Comments on the Draft Accessibility Standards for the Built Environment Sector

On May 21, 2025, the Department of Empowerment of Persons with Disabilities, Ministry of Social Justice & Empowerment, invited comments from stakeholders and the public on the draft accessibility standards for the Built Environment sector. These standards lay down non-negotiable rules to ensure the creation of barrier-free environments in line with the Rights of Persons with Disabilities Act, 2016 (RPwD Act, 2016).

In response, Vidhi Centre for Legal Policy has submitted detailed comments on the draft accessibility standards. Drawing from our ongoing project on ‘Building Better Cities’, which focuses on improving compliance with accessibility mandates for public buildings, our submission offers recommendations to strengthen the language of the draft and provides suggestions to promote effective implementation of comprehensive accessibility standards.

You may read our submissions below, or access the document here: 

Our key recommendations include:

To strengthen the drafting of the standards:

1. To promote clarity and consensus-based uptake, it may be helpful for the draft standards to elucidate the rationale behind the classification and selection of certain provisions as non-negotiable and mandatory.
2. The Rules could benefit from greater clarity on their applicability to retrofitting of existing public buildings that have already been issued completion certificates and are currently in use.
3. It may be useful to clarify how standards from the National Building Code, 2016 (NBC) and the Indian Roads Congress (IRC) are to be incorporated within the binding legal framework under the RPwD Act, 2016, (especially given the NBC is a non-statutory document).
4. Enhancing the accessibility and transparency of the standards themselves
5. The inclusion of updated and context-specific standards from the Harmonised Guidelines and Standards for Universal Accessibility in India, 2021 – such as those addressing Indian-style toilets and stretcher-compatible lifts – could help align the draft standards more closely with local needs and conditions in India.

To strengthen implementation of the standards:

1. Establishing a clearly defined accountability mechanism could support more coordinated and effective implementation of the draft standards. 
2. Further, appointing District Accessibility Officers may help streamline local-level coordination and monitoring.
3. The draft standards could explicitly reference the requirement under Section 45(2) of the RPwD Act, 2016 for a time-bound action plan for retrofitting essential public buildings.
4. Mandating periodic, independent, and high-quality accessibility audits could strengthen oversight and course correction.
5. Regular accessibility training for competent authorities and implementing agencies could enhance their awareness and capacity.
6. To ensure comprehensive inclusivity, the draft standards may include provisions that address the access needs of neurodiverse individuals (such as quiet rooms in crowded waiting places), and also encourage the integration of tech-enabled solutions in infrastructure design.

About the Authors

Manmayi Sharma (Senior Resident Fellow)

Manmayi is a Senior Resident Fellow working with Disability (Inclusion & Access). Manmayi is a graduate of the National University of Advanced Legal Studies, Kochi (2016). Prior to joining Vidhi, Manmayi worked at the law firm of Dhir & Dhir Associates, where she litigated and provided advisory services to various clients in matters pertaining to the Insolvency and Bankruptcy Code. She has also previously worked with the Centre for Law and Policy Research, where she litigated in the areas of public health, women's rights and rights of disabled.

Rahul Bajaj (Senior Associate Fellow)

Rahul Bajaj is Senior Associate Fellow [Disability Rights] at the Vidhi Centre for Legal Policy. In this role, Rahul works with Vidhi's Disability Inclusion and Access team to provide high quality thought leadership on legal policy issues concerning persons with disabilities, assists the team with various origination and engaged projects, spearheads the team's strategic litigation efforts and assists in building mutually beneficial partnerships. Rahul is also a practicing lawyer in the courts of Delhi and the Co-Founder of an NGO called Mission Accessibility which also works on advancing the rights of the disabled. Rahul's prior experiences including working in the Disputes Practice in Trilegal, Delhi, pursuing two masters in law degrees from the University of Oxford as a Rhodes Scholar and clerking for the current Chief Justice of India, D.Y. Chandrachud.

Somya Jain (Research Fellow)

Somya is a Research Fellow with the Disability (Inclusion and Access) Team at Vidhi, New Delhi wherein she primarily focuses on inclusive education for children with disabilities. She graduated from Ram Manohar Lohia National Law University, Lucknow in 2022 with a specialization in Constitutional law. Prior to joining Vidhi, she worked as a LAMP (Legislative Assistant to Member of Parliament) Fellow to a Rajya Sabha MP. During her fellowship, she worked on matters related to representation of marginalized communities, accessible healthcare, inclusive education, and poverty and unemployment in Bihar. She assisted her MP in drafting four Private Members’ Bills on parliament productivity, private sector reservation, prevention of custodial torture and fraternity. Her interests lie in social policy including the rights of children and disadvantaged groups. In her free time, she likes to dance and read about politics and women centric issues.