Key Points
- SEBI has made digital accessibility mandatory for all regulated entities under the RPwD Act, 2016.
- This includes brokers, AMCs, RTAs, depositories, and KYC agencies.
- Websites, mobile apps, and investor touchpoints must meet WCAG 2.1, GIGW, IS 17802, and RPwD Act standards.
- Entities must submit a list of digital platforms and a compliance report within 1 month.
- Appointment of IAAP certified accessibility professionals as Auditor within 45 days, and full audits completed within 3 months.
- All accessibility issues must be fixed within 6 months, followed by annual accessibility reporting.
- Non-compliance could lead to risk—now is the time to act and ensure inclusive digital experiences.
In a landmark move to ensure India’s financial ecosystem is more inclusive, the Securities and Exchange Board of India (SEBI) has issued a circular on July 31, 2025, that mandates all regulated entities to comply with the digital accessibility requirements. This update represents a significant advancement in guaranteeing full and efficient participation of people with disabilities in the securities market. SEBI's directive is aligned with the Rights of Persons with Disabilities (RPwD) Act, 2016, and brings much-needed clarity and accountability to ensure digital platforms in the financial sector are accessible.
Why This Circular Matters?
The RPwD Act, 2016 emphasizes equal access for persons with disabilities across all sectors, including digital solutions. In reality, though, a lot of digital platforms are still inaccessible. SEBI has intervened to close this gap by requiring digital accessibility as a compliance requirement rather than an option. The circular emphasizes the need for accessibility across all digital platforms run by SEBI Regulated Entities (REs) and includes stock exchanges, depositories, mutual funds, portfolio managers, KYC registration organizations, and other intermediaries. SEBI’s intent is clear and that is to protect the rights and dignity of people with disabilities and to ensure that they can use financial services with ease and independence.
To ensure the quality and credibility of accessibility evaluations, SEBI specifically requires that audits be conducted by an IAAP certified auditor, a professional credentialed by the International Association of Accessibility Professionals (IAAP). This makes IAAP certification a baseline requirement for anyone conducting accessibility audits in the Indian financial sector.
Legal Background and Supreme Court Judgment
The circular is strongly influenced by the Supreme Court of India’s judgment dated April 30, 2025, in two key cases
- Pragya Prasun & Ors. Vs. Union of India
- Amar Jain vs. Union of India.
The court ruled that the right to Digital Access is an intrinsic component of right to life and personal liberty under the Indian Constitution. This judgment emphasizes that persons with disabilities must have equal access to digital services, including digital KYC, e-KYC, and video KYC. SEBI’s circular acts as the enforcement arm of this decision in the financial sector.
Download BB100: Digital Accessibility Landscape of the Finance Sector in India. This research report evaluates the digital accessibility landscape of the top 100 companies in the Indian Financial Sector, including Banks, Insurance Companies, Payment Gateway Providers, Investment Firms, and Financial Service Aggregators.
Who Does This Apply To?
The circular applies to all the SEBI Regulated Entities (REs) and include:
- Recognised Stock Exchanges
- Clearing Corporations
- Depositories
- Mutual Funds
- KYC Registration Agencies (KRAs)
- Portfolio Managers
- Investment Advisors
- QRTAs
- Other registered intermediaries
Each of these entities is now responsible for working with an IAAP certified auditor or an IAAP certified accessibility professional to assess and remediate their digital properties in line with the SEBI circular's requirements.
Key Accessibility Laws and Standards to Follow
To ensure compliance, SEBI directs all REs to follow several established accessibility standards:
- Web Content Accessibility Guidelines (WCAG) 2.1 or latest version – These are international standards developed by the W3C that define how to make web content more accessible, especially for people with disabilities.
- Guidelines for Indian Government Websites (GIGW) – National guidelines for website accessibility and usability issued by the Government of India.
- IS 17802:2022 – The Indian Standard on accessibility requirements for Information and Communication Technology (ICT) products and services issued by the Bureau of Indian Standards (BIS).
- The RPwD Act, 2016 and Rules 2017 – Specifically Sections 40, 42, 46 of the Act and Rule 15(1)(c) of the Rules, which provide for time-bound accessibility and access to information and communication technology.
