This analysis is based on a direct reading of the Unified Building Regulations for Industrial Development Authorities of Uttar Pradesh, 2026 — Revised Draft for Comments, Version TMv12, dated 16 April 2026, issued by the Infrastructure and Industrial Development Department, Government of Uttar Pradesh. Accessibility figures are sourced directly from Chapter 13 of that document. The draft was also reported by Shafaque Alam in the Times of India, April 20, 2026 — ‘UP’s draft unified bldg code links FAR with road width’, Times City, Page 3.

Credit where it is due

The draft Unified Building Regulations for Industrial Development Authorities of Uttar Pradesh, 2026 contains a dedicated chapter on accessibility.

Chapter 13 — Provisions for Differently Abled, Elderly and Children — covers access paths, guiding floor materials, accessible parking, drop-off zones, ramps, entrance doors, corridors, stairways, lifts, toilets, drinking water, signage, and refuge areas. The chapter applies to public-use buildings within the industrial development authority framework across Noida, Greater Noida, Yamuna Expressway, UPEIDA, and every IDA in the state.

This is not an afterthought buried in an annex. It is a numbered chapter in a draft building code, treating accessibility as a regulatory obligation rather than a social welfare provision. Many state and authority-level codes do not have this. UP’s does. That deserves to be said plainly before anything else is said.

Now the critique.

The test

Including accessibility in a building code creates a compliance baseline. What that baseline contains determines whether the chapter functions as a genuine design standard or a documentation ritual — a box ticked at the drawing stage that no one verifies at the building stage.

The test is simple: can a person using a standard wheelchair — defined by the draft code itself at Section 13.1(e) as 1050mm × 750mm — actually use the facilities that Chapter 13 mandates? On three provisions, the answer is uncertain at best.

The toilet

Section 13.4.5 requires one accessible toilet per building with minimum internal dimensions of 1500mm × 1750mm.

HGSUA 2021 — the current Government of India accessibility reference standard — specifies 2200mm × 2000mm, with 1800mm × 1800mm manoeuvring space clear of all fixtures. NBC 2016 Type A requires 2200mm × 2300mm.

The draft’s 1500mm × 1750mm is below both. A wheelchair of 1050mm × 750mm occupies most of that floor area before accounting for door swing, washbasin, WC, and the lateral transfer space needed for independent use. Section 13 specifies none of those clearances.
A toilet that cannot be used independently is not an accessible toilet. It is a room with a sign on the door.

The lift

Section 13.4.4 specifies accessible lift internal dimensions as 1100mm depth × 2000mm width. HGSUA 2021 references 1500mm × 1500mm as the minimum. A lift with 1100mm internal depth provides significantly less manoeuvring space than the 1500mm depth referenced in HGSUA 2021 and may limit wheelchair manoeuvrability and ease of use.

The draft’s door hold time of five seconds and closing speed of 0.25 metres per second are correct. The cavity those provisions protect is 400mm shallower than the Government of India reference standard.
The draft also omits Braille floor indicators and visual floor display — both required under HGSUA 2021 and NBC 2016 — leaving a person with a visual impairment no independent means of confirming which floor the lift has reached.

The parking

Section 13.3.2 requires a flat minimum of two accessible parking bays regardless of total parking capacity. HGSUA 2021 requires two accessible spaces for every 25 car parking spaces.

A large industrial development with 200 parking spaces is required to provide exactly the same accessible provision as a small building with 25. As development scale increases under the unlimited FAR provisions elsewhere in this regulation, the gap between the draft’s flat minimum and an adequate standard grows proportionally.

Two bays serving a large facility is not a design standard. It is a floor that was never meant to stand alone.

The pattern

Three provisions. Three shortfalls against the current Government of India accessibility reference standard. Together they describe something structural: the specifications in Chapter 13 reflect a baseline that has not kept pace with HGSUA 2021 or IS 4963:2025 — India’s BIS standard covering accessibility in the built environment for older adults and persons with disabilities, published in 2025.

This matters beyond UP. Building codes across Indian states and authorities contain accessibility provisions of varying vintage, calibrated to different baselines, disconnected from one another. A developer operating across jurisdictions faces a patchwork where meeting the local building code may still leave a building exposed under the RPwD Act 2016.

The fix

The RPwD Act 2016 empowers the Central Government under Sections 40–46 to notify accessibility standards for buildings and public spaces. HGSUA 2021 exists precisely because India recognised that fragmented guidelines produce fragmented outcomes.

Every state building code and authority-level regulation should be required to reference HGSUA 2021 by name as the minimum technical standard — not replicate it selectively, not adapt it downward, but reference it as the floor below which no local regulation may fall. Fire safety provisions routinely reference NBC Part 4 by name. Structural provisions reference IS codes by number. Accessibility has simply not been accorded the same treatment.

The Central Government has recognised this. In December 2025, the Ministry of Social Justice and Empowerment published a draft amendment to the RPwD Rules 2017 — the Rights of Persons with Disabilities (Amendment) Rules on Non-Negotiable Accessibility Standards in Buildings and Built Environment, 2025, G.S.R. 913(E), Gazette of India Extraordinary, Part II, Section 3(i), No. 827, dated 22 December 2025. If enacted, building permission and completion certificates would be conditional on accessibility audit compliance. The draft is not yet law. But its existence signals that the Centre has identified the same structural gap this piece describes: local codes that do not meet the national standard.

UP’s Chapter 13 is evidence of institutional willingness. The draft gazette is evidence of national intent. What is needed now is alignment between the two.

A developer who builds to Section 13 and stops there may satisfy the local building code at occupancy certificate. Exposure under the RPwD Act 2016 is a separate question. Retrofitting a toilet from 1500mm × 1750mm to 2200mm × 2000mm after occupation costs significantly more than building it correctly the first time. Retrofit cost is design failure. At the scale that unlimited FAR makes possible, design failure is liability at scale.

The conclusion

UP has made the right institutional decision. Chapter 13 should be revised to reference HGSUA 2021 explicitly and align its specifications with the current standard. The toilet, the lift, and the parking provisions are the immediate priorities.

India cannot have a different accessible toilet in every jurisdiction. People with disabilities do not stop being disabled when they cross a state boundary. Buildings do not become accessible because a local code says they are.

The national standard exists. The legal mandate exists. The draft gazette shows the Centre knows it. What is needed now is for every state building.

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