TaxTMI 
TaxTMI 
2025 (5) TMI 48
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....sons with disabilities and other marginalised groups. True inclusion requires that technological advancements accommodate the diverse needs of all citizens, thereby fostering an environment where no individual is left behind. With this preface, we now proceed to examine the key issues involved in the cases before us. 3. While the petitioners in W.P(C) No.289 of 2024 are acid attack victims, who suffer from facial disfigurement and severe eye burns, the petitioner in W.P(C) No.49 of 2025 is suffering from 100% blindness. These writ petitions have been filed seeking directions to the various respondents to formulate appropriate rules and guidelines for conducting Digital KYC/ e-KYC / Video KYC process through alternative methods, with a view to ensuring that the process is more inclusive and accessible to all persons with disabilities-particularly acid attack survivors suffering from permanent facial/eye disfigurement and similarly placed individuals, including persons with blindness and low vision - in accordance with the provisions of the Rights of Persons with Disabilities Act, 2016 For short, "the RPwD Act, 2016", Rights of Persons with Disabilities Rules, 2017 For short, "the....
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....imilarly placed individuals to satisfy the "liveness" criterion by blinking their eyes for the purpose of completing the Digital KYC /e-KYC process, (vi) To direct RBI, SEBI, and TRAI to issue instructions to all public and private organisations and institutions regulated by them including banks, financial institutions, service providers, and intermediaries wherein KYC is conducted to adopt and/or follow offline and/or physical KYC procedures for acid attack survivors suffering from permanent eye-disfigurement and other similarly placed individuals who cannot blink their eyes for conducting the Digital KYC /e-KYC process, and (vii) To direct the Central Government, RBI, SEBI, and TRAI to sensitise all public and private establishments conducting the Digital KYC / e-KYC to actively assist acid attack survivors with permanent eye-disfigurement and similarly placed individuals in availing their banking, telecommunication and other financial services." W.P (C) No.49 of 2025 "(i) To direct the Central Government, Reserve Bank of India, Securities and Exchange Board of India, Pension Fund Regulatory and Development Authority, Insurance Regulatory and Develop....
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....ased relationships, conducting transactions, availing services and verifying his identity - whether as a customer or as a citizen accessing government schemes. These difficulties arise primarily because digital KYC / e-KYC / video KYC Hereinafter shortly referred to as "digital KYC" norms are not designed keeping in view the accessibility needs of persons with disabilities. Thus, the digital KYC process that excludes persons with disabilities is a violation of the fundamental rights enshrined under Article 21 of the Constitution of India. 5. Continuing further, the learned counsel for the petitioners submitted that vide RBI Master Direction, 2016, the digital KYC process has been made mandatory. Following this, all major sectors - including banking institutions, telecommunication companies, etc., require KYC as a mandatory part of their registration processes. Accordingly, digital KYC has now become indispensable for accessing essential services, such as opening a bank account, demat and trading accounts, SIM cards, pension accounts, insurance policies; any type of financial investment, such as mutual funds, etc., obtaining Director Identification Number from Ministry of Corpora....
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....nion Public Service Commission & Others (2021) 5 SCC 370, Rajive Raturi v. Union of India & Others (2018) 2 SCC 413, Disabled Rights Group & Anr. v. Union of India & Others (2018) 2 SCC 397, etc., wherein, this Court reiterated the fundamental duty of the State and its instrumentalities to safeguard the welfare, dignity and autonomy of persons with disabilities, in order to ensure their complete integration into the mainstream of society. Further, it emphasized the need for economic empowerment and inclusion of persons with disabilities. 8. Ultimately, the learned counsel for the petitioners submitted that considering the difficulties and barriers faced on account of the inaccessibility of the digital KYC process, this Court may pass appropriate directions to the respondent authorities. 9. Upon notice, learned counsel for the various respondents appeared before us and submitted their responses, both orally and in writing. For the sake of convenience, the same are summarised as under: 9.1 Respondent No.2 - Reserve Bank of India 9.1.1 It is submitted that the Central Government with an intention to prevent money laundering and to combat and prevent channelizing of money i....
