The Government of Karnataka has drafted and published the Bill dated 24 November 2025. Suggestions are invited within 30 days from the date of publication in the Official Gazette. Suggestions may be addressed to the Principal Secretary to Government, Labour Department, Vikasa Soudha, Dr. B.R. Ambedkar Veedhi, Bengaluru.

Why This Bill Matters?

This Bill is a welcome move to advance disability inclusion and strengthen accountability in private-sector employment in Karnataka. While it covers both employment and education, this note focuses only on employment provisions.

Private-sector employment of persons with disabilities remains extremely low. According to an NCPEDP study of the top 100 companies, persons with disabilities represented only 0.28% of the workforce. This Bill has the potential to bring accountability to the private sector and push forward meaningful employment of persons with disabilities.

However, reservation alone will not lead to sustainable outcomes unless backed by enabling measures such as clear policy directives, accessibility, awareness, reasonable accommodation, and inclusive workplace practices. These supportive mechanisms are not elaborated in detail within the Bill and require strengthening.

While penalties for non-compliance are included, there is a risk that some employers may simply pay the fines rather than make genuine efforts to hire and retain persons with disabilities. This aspect requires closer examination.

Therefore, it is important for the disability sector—people with disabilities, organisations, advocates, researchers, and professionals—to review the Bill closely, provide suggestions within the prescribed timelines, and actively advocate for provisions that ensure meaningful implementation and long-term inclusion.

Who the Bill Applies To?

The bill applies to private establishments including industries, factories, shops and commercial establishments covered under the Karnataka Shops and Commercial Establishments Act, 1961.

Key Employment Provisions

• Employers must not discriminate in recruitment, selection, promotion, training, transfer, service conditions or retrenchment.
• Employers must provide reasonable accommodation unless it causes undue hardship. Refusal to provide reasonable accommodation must include written justification and alternatives offered.
• Promotion cannot be denied on grounds of disability.
• Employees who acquire a disability cannot be removed or downgraded and must be placed in suitable roles or supernumerary posts.
• Establishments employing 20 or more persons must reserve 5% of sanctioned posts for persons with disabilities.
• Employers shall ensure reasonable distribution of reserved posts among categories of disability in accordance with a formula notified by the State Regulatory Authority to avoid concentration in a single category.
• Reservation shall be implemented in phases. Employers shall submit an annual compliance plan to the State Regulatory Authority as prescribed. The State Government shall notify phased timelines.
• Posts may be exempted from reservation only where the essential functions cannot be performed even after reasonable accommodation; such exemption shall be recorded in writing and is subject to review by the State Regulatory Authority
• Employers must annually disclose sanctioned posts, persons with disabilities employed, carried-forward vacancies and measures taken on reasonable accommodation.
• Employers must appoint a Grievance Redressal Officer.
• Employers must submit compliance reports and enable anonymised data sharing.
• The Bill provides for constitution of State Advisory Committee, State Regulatory Authority, District Regulatory Officers and State Enforcement Authority.
• Penalties include fine up to ₹10,000 for first violation and ₹50,000 to ₹5,00,000 for subsequent violations. Failure or refusal to furnish information to the Authority shall attract a fine up to ₹25,000 and an additional ₹1,000 per day for continued refusal after notice. Corrective orders may include public disclosure of non-compliance, mandatory training and compliance plans.
• State Government may notify incentives including tax benefits, preference in procurement, certification such as “Inclusive Employer/Institution”, and recognition awards.

Areas for Strengthening the Bill

While the Bill reflects strong intent and a solid foundation and it would be welcome to see it enacted, the following enhancements could significantly improve its effectiveness and real-world outcome.

1. Require Employers to Submit Accessibility and Inclusion Plans: The Bill currently requires educational institutions to prepare Accessibility and Inclusion Plans but does not extend this requirement to employers. Employers should also be mandated to develop such plans in prescribed formats. These plans should include workplace accessibility measures (physical, digital, and communication-related), equal opportunity policies and governance mechanisms for review and monitoring. This will help ensure that reservation translates into meaningful inclusion rather than merely procedural compliance.
2. Appointment of Disability Inclusion Officers: The Bill presently mandates the appointment of Grievance Redressal Officers. However, to make inclusion operational, it should explicitly require Disability Inclusion Officers—preferably persons with lived disability experience and expertise in cross-disability inclusion, reasonable accommodation, disability law, and accessible recruitment. The RPWD Rules already require appointment of Liaison Officers; this Bill should strengthen that mandate by defining their skills, duties, accountability, and nomenclature. The term Disability Inclusion Officer better reflects a proactive role that enables inclusion, rather than one limited to grievance redressal.
3. Provide Structured Support: The State should introduce support mechanisms similar to the UK’s “Access to Work” model, which provides grants for assistive devices, job coaches, interpreters and communication support, workplace adaptations, and disability-related travel costs. Such support—both financial and technical—would reduce implementation barriers and enable employers to meaningfully onboard, accommodate, and retain persons with disabilities.
4. Spell Out Incentives Clearly: Although the Bill mentions incentives and the RPWD Act contains similar provisions, these have not translated into meaningful uptake. The State should clearly specify the tax incentives that will be available to employers, and define the nature of preferential procurement eligibility and other benefits. Clear articulation of these incentives will ensure that employers receive tangible support rather than nominal entitlements, thereby encouraging meaningful implementation of the Bill.
5. Reform Penalty Mechanisms: A penalty ceiling of ₹5 lakh may not serve as a deterrent for large organisations. Penalties should be proportionate and linked to organisational size, turnover, and repeated non-compliance, ensuring that it is more costly to avoid compliance than to implement inclusive practices.

Conclusion

This Bill has the potential to transform disability-inclusive employment in Karnataka and serve as a model for other states. For the Bill to deliver real change, implementation measures must:

• strengthen accountability,
• mandate employers to provide policy-level commitment, accessibility and an enabling work environment,
• provide practical support to employers so that reservation translates into meaningful employment outcomes,
• mandate appointment of a Disability Inclusion Officer and professionalise the role, and
• build enabling structures that support continued, meaningful participation of persons with disabilities in the workforce.

The disability sector should come together to draft specific clause-by-clause recommendations so that incorporation into the Bill becomes possible. Time is limited, as the deadline for submitting suggestions is 24th December 2025.