SEBI Circulars on digital accessibility: mandatory compliances for SEBI-regulated entities

Context

The Securities and Exchange Board of India (“SEBI”) through a circular dated July 31, 2025 (“July 31 SEBI Circular”) mandated certain digital accessibility compliance requirements for SEBI-regulated entities under the Rights of Persons with Disabilities Act, 2016 (“RPD Act”) and the Rights of Persons with Disabilities Rules, 2017 (“RPD Rules”). The July 31 SEBI Circular lays down a comprehensive framework on digital accessibility[1] to ensure that investor-facing digital platforms provided by SEBI-regulated entities such as mobile apps and websites are aligned with the prescribed digital accessibility requirements to ensure full and effective participation of persons with disabilities in securities markets.

SEBI has extended the application timelines for the compliance of the July 31 SEBI Circular in a graded manner by a circular dated August 29, 2025 (“August 29 SEBI Circular”). Notably, the August 29 SEBI Circular does not alter the scope of the digital accessibility compliance requirements which had previously been issued under the July 31 SEBI Circular. Instead, it defers the deadlines for such compliance and prescribes extended deadlines to comply with the substantive requirements issued earlier in this regard.

This note outlines the key compliance requirements under the July 31 SEBI Circular, as well the extended compliance timelines granted by SEBI through the August 29 SEBI Circular (collectively, the “SEBI Disability Circulars”).

Background of the SEBI Disability Circulars

The SEBI Disability Circulars flow from the Supreme Court’s judgment dated April 30, 2025 in Pragya Prasun and others v. Union of India and Amar Jain v. Union of India[2] which, among others, mandated SEBI-regulated entities to follow prescribed digital accessibility standards by holding that the right to digital access is an intrinsic component of the right to life and liberty.

Extended timelines under the August 29 SEBI Circular

The August 29 SEBI Circular has granted extensions on timelines related to the following compliances under the July 31 SEBI Circular:

Compliance required	Old deadline	Revised deadline
Submission of a compliance/ action taken report pertaining to the clauses of the July 31 SEBI Circular	August 30, 2025	September 30, 2025
Submission of a list of digital platforms provided by SEBI-regulated entities for the investors	August 30, 2025	September 30, 2025
Appointment of IAAP certified accessibility professionals as auditors	September 14, 2025	December 14, 2025
Conduct of accessibility audits of their digital platforms	October 31, 2025	April 30, 2026
Remediation of findings from the audit and ensuring compliance with the July 31 SEBI Circular	January 31, 2026	July 31, 2026
Conduct of annual accessibility audits of all digital platforms of SEBI-regulated entities and submission of final report of such audit to SEBI	April 30, 2026	April 30, 2027

Key highlights of the SEBI Disability Circulars

The SEBI Disability Circulars mandate the digital platforms of SEBI-regulated entities to ensure compliance with Sections 40 (Accessibility), 42 (Access to information and communication technology) and 46 (Time limit for accessibility by service providers) of the RPD Act read with Rule 15(1)(c) (Rules for Accessibility) of the RPD Rules.

Ø  Adherence to digital accessibility standards

All SEBI-regulated entities are required to ensure that their digital platforms and any content published on the same strictly adhere to accessibility standards and guidelines, including:

a)     Web Content Accessibility Guidelines (“WCAG”) 2.1 or latest version;

b)    Accessibility guidelines as described in the latest version of Guidelines for Indian Government Websites (“GIGW”);

c)     IS 17802: Indian Standards on Accessibility Requirements for Information and Communication Technology (“ICT”) Products and Services; and

d)    Provisions related to digital accessibility as laid down from time to time under the RPD Act and the RPD Rules.

The July 31 SEBI Circular clarifies that the above standards shall serve as the baseline benchmarks for all compliances flowing out of such circular and must be referenced in all digital initiatives.

Ø  Institutional arrangement to facilitate digital accessibility

SEBI-regulated entities are required to institute the following mechanism to ensure compliance:

a)     Overview and approval: The managing director, managing partner, or the proprietor of the SEBI-regulated entity (as may be applicable) is required to review and approve compliance with the July 31 SEBI Circular.

b)    Appointment of Nodal Officer for digital accessibility compliance: SEBI-regulated entities are required to designate any senior officer as the Nodal Officer for digital accessibility compliance who shall be responsible for ensuring digital accessibility for every investor including conducting accessibility audits, mitigation of accessibility audit findings, implementation of accessibility guidelines, and timely redressal of investor grievances regarding the same. The Nodal Officer shall also serve as SEBI’s point of contact in any matter pertaining to digital accessibility. In the absence of an officially designated Nodal Officer, the SEBI-regulated entity’s compliance officer or proprietor shall be deemed to be the Nodal Officer for ensuring digital accessibility compliance.

c)     Establishment of a grievance redressal mechanism with escalation option: The July 31 SEBI Circular mandates the establishment of a grievance redressal mechanism which is specifically tailored to address digital accessibility issues within the SEBI-regulated entities. It requires that channels such as email, helpline, and web forms must be user-friendly for persons with disabilities. Further, any such grievance redressal mechanism must include provisions for escalation to senior officers.

