Digital KYC must include reasonable accommodation and accessible alternatives for persons with disabilities.

Accessibility and reasonable accommodation are integral to equality, dignity and non-discrimination, so digital KYC, e-KYC and V-CIP systems used for essential services must provide workable alternatives for persons with blindness, low vision and facial disfigurement. Where verification depends on inaccessible visual or facial tasks, regulated entities must adopt inclusive modes such as assistive methods, alternative signatures or thumb impressions, and accessibility audits. Stronger regulatory directions and modified guidelines were required to align onboarding and customer due diligence with disability rights obligations, and to prevent exclusion from financial, telecom and related services.

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Issues: (i) Whether the digital KYC, e-KYC and V-CIP framework, as implemented by regulated entities, must be made accessible to persons with disabilities through reasonable accommodation and alternative modes of verification; (ii) Whether the respondents were required to issue or modify guidelines, directions and accessibility standards to ensure inclusive onboarding, verification and service access for persons with blindness, low vision and facial disfigurement.

Issue (i): Whether the digital KYC, e-KYC and V-CIP framework, as implemented by regulated entities, must be made accessible to persons with disabilities through reasonable accommodation and alternative modes of verification.

Analysis: The governing constitutional and statutory framework recognises equality, dignity, non-discrimination, accessibility and reasonable accommodation as enforceable obligations. The rights of persons with disabilities extend to access to financial, telecom and other essential services, and digital systems cannot be designed or implemented in a manner that excludes persons with blindness, low vision or facial disfigurement. A verification regime that depends on inaccessible visual or facial tasks, without suitable alternatives, creates barriers inconsistent with the disability rights framework and the guarantee of life with dignity.

Conclusion: The issue is answered in favour of the petitioners. Digital KYC processes must admit accessible alternatives and reasonable accommodations.

Issue (ii): Whether the respondents were required to issue or modify guidelines, directions and accessibility standards to ensure inclusive onboarding, verification and service access for persons with blindness, low vision and facial disfigurement.

Analysis: The Court found that the existing regulatory framework already contains the seeds of accessibility, but its implementation required stronger and more explicit directions. Regulated entities must follow accessibility standards, undergo accessibility audits, accommodate assistive methods, accept alternative forms of signature or thumb impression, and ensure that customer due diligence is not defeated by inaccessible design. The respondents' regulatory powers and statutory duties justified issuance of concrete directions to align digital KYC practices with accessibility obligations and to prevent exclusion from essential services.

Conclusion: The issue is answered in favour of the petitioners. The respondents were directed to issue and implement accessibility-oriented guidelines and modifications.

Final Conclusion: The writ petitions were allowed in substance by issuing binding directions to make digital KYC and related verification systems accessible, inclusive and compliant with disability rights norms.

Ratio Decidendi: Accessibility and reasonable accommodation are integral components of the right to equality and the right to life with dignity, and digital verification systems used for essential services must be designed and regulated so as not to exclude persons with disabilities.

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