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.... (ab) The proof of possession of Aadhaar number where offline verification cannot be carried out or any officially valid document or the equivalent e-document thereof containing the details of his identity and address; and (b) The Permanent Account Number or the equivalent e-document thereof or Form No. 60 as defined in Income-Tax Rules, 1962; and (c) Such other documents including in respect of the nature of business and financial status of the client, or the equivalent e-documents thereof as may be required by Reporting Entity. 9.1.4 It is further submitted that as per Rule 2(ab) of the Rules, 2005, "authentication" means the process as defined under Section 2(c) of the Aadhaar (Targeted Delivery of Financial and other subsidies, Benefits and Services) Act, 2016, which means the process by which the Aadhaar number along with demographic information or biometric information of an individual is submitted to the Central Identities Data Repository (CIDR) for its verification with respect to the correctness, or the lack thereof, on the basis of information available with it. 9.1.5 It is further submitted that under Rule 2(bba) of the Rules, 2005, "digital KY....
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....e the feature that only live photograph of the customer is captured and no printed or video-graphed photograph of the customer is captured. The background behind the customer while capturing live photograph should be of white colour and no other person shall come into the frame while capturing the live photograph of the customer. (f) Similarly, the live photograph of the original OVD or proof of possession of Aadhaar where offline verification cannot be carried out (placed horizontally), shall be captured vertically from above and water-marking in readable form as mentioned above shall be done. No skew or tilt in the mobile device shall be there while capturing the live photograph of the original documents. (g) The live photograph of the customer and his original documents shall be captured in proper light so that they are clearly readable and identifiable. (h) Thereafter, all the entries in the CAF shall be filled as per the documents and information furnished by the customer. In those documents where Quick Response (QR) code is available, such details can be auto-populated by scanning the QR code instead of manual filing the details. For example, in cas....
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...., the CAF shall be digitally signed by authorized officer of the RE who will take a print of CAF, get signatures/thumb-impression of customer at appropriate place, then scan and upload the same in system. Original hard copy may be returned to the customer. 9.1.8 Thus, the requirement to conduct due diligence of its clients by the banking companies and the financial institutions is mandated under the provisions of the PMLA and the Rules, 2005, and that, the process of verifying the documents submitted by the clients is also included in various rules and regulations as well as Acts as stated above. Hence, the Reserve Bank of India in compliance with Rule 9(14) of the Rules 2005, has issued the Reserve Bank of India (Know Your Customer KYC) Directions, 2016, thereby reproducing and reiterating the process and procedure prescribed in the PMLA Rules, 2005. 9.1.9 In reply to the submissions made on the side of the petitioners, it is submitted by the learned counsel for the RBI as under: (a) RBI is not an appropriate authority to carry out amendments so as to include the specific suggestions of the petitioners in the already elaborated and described process of digital KY....
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.... not result in denial of banking/financial facility to members of the general public, especially those, who are financially or socially disadvantaged. (d) According to RBI, the guidelines regarding V-CIP are already in place. As per paragraph 4 of the MD on KYC, the Regulated Entities are directed to have a KYC policy duly approved by the Board of Directors. Furthermore, the Regulated Entities are also mandated under the MD on KYC to ensure that they comply and follow the directions issued by RBI. (e) Referring to Clause 3(ii) of the Aadhaar (Authentication and Offline Verification) Regulation 2021, it is submitted that in terms of proviso (i) to paragraph 16 of the MD on KYC, when a customer submits Aadhaar number under paragraph 16(a), the Regulated Entities shall carry out authentication of the customer's Aadhaar number using e-KYC authentication facility provided by the Unique Identification Authority of India. e-KYC authentication can be carried out through biometric e-KYC authentication or OTP based e-KYC authentication (face to face). 9.1.10 Thus, it is submitted by the learned counsel, adherence to the guidelines/ notifications/directions issued by RBI ....
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.....3.3 It is further submitted that as per the direction of this Court in Avishek Goenka v. Union of India in W.P.(C) No.285 of 2010, a Joint Expert Committee was constituted in the Department of Telecommunications and based on the report submitted by the Committee, instructions dated 09.08.2012 in Letter No. 800-09/20010-VAS titled as "Instruction on Verification of New Mobile subscribers (Pre-paid and Post-paid)" came to be issued. The said instructions laid down KYC provisions for issuing mobile connections to individual, outstation, foreign and business category customers. There are also additional provisions dealing with mobile connections obtained on fake / forged documents, timely disconnections in case of KYC non-compliance or directions of Law Enforcement Agencies, etc. That apart, various documents have been allowed as valid proof of identity/ proof of address documents for obtaining mobile connections. 9.3.4 It is further submitted that on 03.04.2019 vide Letter No. 800-26/2016- AS.II, Instructions for Alternate Digital KYC process for issuing new mobile connections to subscribers were introduced by the Department of Telecommunications, wherein it was stated that the Cu....
