National Policy on Universal Electronic Accessibility – An Analysis

They not only make life easier for people in general, but have the potential to revolutionise the lives of persons with disabilities through larger inclusion and participation in these areas and by enabling independent living through use of appropriate assistive technologies (ATs).

In the year 2010, the erstwhile Department of Information Technology, Government of India circulated a draft consultation paper on the National Policy for Electronic Accessibility that sought to regulate the provision of accessible Electronics and ICTs services and products and universal design concepts for persons with disabilities. Post consultation and deliberation, the Government of India has passed the National Policy on Universal Electronic Accessibility (National Policy) in 2013. This is a brief analysis of the policy and the provisions therein.

The draft consultation paper had clearly identified the requirements of persons with disabilities that had to be kept in view while designing electronic accessibility solutions:

• Eliminating discrimination on the basis of disabilities and facilitating equal access to Information and Communication Technologies and Electronics (ICTE)
• Understanding the diversity of persons with disabilities and creating solutions for their specific needs
• Ensuring that accessibility standards and guidelines and universal design concepts are adopted and adhered to.

While the draft consultation paper only sought to provide equal access to ICTE products and services to persons with disabilities, the objective of the National Policy has been expanded to include not just equal but also barrier free access. The category of disabilities has also been expanded to include mental disabilities. Further, the policy seeks to facilitate local language support and sync universal access with barrier free access that should be usable without adaptation.

The scope of the National Policy continues to cover access to ICTE products and services to persons with disabilities in the areas of universal design, assistive technologies and independent living aids as in the draft consultation paper, but the National Policy expands on the broad roles and functions of the major stakeholders.

The National Policy clearly defines the following points that were not discussed in the Draft Consultation Paper:

• The Department of Electronics and Technology is named as the nodal authority for monitoring the implementation of the policy.
• Recommends constitution of a high level advisory committee of multiple stakeholders – central and state. ministries and department, industry, academia, disabled persons organisations and persons with disabilities for guiding and implementing the policy.
• Recommends an amendment in the Information Technology (IT) Act to protect persons with disabilities who inadvertently break the law.
• Lays emphasis on providing support in local languages to accessible Electronics and ICTs.

The strategy and Action Plan defined in the Draft Consultation Paper have been augmented and restructured to include the following points described in the National Policy:

Creating awareness on universal electronics accessibility and universal design

• The National Policy specifically provides that the Department of Electronics and Information Technology will play the lead role.
• Other central and state ministries, departments and agencies will also be responsible.
• Carried out through Media, campaigns, conferences, workshops and seminars.
• Will also include available and emerging assistive technologies and independent living aids and schemes.
• Information to be made available in public domain in local languages in accessible format.

Capacity building and Infrastructure Development

• The National Policy requires that schemes for capacity building on accessibility and assistive technologies be taken up within the government and for persons with disabilities.

Education and Assistive Technologies Centres

• Accessibility standards and guidelines and universal design concepts to be included in the curriculum of Electronics and ICTs education.
• Assistive technologies and independent living aids to be included in the curriculum of Special Education and Rehabilitation.
• Model Electronics and ICTs centres to be set up to provide training and demonstration to special educators and persons with disabilities including persons with mental disabilities.

Conducting research and development

• To develop assistive technologies and independent living aids based on accessibility standards and guidelines and universal design concepts
• To provide incentives for the research and development of such products
• To formulate schemes to support research and development organisations for developing such products
• To include persons with disabilities and rehabilitation professionals in formulation, implementation and monitoring the schemes.

Accessibility Standards

• The draft consultation paper provides that the accessibility standards and guidelines be taken or modified from existing standards and guidelines in accessibility
• The National Policy specifically names existing accessibility standards and guidelines such as the following as examples

1. W3C Accessibility Standards
2. ATAG (Authoring Tools Accessibility Guidelines)
3. WCAG 2.0 (Web Content Accessibility Guidelines)
4. UAAG (User Agent Accessibility Guidelines)

• Accessibility compliance would be monitored for government websites, websites for disability issues, general citizen centric websites and important websites with high traffic or high consumer transaction.

Accessible format for content

• Content published in electronic format including text books, journals, publications, multimedia etc  are required to be published in accessible format
• Support in local languages to be provided for all content

Developing programmes and schemes

• The National Policy lays emphasis on schemes for women and children with disabilities

Developing procurement guidelines for Electronics and ICTs for accessibility and assistive needs

• The draft Consultation Paper merely states that ICTE procurement guidelines and processes should include accessibility standards and guidelines.
• The National Policy requires that Electronics and ICTs procurement policies be evolved to confirm to the requirements of the National Policy.
• Higher cost of accessibility compliant hardware and software to be budgeted for at procurement.
• Incentives to be provided by the government to assist with the procurement of such products.
• Any scheme formulated by the central or state governments for persons with disabilities should be linked with ongoing schemes for universal electronic accessibility.

Affordable Access

• The Draft Consultation Paper requires that schemes be formulated to provide access to ICTE services and products to persons with disabilities at affordable costs.
• Information about these schemes to be made available in the public domain in local languages in accessible format.
• The National Policy promotes open source usage to meet affordable access requirements.