Ø  Reporting to authorities

SEBI-regulated entities are required to report on their compliance milestones to their respective authorities as laid down below:

Regulated Entity	Reporting Authority
Stock brokers / depository participants	Stock exchanges / depositories
Investment advisors and research analysts	BSE Limited
Market infrastructure institutions and other REs	SEBI

In effect, SEBI-registered merchant banks have to report compliance to SEBI.

Ø  Web and document accessibility

The digital platforms of SEBI-regulated entities are required to include accessibility enhancing features such as Indian Sign Language (“ISL”) videos, closed captioning, descriptive audio, and alternate text for images. The July 31 SEBI Circular states by way of an indicative example that an explainer video on KYC must include captions and ISL interpretation.

Further, SEBI-regulated entities are required to ensure that all circulars, notices, and investor documents published on their digital platforms should follow accessible document standards such as tagged PDFs, logical reading order, and proper use of headings. In this regard, SEBI-regulated entities are required to follow the PDF techniques covered in WCAG 2.1 for the same.

Ø  Training and awareness

Training modules which provide detailed understanding on digital accessibility are required to be made a part of all internal training programs for the staff members of SEBI-regulated entities as well as third-party service providers who develop and publish content for dissemination on the digital platforms of SEBI-regulated entities. Digital platforms are required to be ‘accessible by design’.

Ø  Registration and e-KYC requirements

SEBI-regulated entities are required to ensure that digital KYC, e-KYC, and video KYC processes include alternatives to accommodate persons with disabilities such as allowing alternative formats of document submission by permitting the upload of scanned documents, human-assisted video KYC, or voice-assisted KYC for visually impaired users. Furthermore, KYC and client registration forms of SEBI-regulated entities should include a mandatory field to indicate disability status and users who are persons with disabilities have the option to select specific facilitative provisions such as helpdesk call back for assistance.

Notably, any client application which has been submitted by a person with disability cannot solely be rejected through automated systems and human review is permitted to override any incorrect automatic rejection to ensure equitable access to persons with disabilities.

Ø  Digital accessibility audits and remediation

The following audit and ongoing compliance actions are required to be undertaken by SEBI-regulated entities to promote better digital accessibility:

a)     Conduct of audit: SEBI-regulated entities are required to initiate a comprehensive accessibility audit of their digital platforms through the International Association of Accessibility Professionals (“IAAP”), which audit is required to follow the latest guidelines as may be issued under the WCAG, GIGW, the RPD Act and RPD Rules, as well as any SEBI guidance on the same. The accessibility audits are required to include usability testing by persons with disabilities.

b)    Remediation actions: Based on the audit findings, SEBI-regulated entities are required to implement an audit remediation plan for adverse audit observations. Further, they are required to upgrade their extant digital platforms to meet the accessibility standards within the stipulated timelines as prescribed under the August 29 SEBI Circular.

c)     Annual accessibility audits: All SEBI-regulated entities are required to conduct annual accessibility audits of their digital platforms through IAAP certified accessibility professionals and submit reports regarding the same to their respective reporting authorities.

Ø  Procurement and technical compliance

Any digital solution which has either been newly developed or procured by SEBI-regulated entities should conform to latest guidelines on WCAG, IS17802, GIGW and the provisions of the RPD Act and RPD Rules in relation to digital accessibility and all procurement requests or contracts assign weightage to accessibility readiness. In case SEBI-regulated entities procure software products, then such products too must be tested against these accessibility guidelines. Ultimately, the responsibility to ensure the accessibility of digital platforms lie with SEBI-regulated entities.

Conclusion

SEBI-regulated entities will have to now focus on institution of internal processes and systems in a time-bound manner to ensure that their digital systems are aligned to enhance digital accessibility outcomes for persons with disabilities.

[1] Under the July 31 SEBI Circular, ‘digital accessibility’ has been defined as: “Digital Accessibility” shall inherently be understood as “Digital Accessibility for Persons with Disabilities” in order to prioritize digital accessibility for all persons with disabilities – including but not limited to acid attack survivors suffering from permanent facial/eye disfigurement, persons with blindness and low vision, and other similarly placed individuals.”

[2] (2025) 7 SCC 191

This note does not constitute legal advice and is not intended to create an attorney-client relationship.