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....ted biometrically and demographic details are fetched from the UIDAI database. Live photograph of the customer is taken and matched with the photo received from UIDAI. 9.3.8 Pursuant to the instructions issued by the Department of Telecommunications vide Letter No. 800-09/2023-AS II dated 31.08.2023, additional strict measures have been incorporated into the KYC process viz., (a) end user KYC in business connections, (b)use of Digital-KYC/e-KYC process in case of SIM swap / replacement, and (c) other enhanced safeguards. 9.3.9 It is submitted that the Department of Telecommunications is continuously committed to improving the KYC process and make it user friendly. With passage of time, the KYC process has improved, attaining better verification norms and maintaining the orderly growth of the telecommunications sector. In order to enhance security and authenticity of the KYC process adopted by licensees, the Department of Telecommunications issued instructions on 05.12.2023 for the discontinuation of the paper - based KYC process with effect from 01.01.2024. 9.3.10 Pursuant to the grievance expressed by the first petitioner in WP(C) No. 289 of 2024 vide communication dated ....
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.... application for completing digital KYC to enable seamless, real-time, secured, end-to-end encrypted audio-visual interaction with the client. Digital KYC is an additional option available to the investors, along with the option of physical KYC. Thus, a person who, due to blindness or low vision is unable to e-sign a document, can opt for offline/ physical KYC and affix a thumb impression instead of signature. 9.4.4 Further, as mentioned in para 5 of the FAQs titled as "FAQs on Demat Account and Trading Account by Persons with Disability" issued by Respondent No.7, if a person with disability is unable to sign for himself / herself, the account can be opened with the signature of the guardian. 9.4.5 It is further submitted that Clause 47 provides for cancelled cheque for capturing bank details of the client. It also provides that verification of the bank account details can be carried out through Penny Drop Mechanism or any other mechanism using the API of the Bank. SEBI is open to include other possible documents that may be used by the registered intermediaries for capturing the bank details of the clients. 9.4.6 Regarding the requirement of liveliness check as provided ....
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....ed online, documents have been provided through Digilocker or any other source which could be verified online. These are additional options available to all investors including persons with blindness/ low vision. 9.4.9 It is further submitted that the FAQs have been put in place to guide the investors and market participants. Such interpretations are valid being transparent and applied consistently without discrimination. It is reiterated that SEBI is committed to the cause of enabling equal access of services of its registered intermediaries to persons with disabilities, including persons with visual impairments and has complied with the directions issued by the Chief Commissioner for PwD from time to time in this regard. At the same time, it is imperative for SEBI as the Regulator of securities market to build in / retain necessary checks to ensure that the securities market platforms are secured. 9.5. Respondent No.8 - Pension Fund Regulatory & Development Authority (PFRDA) 9.5.1 It is submitted that PFRDA is a statutory authority established by the Government of India under the Pension Fund Regulatory Authority and Development Authority Act, 2013 For short, "the PFRDA ....
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....es in respect of the facilities and services pertaining to pension schemes regulated by PFRDA. Clause 3.1 of the said Guidelines pertaining to Accessibility of website and application for visually impaired persons, mandate the intermediaries to design and develop user-friendly website and app (with the enablement of text-to-speech software) in such a way that they are accessible by all persons including visually impaired. Further, these Guidelines have been sent to intermediaries for ensuring compliance. That apart, the said Guidelines also mandate PFRDA regulated intermediaries to implement the following: (a) 'Guidelines for India Government Websites and Apps' (GIGW) as amended issued by Ministry of Electronics and Information Technology (MEITY) which prescribes accessibility standards for websites and apps. (b) Indian standards IS 17802 (Part 1), 2021 and IS 17802 (Part 2), 2022, issued by MEITY and notified by the Bureau of Indian Standards (BIS) which prescribes accessibility standards for Information and Communication Technology (ICT) products and services. 9.5.4 In response to the submissions made by the petitioners regarding the challenges faced by them,....
