India’s approach to artificial intelligence governance is currently shaped by a principle-based framework aimed at enabling innovation while managing systemic risk. The India AI Governance Guidelines, issued under the policy stewardship of the Ministry of Electronics and Information Technology, position themselves as non-prescriptive, forward-looking, and adaptable across sectors. As AI systems increasingly mediate access to public services, finance, education, healthcare, and digital identity, an important question arises: do these guidelines meaningfully address digital accessibility?
This article examines the document carefully, without presuming intent or omission, to understand whether digital accessibility is addressed, how it is framed indirectly, and what the implications are for organisations building or deploying AI systems in India.
Is Digital Accessibility Explicitly Mentioned?
The answer is straightforward: no.
The AI Governance Guidelines do not explicitly reference:
- Digital accessibility
- Web or mobile accessibility
- Persons with disabilities
- Assistive technologies
- Accessibility standards such as WCAG
Accessibility does not appear as a named principle, requirement, or risk category.
Where Digital Accessibility Appears Indirectly in the Guidelines
Although digital accessibility is not named, certain principles intersect conceptually with accessibility concerns. These intersections, however, remain implicit rather than operational.
People-First AI
The guidelines emphasise human-centric and people-first AI development, highlighting human oversight and empowerment.
What is missing is a definition of “people” that accounts for diverse abilities, sensory access, or interaction needs. Without this clarity, accessibility remains an assumed outcome rather than a design requirement.
Fairness and Equity
Fairness is framed primarily in terms of:
- Bias mitigation
- Non-discriminatory outcomes
- Protection of vulnerable groups
However, this focus is largely on decision-making harms. It does not address access barriers that prevent users from interacting with AI-driven systems in the first place.
This distinction matters. A system can be unbiased in its outputs yet inaccessible at the interface level.
Understandable by Design
The requirement for AI systems to be understandable focuses on:
- Transparency
- Explainability
- Disclosure of AI use
While this aligns partially with cognitive clarity, it does not cover:
- Perceivability of content
- Keyboard or non-visual operability
- Compatibility with assistive technologies
In accessibility terms, this principle addresses comprehension, not access.
Digital Public Infrastructure (DPI)
The guidelines strongly promote Digital Public Infrastructure as a means to deliver AI at a population scale.
At this scale, assumed accessibility becomes a structural risk. If accessibility is not explicitly embedded, exclusion can scale just as efficiently as inclusion.
What the AI Guidelines Are Optimised For
It is important to acknowledge the document’s intent.
The AI Governance Guidelines prioritise:
- Innovation enablement
- Risk mitigation at a systemic level
- Interoperability across sectors
- Avoidance of premature regulatory burden
From this perspective, the absence of explicit digital accessibility language may reflect a deliberate choice to defer implementation-level requirements to sectoral regulators and future standards.
This makes the omission understandable, though not inconsequential.
Digital Accessibility in Indian Law: The RPwD Act Context
Any discussion on digital accessibility in India must be situated within the country’s existing legal framework. The Rights of Persons with Disabilities Act, 2016, establishes enforceable obligations to ensure equal access for persons with disabilities, including access to information and communication technologies.
Section 42 of the Act places a responsibility on the government to make digital content, electronic media, and information systems accessible, and to promote universal design and reasonable accommodation. These obligations apply irrespective of whether a system is AI-driven or not.
In this context, the AI Governance Guidelines do not operate in a legal vacuum. While the guidelines are explicitly non-binding and principle-based, AI systems deployed in India are already subject to statutory accessibility requirements under the RPwD Act. The absence of an explicit reference to digital accessibility in the governance framework, therefore, reflects a policy-level gap rather than a lack of legal obligation.
This distinction matters for organisations interpreting the guidelines. Compliance with AI governance principles does not automatically imply compliance with accessibility law. Without explicit alignment, there is a risk that accessibility is treated as external to AI governance rather than as a foundational requirement that already applies.
Why Digital Accessibility Still Matters at the Governance Level
Accessibility concerns arise before issues of bias, fairness, or explainability can be evaluated. If a user cannot perceive information, operate an interface, or understand or navigate a system, then governance safeguards related to fairness or accountability become irrelevant to that user.
At a governance level, accessibility functions as:
- A prerequisite for inclusion
- A risk-reduction mechanism
- A determinant of who can participate in AI-mediated systems at all
When accessibility is not named early, it risks being treated as optional or deferred to post-deployment fixes.
Implications for Organisations Building AI in India
For organisations aligning with India’s AI Governance Guidelines, this has practical consequences:
- Compliance with governance principles does not guarantee accessibility
- AI systems can meet policy expectations while remaining unusable for disabled users
- Accessibility gaps can translate into legal, reputational, and operational risks as regulation evolves
Accessibility should therefore be treated as part of responsible AI practice, not as an external compliance exercise.
A Measured Way Forward
Rather than prescribing mandates, a neutral path forward could include:
- Explicit recognition of digital accessibility under people-first and fairness principles
- Sector-specific accessibility guidance for AI systems in public services, finance, healthcare, and education
- Treating access barriers as a form of AI harm within risk assessments
Such steps would strengthen governance without undermining innovation
India’s AI Governance Guidelines provide a strong foundation for responsible and scalable AI adoption. However, digital accessibility currently remains implicit rather than explicit.
As AI systems increasingly mediate access to essential services, clarifying this gap will become critical, not as a moral add-on, but as a governance necessity that determines who can meaningfully participate in India’s digital future.
Organisations developing AI-based products or services may benefit from embedding digital accessibility early. Our team collaborates with product and policy teams to provide support. Contact us by filling out the form below to get started.