Comments on the draft Policy on IT Accessibility for People with Disabilities

We welcome the initiative of the MEITY to formulate a policy/ set of guidelines to implement electronic accessibility for persons with disabilities within the government and provide our comments to the draft document below:

Accessibility of the document:

The present document is not completely accessible. The first two Annexures cannot be read at all using a screen reader and there is also scope for improving accessibility in the rest of the document. Given the government’s policy requiring electronic accessibility and the nature of this document itself, this error may be rectified immediately. A good resource for creating accessible electronic documents is available at https://help.rnib.org.uk/help/daily-living/technology/accessible-documents

Title and content presentation:

The present title reads- ‘Policy for IT Accessibility for people with disabilities”. This may be rephrased to - Policy for Implementing IT accessibility for persons with disabilities so that its purpose is clear and differentiated from the National Policy on Universal Electronics Accessibility. The policy may be broadly divided into four main aspects- Content and communication, technology, training and procurement, since these are the four areas where specific interventions are required and have different needs and associated standards.

Preliminary sections:

The policy would benefit from clearly articulated vision, objectives, scope, applicability and statement.

Content and communication:

All communication, including documents and publications, whether print or electronic, should be universally accessible. This could include documents, mails, invoices, leaflets etc. We recommend use of Unicode, EPUB 3, EPUB 3 Accessibility Guidelines and WCAG 2.0 (level AA) as the standards to be followed while creating and publishing electronic documents and information. The need to use Unicode for regional languages is especially emphasised, as also the need to provide alternatives in case of scanned notifications and documents. We would also like to stress the need to use alternate modes of communication for transactions such as Alternative mode of authentication other than visual captcha (IE: One time password (OTP), logical reasoning (2+2) etc.)

Accessibility of technologies:

ICT accessibility interventions for different disabilities- This section should be circulated to experts of different disabilities to get their inputs. Attention may be given to also providing technology options such as the screen reader NVDA which are open source, efficient and work with indian languages. Overall, it is recommended that this section, recognises that persons with disabilities be provided with suitable assistive technologies and accessible technologies to enable them to work efficiently. The illustrative list of disabilitywise technologies may be provided as annexures to the policy/ guidelines and not be part of the main document.

Click to read the full submission here; and see the Policy and Guidelines here