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....isual impairments, including taking all reasonable measures to comply with existing accessibility norms. This respondent is further committed to complying with any directions issued by this court to enhance accessibility in the digital KYC process for persons with disabilities. 9.6 Respondent No.9 - Insurance Regulatory and Development Authority of India 9.6.1 It is submitted that in terms of the provisions of the Prevention of Money Laundering Act, 2002, and the Prevention of Money Laundering (Maintenance of Records) Rules, 2005, this respondent has issued Master Guidelines on Anti Money Laundering/Counter Terrorist Financing (AML/CFT) 2022 on 01.08.2022, which provides framework related to KYC for issuance sector. 9.6.2 It is further submitted that as per the regulatory framework put in place, this respondent did not make digital KYC and VBIP mandatory and it is being provided as one among many options for customer identification process. Both digital and VBIP are assisted by Authorised Officials / Persons of REs. These officials / persons can assist customers in completing KYC by taking photos, aligning camera, aligning documents, etc. Further, paragraph M of digital KY....
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...."MD on KYC". The Master Direction on KYC prescribes the framework for Customer Due Diligence (CDD) procedures and outlines the digital KYC process under Chapter VI and Annex I, respectively. Additionally, Clause 18 of the MD on KYC introduced the Video based - Customer Identification Process (V-CIP) enabling remote customer verification through secure, real-time video interaction. As a result, multiple sectors - including banking, telecommunications, insurance, and mutual funds - have adopted digital KYC as a mandatory component of their CDD or Customer Identification Program (CIP) obligations, thereby facilitating identity verification of prospective customers in compliance with regulatory requirements. 13. According to the petitioners, while it is mandatory for Regulated Entities to conduct offline verification at the ground level, many Regulated Entities have refused to do so, even when customers submit valid proof of possession of Aadhaar in compliance with sub-clause (aa) of paragraph 16 of the MD on KYC. Secondly, under Option 2, if a customer submits an Offline Based Document (OBD) or an equivalent e-document, the Regulated Entities are required to verify the customer's d....
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....d Services" (Part I & II) issued in 2021 and 2022, as notified by the Central Government under Section 40 of the Rights of Persons with Disabilities Act, 2016, by way of amendment to Rule 15(1) of the Rights of Persons with Disabilities Rules, 2017, notified on May 10, 2023. (ii) Inaccessibility of biometric devices - All biometric devices presently designed for Aadhaar authentication, where the Aadhaar number is captured or information is displayed on screen, do not comply with IS 17802 Accessibility Standards for ICT Products and Services. As a result, there is no text-to-speech facility or other accessibility features available to assist persons with blindness in inputting relevant information or in verifying the information entered or displayed on screen. (iii) Lack of awareness - Officials and third-party agents deployed by regulated entities, including officials responsible for concurrent audits, are not adequately trained or sensitized to assist persons with blindness in performing digital KYC or in facilitating the digital KYC process for them. Many persons with blindness are either asked to physically visit the office of the entity (which, in the case of ....
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....lement and reads as under: "The State shall, within the limits of its economic capacity and development, make effective provision for securing the right to work, to education, and to public assistance in cases of unemployment, old age, sickness and disablement, and in other cases of undeserved want." 14.2 United Nations Convention on the Rights of Persons with Disabilities (UNCRPD) 14.2.1 India signed the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD), 2006, on 30th March, 2007 and ratified it on 1st October, 2007. The Convention came into force in the country with effect from 3rd May 2008. It places the following three important obligations on each State Party: (i) To respect the rights and freedoms of persons with disabilities. (ii) To protect individuals with disabilities from rights violations by others. (iii) To fulfil these rights by taking appropriate legislative, administrative, and policy measures. 14.2.2 Article 9 of the UNCRPD deals with Accessibility and reads as follows: "(1) To enable persons with disabilities to live independently and participate fully in all aspects of life, States ....
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....eality in the Asia - Pacific region. Notably, ICT (Information and Communication Technology) accessibility is specifically referenced in Goal 3 of the strategy. This goal emphasizes the need to enhance access to the physical environment, public transportation, knowledge, information, and communication systems for persons with disabilities. 14.4 RPwD Act, 2016 and RPwD Rules, 2017 14.4.1 The Government of India had enacted The Rights of Persons with Disabilities Act, 2016 to give effect to the United Nations Convention on the Rights of Persons with Disabilities and for matters connected therewith or incidental thereto. 14.4.2 The RPwD Act, 2016 marks a paradigm shift from the earlier medical and technical model of disability under the 1995 Act, which carried a significant burden of stigma. The new model recognizes disability as a condition arising not only from impairments but also from physical, mental, intellectual, social, psycho-social, and other barriers that hinder full and effective participation in society. These barriers lie at the heart of the exclusion experienced by persons with disabilities, preventing them from realizing their full potential and participating ....
