“WAVES – I think we have such a big country, and the maximum number of films are made here. The world’s biggest creative industry is here. So, I am establishing a huge movement. I am going to gather the creative world here. The world’s creative centre will be India,” said Prime Minister Modi while speaking to Diljit Dosanjh, in reference to the World Audio Visual Entertainment Summit (WAVES) organised by the Ministry of Information & Broadcasting (MIB) in Mumbai, from May 1-4, 2025. Dosanjh, Shah Rukh Khan, Akshay Kumar and other celebrities have amplified the PM’s vision, aiming to make India the world’s entertainment content hub.
WAVES presents an opportune event to establish India’s leadership on another big idea that is rapidly taking root in the entertainment industry: “Accessibility”, thanks to the legal and policy efforts of disability rights groups. All new content in films, on TV, and Over-The-Top (OTT) must be “born” accessible and not retrofitted for accessibility as an afterthought. It means the creation and inclusion of accessibility features like Same Language Captions/Subtitles (SLC/S), English translated captions, Audio Description (AD) and Indian Sign Language (ISL) into any professionally produced content’s Digital Content Package (DCP). For the life of any content property, it remains accessible in all licensing, distribution and consumption scenarios.
By embracing accessibility at WAVES, India can become a global hub for accessible content in entertainment. The all-content-born-accessible initiative in India will benefit approximately 80 million Deaf and Hard of Hearing (DHH) individuals and 70 million Visually Impaired (VI) people. What is less obvious is that accessible media will provide significant value to the majority of hearing and sighted individuals as well, both in India and globally.
The social returns of accessible media in improving the reading literacy skills of 600 million weak readers and the language skills of more than a billion viewers nationally are not marginal secondary benefits. An aging population will always need support for hearing and visual impairments, which are vitally important for living a fuller life and preventing cognitive decline. Thus, an investment in accessible content is an investment in every Indian.
The Supreme Court of India and the Delhi High Court laid the legal and policy foundation for the implementation of media accessibility via several pathbreaking judgements in 2024-25. SC ruled in the Rajive Raturi v. Union of India (2024) case that all the accessibility standards framed by the ministries under the Rights of Persons with Disabilities (RPwD) Act, 2016, cannot be merely recommendatory guidelines but need to have mandatory accessibility standards.
MIB’s Accessibility Standards for TV, 2019 recommend that 50 per cent of all General Entertainment Content on TV be made accessible to the DHH by 2025. A hundred odd TV programmes currently carry SLC/S. Still, it is less than one-tenth of the recommended quantum. Besides, these standards do not mention any feature for the VI. The SC had given the government till today, March 7, to specify the mandatory aspects of media accessibility on TV.
India’s challenge at WAVES is to achieve global standards of accessibility, while emerging as a global content hub. Most countries that have mandated accessibility on TV, like the US, UK, Canada, Australia and New Zealand, require it on 80-90 per cent content. In the US, “the Federal Communications Commission (FCC) mandates that most television programs must include Closed Captioning (CC).” In the UK, Public Service Broadcasters (PSBs), including channels like BBC, ITV, Channel 4, and Channel 5, are required to caption at least 90 per cent of their programming. Most of the major broadcasters in the UK subtitle 90 per cent or more of their programming, while smaller channels typically subtitle at least 80 per cent of their content.
The mandatory floor that MIB sets for TV should therefore be well above 50 per cent, currently mentioned in the recommended standards. This can be achieved by considering a separate policy for new and existing content. On all new entertainment content, there is no reason why access cannot be 100 per cent, or close to it, at par with global standards. On existing content, access retrofitting can be a gradual ramp up, which is already specified in the Accessibility Standards for TV, 2019, but not notified.
The precedence for universal accessibility on new content is available in MIB’s own accessibility standards for films, notified in March 2024. The Central Board of Film Certification (CBFC) requires all films in more than two languages, submitted for certification after September 2024, to include SLC/S and AD files, corresponding to every audio language and not just the master language in which the film is released. After March 2026, all new films, including single language films, will need to do the same.
Technologically, OTT platforms are a natural fit for accessible content. Disability rights activists have moved the Delhi HC to require all films, especially those released after September 2024, in more than two languages and presumably born accessible, to be hosted as accessible on OTT. In response, the court has asked MIB to frame accessibility standards for OTT. The framing and notification of such standards is necessary because the history of industry self-regulation of media access has shown that it tends to result in patchy and token implementation.
India’s entertainment ecosystem is looking forward to WAVES as an annual gathering of creative talent and an economic engine for the industry. WAVES can establish India as a powerhouse of ‘accessible’ content, for entertainment and the development aspirations of 1.4 billion citizens.
Kothari is an adjunct professor at IIT-Delhi’s School of Public Policy and lead, Billion Readers (BIRD). Mohandas is BIRD’s lead, Legal Affairs
