Digital Accessibility for 30 crore Indians — Part 1

Time for Fintech and Insurance industry to adopt accessibility guidelines

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Digital accessibility just became non-optional. In recent judgments in the April 2025 Supreme Court Order, the RBI Circular, and IS-17802 mandatory compliance is converging for Indian financial industry including fintechs, banks and insurance companies.

In this three-part article series, I try to unfold why making digital systems accessible is not only a compliance issue, but an essential requirement today for 30 crore indians.

Declaration: No AI was used to generate this content. All inputs are originally from the author.

The Problem of Digital Accessibility for 30 Crore Indians

Digital systems and their ease of access are commonplace now. However, the majority of 30 crore indians (including about 16 crore people above the age of 60) are classified as having one or the other digital accessibility challenges

Here are some of the case examples.

Take, e.g., Asha, who is 31. She has been blind since childhood. She has a job, an income, a credit history, and — for the last three months — a strong reason to take out a home loan.

She has tried three Indian Housing Finance websites. On all three, her screen reader announced the home page as “image, image, image, link, link, link.” Form fields had no labels. Buttons said “Click here” with no context. She gave up before reaching the EMI calculator on any of them.

Asha is a customer who is now legally protected by the law. She is also a customer, and the law now legally requires you to serve. And if you run a fintech, NBFC, HFC, bank, or insurance company in India, you almost certainly cannot serve her today.

What I have stated above is not a hypothesis. It’s measurable and a fairly common scenario.

At InfoAxon, we have run the accessibility scan against the home pages of over a dozen Indian financial services brands in the past two months.

The median Lighthouse accessibility score is in the 40s.

Several are below 20.

A good score should be at least 80.

Already, the Indian fintech and insurance companies have all of them have started receiving — or will shortly start receiving — regulatory advisories that turn this from a “nice to have” into a board-level compliance item.

The definition of digital accessibility is actually quite simple: “Anyone visiting your site, mobile app, or any digital channel should be able to use it without any issues”. In this, anyone specially people with disabilities who can not usually access the product, or see the screen, or have low vision or similar, should be able to access your digital channels.

In a more technical friendly definition, one can say that Digital accessibility is the practice of building digital products that work for people regardless of how they use the web. That includes users who:

  1. Cannot use or see the screen without the help of a screen reader
  2. Having no or very low vision thus has a need to increase the text, contrast, or magnify the screen.
  3. Unable to use a mouse because of motor impairment, some kind of repetitive strain injury, restricted movement of hands, or trembling hands. Such users often use voice control or switches to manage digital equipment or browse websites.
  4. People with cognitive or learning differences — People with dyslexia, ADHD, slower processing, who need clear instructions, language aids, and predictive layout.
  5. People with listening abilities, Deaf or hard of hearing, and requiring image captions, transcripts, and visual alternatives to audio cues.
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Estimates Indians under coverage of Digital Accessibility needs

Often when you see Government web sites in India, try accessing them on mobile, or imagine a person with accessibility limitations accessing the site its very apparant that we need to be far more sensitive and inclusive to their needs.

Now that it is a legal requirement, fintech and insurance companies at least need to ramp up their accessibility posture. There are many reasons for indian businesses to fast ramp up on digital accessibility.

  1. Litigation risks — As per Supreme court of India regulations under RPwD Sec 89 are now mandatory. The law of the land is demanding digital accessibility. The risks of class action suits remains.
  2. Regulatory requirements — RBI (Reserve Bank of India) and NHB (National Health Bureau) now expect accessibility evidence in quarterly audits. Without an ACR (Accessibility Conformance Report), the entity sits is at risk.
  3. Branding advantages — calling yourself out as a digitally accessiblity ready business with certification scores leads to overall rise in credibility.
  4. Customer Reach — Churn is reduced with 30 Crore indians

What Digital Accessibility means in an Indian context

The international standard for “accessible” is the W3C’s Web Content Accessibility Guidelines version 2.1 at Level AA.

WCAG 2.1 AA defines 50 testable success criteria across four principles: a page must be Perceivable, Operable, Understandable, and Robust.

India’s national standard for ICT accessibility — IS-17802, published by the Bureau of Indian Standards — is the technical adoption of the European EN 301 549 v3.2.1 standard, which incorporates WCAG 2.1 AA wholesale and adds India-specific clauses around the 22 Indian languages, Indian Sign Language, captioning, and documentation accessibility.

We have done a detailed study of the recent laws, mapping them with a common accessibility criteria that mixes the scoring techniques using three scoring approaches.

  1. WCAG 2.1 AA tools (The core standard to be achieved, which is an absolute minimum to comply)
  2. AXE (A test accessibility engine used to measure accessibility)
  3. WAVE (Evaluation tools mainly for content authors to make the content published

Measuring Digital Accessibility Scores — Composite Scores in an Indian Context

We went further and created a composite scoring approach that is a mix of all three common standards of measuring accessibility.

This was needed because the available mechanisms cater to different kind of scoring assessments. For e.g. the AXE method is more tuned to measure in terms of HTML accessibility and more fits the detailed criteria for engineering teams. But at the same time the WAVE evaluation tools are more aligned to scoring the content and whether the content publishes is accessible when rendered into a page.

The next chapter will be on how fintech and insurance organizations can quickly move to digital accessiblity future using the technology frameworks and composite scoring.

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Datum: 26-07-14