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.... "The Central Government shall, in consultation with the Chief Commissioner, formulate rules for persons with disabilities laying down the standards of accessibility for the physical environment, transportation, information and communications, including appropriate technologies and systems, and other facilities and services provided to the public in urban and rural areas." 14.4.9 Section 42 of the RPwD Act, 2016, deals with 'Access to information and communication technology'. This section requires the appropriate Government to take measures to ensure that- (i) all contents available in audio, print and electronic media are in accessible format; (ii) persons with disabilities have access to electronic media by providing audio description, sign language interpretation and close captioning; (iii) electronic goods and equipment which are meant for everyday use are available in universal design. 14.4.10 Section 46 provides 'time limit for accessibility by service provides'. According to this provision, the service providers whether Government or private shall provide services in accordance with the rules on accessibility formulated by the Central Government under section....
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....ties and Elderly Persons as issued by the Government of India, Ministry of Urban Development in March, 2016; (b) standard for Bus Body Code for transportation system as specified in the notification of the Government of India in the Ministry of Road Transport and Highways, vide number G.S.R. 895(E), dated the 20th September, 2016; (c) Information and Communication Technology- (i) website standard as specified in the guidelines for Indian Government websites, as adopted by Department of Administrative Reforms and Public Grievances, Government of India; (ii) documents to be placed on websites shall be in Electronic Publication (ePUB) or Optical Character Reader (OCR) based pdf format: Provided that the standard of accessibility in respect of other services and facilities shall be specified by the Central Government within a period of six months from the date of notification of these rules. (2) The respective Ministries and Departments shall ensure compliance of the standards of accessibility specified under this rule through the concerned domain regulators or otherwise." POLICIES AND GUIDELINES 14.5 National Policy on Univer....
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....s version, the 2019 version was based on WCAG 2.0 and covered a wider range of disabilities including visual, auditory, physical, and cognitive impairments. The guidelines included detailed information on various accessibility features such as keyboard accessibility, colour contrast, and text resizing. It mandated that all new government websites should comply with the WCAG 2.0 Level AA accessibility standards. GIGW 3.0 - Released in March 2023, this is the most advanced version of GIGW formulated jointly with Standardisation Testing and Quality Certification (STQC), Directorate of the Ministry of Electronics and Information Technology and Indian Computer Emergency Response Team (CERT-In). It is aimed at improving the user interface and user experience of government websites. These guidelines are especially designed to incorporate features like intuitive page loading (using AI and analytics) based on user profile. It takes special cognisance of mobile revolution and seeks to enhance accessibility and usability of mobile apps developed by government agencies. The guidelines have been designed keeping in mind the public digital infrastructure initiatives that will enhance governme....
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....of poverty and isolation. 5 World Health Organization and World Bank, World Report on Disability (2011). See Summary, pp. 10. The report provides the best available evidence about what works to overcome barriers to health care, rehabilitation, education, employment, and support services, and to create the environments which will enable people with disabilities to flourish. ......... 15. Accessibility is woven throughout the United Nations Convention on the Rights of Persons with Disabilities as a cross-cutting right, reinforcing its critical role in achieving social inclusion. It is highlighted in paragraph (e) of the Preamble, which calls for an environment that supports full personal development and societal participation. Article 3 sets out accessibility as a general principle, which highlights the necessity of removing both tangible and intangible barriers to ensure that PWDs can fully exercise their rights. These barriers can be physical, such as inaccessible buildings and transportation systems, or intangible, such as discriminatory attitudes or inaccessible digital content.... 16. ...Article 9(1) mandates that States take proactive steps to ensure ....
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....gime and was enacted by the Parliament under Article 253 of the Constitution, the fact that 'disability' as a ground is not specifically stated under Article 15 of the Constitution, would not mean that the same is not part of the constitutional obligations of the State. The provisions under section 32 and section 34 of the RPwD Act, 2016 would also be a clear indication that similar to the State's obligations to provide for special protection including in the form of reservation for socially and educationally backward classes in educational institutions as well as in employment as stated in Articles 15 and 16 of the Constitution, the State has taken up the obligation of providing similar protection including reservation in respect of PwD. In view of the same, it can now be said that it is high time that an anti-discrimination clause be included in the Constitution with a specific provision that the State shall not discriminate on the grounds of mental or physical disability in line with the principles as stated in the RPwD Act, 2016. At this juncture, it is relevant to point out that as many as 70 countries out of 189 contain 'disability' as one of the grounds mentioned specificall....
