cent of the total content library within twelve months, not less than 60 per cent within eighteen, and 100 per cent within twenty-four ^[10]. None of those three milestones appears in the final guidelines, which instead encourage publishers to add features to their content libraries progressively on a best effort basis, with no percentage and no date ^[2].

The final document is stricter than the draft in one respect: the draft let a publisher meet the visually impaired limb with either an audio description or Indian Sign Language ^[9]. The final guidelines move sign language to the hearing-impaired limb, which leaves an audio description as the only way to satisfy the other ^[13].

Three categories are exempt: live and deferred live content, audio content such as music and podcasts, and short form content, defined as standalone audiovisual content of ten minutes or less ^[6]. Advertisements fall inside that exemption, and the guidelines add that it applies to standalone content only and not to the individual episodes or segments of a title ^[6].

The first Accessibility Conformance Report is due on expiry of the same thirty-six months, quarterly progress reports follow, and the report covers newly published content rather than the whole library ^[5]. A Monitoring Committee chaired by an officer not below the rank of Joint Secretary meets every quarter to monitor implementation and redress grievances, above a three-tier route that begins with the publisher, who acknowledges a written grievance within twenty-four hours and decides it within fifteen days ^[7].

One inconsistency sits inside the document: section 3.1 says publishers shall strive to make audio descriptions available, a weaker formulation than the shall ensure of section 4.1, which covers the same feature ^[3]. The underlying duty is not new either, and predates both documents: section 42 of the Rights of Persons with Disabilities Act, 2016 already requires the appropriate Government to ensure that persons with disabilities have access to electronic media by providing audio description, sign language interpretation and close captioning ^[12].

What the record does not settle is when the clock started. Section 4.1 counts the thirty-six months from the date of publication of these Guidelines ^[13]. The government announced the guidelines on 27 March 2026, seven weeks after the date printed on the document, in a written reply to the Rajya Sabha that set out the two feature requirements and referred to a prescribed implementation schedule without stating the schedule or any compliance date ^[11]. Which of the two dates starts the count is not resolved on the face of the record ^[11].