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SEBI Issues Clarification on Digital Accessibility Requirements: Guide for Regulated Entities

Digital accessibility has become a critical compliance requirement in India’s financial sector. With all investor services shifting to online platforms, SEBI has taken a significant step to ensure that information and services are made accessible to all investors including people with disabilities.

Building on earlier SEBI guidelines issued this year, SEBI released a fresh circular offering clarifications on digital accessibility requirements on December 08, 2025.

Why SEBI Is Strengthening Digital Accessibility?

SEBI’s mission is to protect investors and promote equal and fair access. In today’s digital age, websites, mobile apps, trading platforms, and online portals are primary touchpoints. Any accessibility barrier directly impacts investors' rights.

This is why SEBI has now positioned digital accessibility as a fundamental part of investor protection, requiring all Regulated Entities (REs) to comply with WCAG 2.1 AA standards, conduct ongoing digital accessibility testing, and undergo periodic audits by certified accessibility auditors.

Major Highlight: Investors’ Right to Have Digital Accessibility

The new circular clearly states that digital accessibility is an investor right which will now be included in every Investor Charter applicable to REs. This is a landmark step, making India a market where accessibility is explicitly recognized as a core investor entitlement.

Updated Compliance Requirements Under SEBI Guidelines (December 2025)

SEBI's latest clarification specifies what Regulated Entities must do to meet the digital accessibility mandate. Here’s a streamlined summary:

New Deadline

As per the previous circular , REs were required to appoint an accessibility auditor by December 14, 2025.
This requirement has now been postponed to March 31, 2026 for Accessibility Readiness Reporting

New Requirement

All REs must submit a status of accessibility readiness and compliance for each investor-facing digital platform by March 31, 2026. REs that submit directly to SEBI must email their reports to: digital_acc@sebi.gov.in            

This gives organizations time to complete internal assessments, perform accessibility testing, and plan WCAG compliance.

Use Annexure B for Accessibility Reporting

SEBI has provided a structured format of submitting a status of readiness and compliance to the accessibility requirements for digital platforms
REs must list:

  • URLs of every digital platform
  • Whether it meets minimum level of accessibility at AA level as per the latest WCAG guidelines
  • Remarks on status of readiness and compliance to the accessibility requirements.

This ensures standardized reporting across the industry and helps SEBI track overall accessibility maturity.

‘Accessibility’ Complaint Category on SCORES

SEBI has added ‘Accessibility’ as a complaint category on SCORES.

In   response   to   the   accessibility   related complaint, the RE should remediate the accessibility related issue for the closure of the complaint. This pushes REs to prioritize accessibility fixes and continuous improvement.

Mandatory Periodic Accessibility Audits by Certified Accessibility Auditors

A major update is the requirement for all REs to conduct regular accessibility audits of their digital platforms including Websites, Mobile app and portals. These audits must be performed by certified accessibility professionals, ensuring accuracy and alignment with WCAG compliance standards.

This makes accessibility a continuous process, not a one-time activity.

Understanding the Reporting Structure (Annexure A)

SEBI has outlined where each category of RE must submit their accessibility readiness report.

  • Stock Brokers & Depository Participants will report to Stock Exchanges/Depositories
  • Investment Advisors & Research Analyst will report to BSE Ltd.
  • Other REs (including MIIs) will report directly to SEBI

SEBI also listed entities that must report directly, such as Mutual Funds, AMCs, Merchant Bankers, AIFs, Portfolio Managers, KRAs, RTAs, and more ensuring clear accountability.

Why SEBI Guidelines Matter for the Financial Sector?

It is evident that SEBI is making digital accessibility a mandatory regulatory compliance requirement for all Regulated Entities, rather than merely an optional improvement. SEBI has highlighted the importance of digital accessibility for market integrity and investor protection through its circulars, stating that all investors, including those with disabilities, must be able to use digital platforms without any obstacles. These guidelines seek to strengthen regulatory accountability, advance equal investor rights, guarantee transparent and inclusive digital operations, enhance usability for all users, and stimulate the creation of better digital platforms throughout the securities market ecosystem.

In the future, following WCAG compliance guidelines, conducting frequent accessibility audits by certified accessibility auditors, and conducting regular digital accessibility testing will no longer be best practices but rather crucial elements of successful digital governance for all Regulated Entities.

What Regulated Entities Should Start Doing Immediately?

Here is a practical action plan for REs:

  • Conduct a Comprehensive WCAG Accessibility Gap Assessment - Evaluate all digital platforms against WCAG 2.1 AA guidelines.
  • Start Digital Accessibility Testing - This includes manual testing, assistive technology testing, and automated scans.
  • Engage a Certified Accessibility Auditor - Periodic audits are mandatory, and only trained, certified experts are acceptable.
  • Build an Accessibility Roadmap - Outline remediation actions, timelines, and governance structures.
  • Train Developers & Product Teams - Internal capability building is essential to avoid repeat accessibility errors.
  • Prepare to Handle SCORES Accessibility Complaints - Set up a dedicated workflow for accessibility-related grievance redressal.

Accessibility is Now a Compliance, No Longer a Choice

The message from SEBI is clear that Digital accessibility is a regulatory requirement, an investor right, and a long-term commitment to inclusion. Any organization that delays WCAG compliance or skips accessibility testing is likely to face:

  • Increased accessibility complaints
  • Audit findings
  • Reputational impact
  • Regulatory scrutiny

It is important that REs act early.

Partner with BarrierBreak

As SEBI moves strongly toward accessibility enforcement, Regulated Entities need a trusted, experienced partner to guide them through WCAG compliance, digital accessibility testing, accessibility audits, and remediation support.

BarrierBreak is an empanelled web accessibility auditor with the DEPwD and an authorized accessibility auditor with IAAP with:

BarrierBreak has been at the forefront of making India’s digital landscape inclusive and is uniquely positioned to support REs in meeting SEBI’s digital accessibility compliance requirements. If you want your websites, applications, and portals to meet SEBI guidelines confidently and on time then get in touch with our team today.

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