Universal Acceptance as a Rights-Based Design Requirement: Evidence from India's Digital Public Infrastructure

I am a cybersecurity student at the National Forensic Sciences University, New Delhi, researching Digital Public Infrastructure and digital rights across Asia through NetMission Asia. I submit this comment in response to ICANN's Draft Guidelines for Advancing UA Adoption, drawing on empirical research into how UA failures are producing measurable rights denials in India's digital welfare systems.

The Core Argument

Universal Acceptance is currently framed primarily as a technical compliance standard — ensuring that applications correctly handle all valid domain names and email addresses including internationalized domain names. This framing is necessary but insufficient. In countries like India, where governments are rapidly digitising essential public services, UA failures are not merely technical inconveniences. They are mechanisms of rights denial at scale.

When a welfare registration portal rejects a user's email address because it falls outside ASCII assumptions, or when a government authentication system cannot process inputs in Devanagari or Tamil script, the consequence is not a failed transaction. It is a citizen locked out of a constitutional entitlement — food, healthcare, employment, education — that the state is legally obligated to provide.

Evidence from India

India's Digital India programme has digitised delivery of welfare, health, education, and civic participation at scale. The empirical record demonstrates that this digitisation, conducted without UA as a foundational design principle, has produced systematic exclusion:

India has 22 officially recognised languages and hundreds of dialects. Yet most government portals — UMANG, DigiLocker, CoWIN, MGNREGA online — were designed with Hindi and English as primary interfaces. Where regional language options exist, they are frequently incomplete, poorly rendered, or technically broken for users whose devices or email addresses fall outside ASCII assumptions.

The consequences are documented and measurable. India's computer literacy rate stands at 24.7 percent nationally and 18.1 percent in rural areas (NSS, 2024). Internet penetration in rural India is 37 percent against 67 percent in urban areas (TRAI, 2023). During COVID-19, CoWIN's digital-only registration system — built without multilingual support or UA-compliant alternatives — produced a vaccination rate of 30 doses per 100 urban persons against 12.7 per 100 rural persons by May 2021 (Oxfam India, 2021). MGNREGA workers with legally earned wages have been systematically denied payment because biometric authentication systems and online portals were not designed for their linguistic or technical reality. PDS ration beneficiaries across Rajasthan and Jharkhand have been denied food entitlements due to Aadhaar verification failures and portal inaccessibility in local languages.

These are not edge cases. They are the predictable consequence of deploying digital infrastructure without UA as a design requirement.

Specific Recommendations for the Draft Guidelines

The Draft Guidelines should be strengthened in the following specific ways:

First, the Guidelines should explicitly address government Digital Public Infrastructure as a priority deployment context for UA adoption. Governments digitising essential services — welfare, health, education, civic participation — should be identified as high-priority actors whose UA compliance directly implicates human rights obligations under international law, including ICESCR Articles 12, 13, and the right to equality under ICCPR Article 26.

Second, the Guidelines should recommend that all government digital systems support the full range of valid internationalized domain names and email addresses before essential services are migrated to digital-only delivery. Digital-first without UA-compliant infrastructure is not inclusion — it is the relocation of exclusion from one mechanism to another.

Third, the Guidelines should address the relationship between UA adoption and non-digital alternatives. Where UA implementation remains incomplete — as it does across most of India's government portal infrastructure — non-digital fallback options must be maintained as a legal safeguard. The Guidelines should recommend that governments not move to digital-only service delivery until UA compliance is verified across all relevant systems.

Fourth, the Guidelines should include specific provisions for multilingual support beyond script rendering. True UA adoption in linguistically diverse countries requires not only that systems accept IDN inputs, but that interfaces, error messages, help documentation, and user onboarding are available in the languages users actually speak. Partial translation — which characterises most of India's government portal language support — does not constitute UA compliance in any meaningful sense.

Fifth, the Guidelines should recommend civil society and community inclusion in UA adoption assessments. The communities most affected by UA failures — rural, low-literacy, non-English speaking populations — are rarely consulted in technical compliance processes. Their inclusion in testing, feedback, and evaluation would produce more accurate assessments of real-world UA adoption than technical audits alone.

Conclusion

ICANN's Universal Acceptance initiative has the potential to meaningfully advance digital inclusion across the Global South. Realising that potential requires the Draft Guidelines to move beyond technical compliance framing toward a rights-based approach that treats UA adoption as a prerequisite for the equitable digitisation of essential services.

India's experience demonstrates what happens when that prerequisite is ignored. The Guidelines have an opportunity to ensure that other countries building Digital Public Infrastructure learn from that experience rather than repeat it.

I have attached my research paper — The Illiterate Citizen in a Digital State: Digital Exclusion and the Denial of Social Rights in Rural India — as supporting documentation for the empirical claims made in this submission.

Research paper documenting empirical evidence of digital exclusion and rights denial in rural India, including data on computer literacy rates, internet penetration gaps, and welfare system failures produced by inadequate digital infrastructure design. Provides full sourcing for empirical claims made in the public comment submission.

This submission argues that Universal Acceptance must be treated as a rights-based design requirement for Digital Public Infrastructure, not merely a technical compliance standard. Drawing on empirical data from India's National Sample Survey, TRAI, Oxfam India, and civil society documentation, this comment demonstrates that UA failures in India's government welfare systems — including CoWIN, MGNREGA, and PDS — have produced measurable rights denials across health, welfare, and education delivery. The submission makes five specific recommendations: explicitly addressing government DPI as a priority UA deployment context; requiring UA compliance before digital-only service migration; maintaining non-digital alternatives where UA implementation is incomplete; mandating meaningful multilingual support beyond partial translation; and including civil society in UA adoption assessments. The attached research paper provides full empirical documentation.