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....ssibility of being automatically logged off; and (vi) Accessibility protocols, such as use of appropriate colour contrasts, should be adhered to." 14.6.4 This Court in Disabled Rights Group & Another v. Union of India & Ors. (2018) 2 SCC 397, emphasized the need for inclusive education and the removal of barriers that hinder access and participation. The relevant paragraphs are extracted below: "14)...Section 40 mandates the Central Government to frame Rules and laying down the standards of accessibility for physical environment, transportation system, information & communication system and other facilities & services to be provided to the public in urban and rural areas. Rule 15 deals with accessibility standards for public buildings, passenger bus transport and information and communication technology. As regards public buildings, the accessibility standards prescribed under the Harmonised Guidelines and Space Standards for barrier-free built environment for persons with disabilities and elderly persons issued by Ministry of Urban Development have been adopted. This implies that all the public buildings are now required to conform to these standards. ....
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.... to persons with disability. It distinguishes between functional impairments (disability) both of a physical and psychological nature, and the loss of equal participation in social processes that only arises through interaction with the social setting (handicap). These developments have contributed to a new (WHO) model, which bears in mind social as well as functional and individual factors in its classification of health and health-related areas. Keeping in view the above, proper facilities are need to be provided to differently-abled persons while having higher education. 17) Insofar as the rights base approach is concerned, that has been narrated in detail in Rajive Raturi's judgment. We may add that a basic underline assumption, which is well recognised, is that everyone can learn; there is no such person as one who is ineducable; and that, accordingly, all disabled persons (from whatever disability they are suffering) have right to get not only minimum education but higher education as well. Not making adequate provisions to facilitate proper education to such persons, therefore, would amount to discrimination. Such requirement is to ensure that even a student with di....
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....blic by making verification processes faster and more efficient, persons with blindness and low vision continue to face significant barriers in accessing and completing these procedures. Many such digital platforms are not compatible with screen readers, and crucial information is often presented in visual formats without alternative text. CAPTCHA tests, unlabeled form fields, and biometric verification methods such as facial recognition further exclude individuals with visual impairments. Moreover, those platforms often require fine motor control (e.g., precise selfie or signature capture) which is not feasible for individuals with mobility impairments. Additionally, interfaces are frequently overly complex and lack cognitive accessibility, thereby posing significant challenges for users with intellectual or learning disabilities. For instance, videos without captions prevent users from accessing information. Given the troubling state of government-run websites, it is easy to conjecture that the situation with private service providers is even worse. Such barriers significantly hinder the ability of persons with disabilities to work, learn, and engage with society, thereby violati....
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....nequal access to digital infrastructure, skills, and content - continues to perpetuate systemic exclusion, not only of persons with disabilities, but also of large sections of rural populations, senior citizens, economically weaker communities, and linguistic minorities. The principle of substantive equality demands that digital transformation be both inclusive and equitable. As already pointed out, persons with disabilities encounter unique barriers in accessing online services due to the lack of accessible websites, applications and assistive technologies. Similarly, individuals in remote or rural areas often face poor connectivity, limited digital literacy, and a scarcity of content in regional languages, effectively denying them meaningful access to e-governance and welfare delivery systems. In such circumstances, the State's obligations under Article 21- read in conjunction with Articles 14,15 and 38 of the Constitution - must encompass the responsibility to ensure that digital infrastructure, government portals, online learning platforms, and financial technologies are universally accessible, inclusive and responsive to the needs of all vulnerable and marginalized populations....
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.... respondent authorities should provide clear directions to all regulated entities to accept image of thumb impression during Digital KYC process. (vii) Respondent No. 2 / RBI shall amend the MD on KYC so as to enhance the implementation of the 'OTP based e-KYC authentication' (face-to-face) to customers. (viii) Respondent No.3 shall make the necessary amendments and/or modifications to its notification dated 05.12.2023 thereby ensuring that the paper-based KYC process for verification of customers shall continue, enabling the petitioners and other similarly placed individuals to avail an accessible alternative for completing the KYC procedure. (ix) The respondent authorities shall provide options for sign language interpretation, closed captions, and audio descriptions for visually and hearingimpaired users. (x) The respondent authorities shall develop alternative formats including Braille, easy-to-read formats, voice-enabled services, to disseminate government notifications and deliver public services, ensuring accessibility for all. (xi) All regulated entities should procure or design devices or websites / applications / software in co....