On 12 December 2025 (published on 5 January 2026), the Department of Empowerment of Persons with Disabilities invited public feedback on the Draft Revised Rules to amend the Rights of Persons with Disabilities Rules, 2017—specifically on non-negotiable accessibility standards for the built environment.

The intent behind this exercise is welcome. It appears aimed at reducing confusion caused by multiple, overlapping accessibility standards and clarifying their hierarchy and application. However, from the perspective of long-term accessibility practitioners, several critical gaps and risks remain.

1. Reliance on NBC 2016

The Draft Rules heavily reference NBC 2016, even though NBC 2026 is expected shortly. Once NBC 2026 is notified, clause numbers—and in some cases content—will change, making the Rules instantly outdated. Deferring notification until NBC 2026 is finalised would avoid avoidable re-amendments.

2. Clause references without accessible text

The Rules rely on clause numbers from NBC, IRC, and Indian Standards without reproducing the actual provisions. This creates two problems:

• Many of these documents are paid and not freely accessible
• Clause-based references become unstable when codes are revised

Embedding the actual accessibility provisions directly in the Rules would improve transparency, access, and long-term validity.

3. Conflicts across multiple codes

Accessibility provisions are drawn from NBC, IRC, and IS codes without clarifying hierarchy or resolving conflicts. A clear example is accessible parking—where NBC and IRC prescribe different numbers and dimensions. Incorrect clause references in the Draft further compound confusion. Without explicit conflict resolution, implementation on the ground will remain inconsistent.

4. Missing building typologies

Apart from transport facilities, the Draft Rules do not clearly address typology-specific requirements for schools, offices, hotels, housing, cultural or sports facilities. These were previously covered under 2017 provisions. The absence of clarity risks contradictory interpretations and uneven enforcement. Typology-specific, non-negotiable requirements must be explicitly stated.

5. Strengthening NBC 2026

This revision is an opportunity to strengthen NBC 2026 by correcting known errors, addressing inter-part conflicts (notably between Parts 3 and 4), incorporating lived user experience, and addressing neurodiversity. Accessibility should be embedded across NBC—not confined to one section.

6. Applicability and transition clarity

Frequent revisions without clear applicability dates and transition provisions lead to duplication of work, wasted resources, and confusion. Clear timelines are essential.

7. New vs existing buildings

The Rules must clearly distinguish between non-negotiable provisions for new buildings and realistic requirements for existing buildings. This distinction is currently unclear.

8. Toilet layouts need reconsideration

Mandating centre-placed WC layouts (Type A / peninsular) raises serious safety, usability, and independence concerns for wheelchair users. These concerns have been clearly articulated in British Standard BS 8300, which cautions that a peninsular WC layout is appropriate only where an assistant is available. This is because drop-down support rails do not provide sufficient stability for independent transfers and the absence of a side wall can create feelings of insecurity. BS 8300 further states that a single unisex accessible toilet with a peninsular WC layout for assisted use should not be provided as a substitute for separate unisex accessible toilets with handed corner layouts, nor as a replacement for a Changing Places toilet. Where provided, it should only be an additional facility. International best-practice standards therefore consistently caution against mandating this layout for independent use. Additional concerns arise with the NBC Type B toilet option referenced in NBC, which is smaller in size and does not accommodate a full 1800 mm turning circle required for larger wheelchairs. In contrast, the toilet configurations prescribed under the Harmonised Guidelines 2021—such as corner WC layouts with fixed wall-mounted grab bars and larger clear dimensions—offer significantly better safety, stability, and functional independence. These configurations should be retained and strengthened in the Revised Rules, rather than diluted.

9. Accessibility goes beyond buildings

Accessible buildings can still be unusable if products, ICT systems, and services are inaccessible. Lifts, kiosks, DCS panels, turnstiles, software interfaces, and emergency systems must meet accessibility standards. Equally important is mandatory training of facility and security staff.

10. Enforcement is the missing link

Despite legal mandates, approvals and Occupancy Certificates are routinely issued without accessibility compliance. The Rules must embed enforceable mechanisms—mandatory access audits, empanelled auditor sign-offs, and clear linkage to approvals and OCs.

In conclusion

Without enforceable procedures and clarity at approval and certification stages, accessibility will continue to be inconsistently implemented. These Revised Rules are an opportunity to move from intent to impact—if they are strengthened with clarity, consistency, and accountability.

Rama Krishnamachari
Director, DEOC Accessibility Services Private Limited
Accessibility Professional – IAAP CPABE (Advanced) and Rick Hansen Foundation Accessibility Certification
Postgraduate in Special Education
Over 35 years of professional experience in accessibility and inclusion

Ruchira Sarin
Director and Principal Architect, DEOC Accessibility Services Private Limited Architect
Over 25 years of professional experience in Universal Design and accessible built environments