EPFO Portal Has Many Blind Spots for the Visually Challenged
Moneylife Digital Team 04 January 2022
We are in an era of e-governance where most day-to-day transactions are just a click away; but, sadly, people with disabilities are fighting for inclusion within the digital space, since most apps and online platforms are not designed for the visually challenged. 
But it is even worse when websites like the Employee Provident Fund (EPFO) do not take into account the needs of people with disabilities seven years after the Central government ambitiously launched the ‘Accessible India Campaign’, or Sugamya Bharat programme promising ‘universal accessibility’ in December 2015. 
Although we have a statute called the Rights of Persons with Disabilities Act, 2016 (RPD Act), there is an automatic violation of rights when government websites are not available with navigators and conversion to Braille displays, or to people with other disabilities leading to their exclusion. Often, a mere captcha code, not being available in audio format, can lead to exclusion of those who are visually impaired. 
“Digital accessibility is a human right. When any government is working towards implementing e-governance system, it should be accessible or should be inclusive for all kinds of people. When this does not happen and the websites are inaccessible, these sections of society are excluded and denied of empowerment,” Pratik Rai, a Delhi-based young visually impaired technician told Moneylife.
Take the case of young lawyer Turab Chimthanawala who wrote to us to highlight the issue of inaccessibility of the Employees Provident Fund (EPFO) website to visually challenged provident fund (PF) subscribers.
Mr Chimthanawala has written several mails to the EPFO pointing to the inaccessibility of EPFO’s website  to visually challenged PF subscribers but it has made no difference.
In the absence of social security, EPFO is a big factor in retirement planning, so it is disturbing to visually challenged subscribers that they cannot independently access their accounts on the EPFO website. 
The visually challenged usually operate computers and mobile phones with the assistance of a screen reader—a software which reads aloud the contents on the screen using voice synthesised speech. However, independent access to the EPFO website is severely restricted.
Mr Chimthanawala forwarded to us his letter to the EPFO summarising challenges faced by the visually impaired while accessing the EPFO portal. They are:
i. The home screen is difficult to navigate;
ii. The links on the home screen do not get easily activated;
iii. The Captcha while logging into one’s PF Account is not accessible.
“Article 21 of the Constitution of India guarantees to all persons a life with dignity. Most visually challenged PF subscribers hold coveted positions in reputable organisations in diverse fields. By denying them independent access to their accounts on the EPFO website and compelling them to depend on sighted assistance and involvement in their financial matters, the EPFO is violating their aforementioned right to personal dignity and privacy. India enacted the Rights of Persons with Disabilities Act 2016 ‘the Act’, and has notified the same. EPFO is obliged to follow the law,” Mr Chimthanawala writes. 
As per Section 42 of the Act, the appropriate government shall 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.
Further, Section 46 of the Act mandates all service-providers, whether government or private, to provide services in accordance with the rules on accessibility formulated by the Central government under Section 40 within a period of two years from the date of notification of such rules. 
The Central government has notified the Rights of Persons with Disabilities Rules 2017 ‘the Rules’. Rule 15 of the Rules provides that every establishment shall comply with the following standards relating to physical environment, transport and information and communication technology, namely: 
(a) Information and Communication Technology;
(b) 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.
The Act was brought into force on 19 April 2017 and the Rules were notified on 15 June 2017. Per a combined reading of Section 46 of the Act and Rule 15 of the Rules, the last date of compliance was 14 June 2019.
The EPFO has not designed its website in accordance with the aforementioned standards and, thus, has violated its legal obligations.
The Guidelines for Indian Government Websites, the latest edition of which was released in 2018, contain exhaustive principles to be followed for designing websites to make them accessible for persons with visual disability. The said guidelines are based on an internationally recommended standard of World Wide Web Consortium called Web Content Accessibility Guidelines 2.0, level AA. – The EPFO website is not developed and designed as per the WCAG and the GIGW guidelines 2018.
Section 13(1) of the Act guarantees the persons with disabilities the right to manage their own financial affairs. By denying visually challenged subscribers independent access to the EPFO website, EPFO is  violating their aforementioned right.
Blind people and people with low vision, like other citizens, have the right to manage their own financial affairs, especially since the prime minister of India has been pushing for Digital India.
Mr Chimthanawala’s letter requests the EPFO office “to take up this matter urgently so as to make the EPFO website is accessible to visually challenged PF subscribers.” He adds that “Any change or upgrade to the website should be done only after disability accessibility audit since it is also used by persons with disabilities all over the country.”
Unfortunately we are not sure the EPFO is listening to such valuable feedback. 
On the EPFO portal, they have put up a statement claiming “We are committed to ensure that the eSamikSha portal is accessible to all users irrespective of device in use, technology or ability. It has been built, with an aim, to provide maximum accessibility and usability to its visitors. As a result this portal can be viewed from a variety of devices such as desktop / laptop computers, web-enabled mobile devices.”
The EPFO also claimed “We have put in our best efforts to ensure that all information on this portal is accessible to people with disabilities. For example, a user with visual disability can access this portal using assistive technologies, such as screen readers and screen magnifiers.” 
The portal adds ”We also aim to be standards compliant and follow principles of usability and universal design, which should help all visitors of this portal. 
This portal is designed using XHTML 1.0 Transitional to meet Guidelines for Indian Government Websites and also adheres to level A of the Web Content Accessibility Guidelines (WCAG) 2.0 laid down by the World Wide Web Consortium (W3C). Part of the information in the portal is also made available through links to external Websites. External Websites are maintained by the respective departments who are responsible for making these sites accessible.” 
EPFO, however, also grudgingly admits on the same page “Employees' Provident Fund Organisation, Ministry of Labour & Employment, Government of India is working towards making its portal accessible for persons with disabilities, however currently Portable Document Format (PDF) files are not accessible. In addition, information provided in Hindi language is also not accessible.” 
The EPFO has even put up a notice on its website saying “if you have any problem or suggestion regarding the accessibility of this portal, please write to us to enable us to respond in a helpful manner. Do let us know the nature of the problem along with your contact information.” 
This, however, appears more of empty rhetoric only as is seen from the obvious lack of response from EPFO to Mr Chimthanawala’s emails.
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