Timelines and Milestones for Compliance
SEBI has outlined a clear and time-bound roadmap for REs to comply with digital accessibility requirements:
Within 1 Month of the Circular (By August 31, 2025)
- Submit a list of all digital platforms (websites, mobile apps, etc.) provided for investors.
- Submit a compliance or action-taken report based on the circular’s requirements.
Within 45 Days (By September 14, 2025)
- Appointment of IAAP certified accessibility professionals as digital accessibility auditors.
This 45-day deadline underscores the urgency SEBI places on engaging qualified IAAP certified auditors. Organizations that do not already have access to an IAAP certified auditor must act immediately to identify and onboard the right professional or agency.
Within 3 Months (By October 31, 2025)
- Conduct accessibility audits of all digital platforms.
Within 6 Months (By January 31, 2026)
- Complete the remediation of audit findings and ensure full compliance with the circular.
Annual Reporting
- All REs must submit an annual accessibility compliance report within 30 days from the end of each financial year. Reporting will be done to SEBI, relevant stock exchanges, or BASL depending on the type of entity.
Institutional Roles and Nodal Officers
The responsibility to ensure compliance with this circular lies at the top level of each RE. The circular states that:
- The Managing Director, Managing Partner, or Proprietor must review and approve the digital accessibility compliance.
- A senior officer must be appointed as the Nodal Officer to oversee digital accessibility efforts. In the absence of such designation, the compliance officer or proprietor will be considered the default nodal officer.
The Nodal Officer must:
- Ensure that accessibility audits are conducted.
- Oversee remediation of audit findings.
- Implement accessibility guidelines across platforms.
- Address grievances related to accessibility.
- Act as the contact point for SEBI.
The Nodal Officer is expected to coordinate closely with an IAAP certified auditor to ensure that audit findings are properly understood, prioritized and remediated in line with WCAG and RPwD Act requirements.
Additionally, REs must set up a grievance redressal mechanism that is accessible to persons with disabilities and includes channels like email, phone helplines, and web forms.
Accessibility of Websites and Documents
SEBI emphasizes that accessibility is not limited to websites. It extends to all digital documents and user interfaces.
- Websites must include Indian Sign Language (ISL) videos, closed captions for audio, alternate text for images, and descriptive audio where needed.
- PDFs and digital documents must be fully accessible. This means:
- Using tagged PDFs.
- Logical reading order.
- Proper headings and formatting.
- Alternate text for images.
If a newer accessibility standard is released by W3C or BIS, REs must comply with the latest version.
Inclusive Training and Awareness Programs
Another key focus of the circular is internal capacity building. SEBI mandates that:
- Accessibility training must be a part of all internal training programs.
- This includes staff as well as third-party vendors who design or develop digital content.
- Trainings should cover:
- Understanding of accessibility guidelines.
- Use of assistive tools.
- Creating inclusive digital experiences.
- Behavior training to improve support for customers with disabilities.
The circular calls for an “accessible by design” approach rather than treating accessibility as an afterthought.
Organizations looking to build in-house expertise may consider encouraging team members to pursue IAAP certification such as CPACC (Certified Professional in Accessibility Core Competencies) or WAS (Web Accessibility Specialist) to develop sustained internal accessibility capability aligned with global best practices.
Accessible KYC and Onboarding
Digital KYC, e-KYC, and video KYC must be made inclusive for people with disabilities.
Some of the recommendations include:
- Offering human-assisted video KYC.
- Allowing document uploads as an alternative.
- Enabling voice-assisted KYC options for visually impaired users.
KYC and client registration forms must include a mandatory field to declare disability status. If a client’s application is rejected, it must be reviewed by a human officer who has the authority to override automated systems and approve the application if possible.
This ensures that persons with disabilities are not unfairly excluded from financial services due to rigid digital procedures.
Mandatory Accessibility Audits
All REs must conduct comprehensive accessibility audits of their digital platforms.
- The audits must be performed by IAAP-certified accessibility professionals.
- The audit should follow the latest WCAG, GIGW, and RPwD Act standards.
- Usability testing must involve persons with disabilities.
Following the audit, REs are required to:
- Prepare a plan to remediate the findings.
- Implement changes within the stipulated six-month timeline.
- Conduct annual audits thereafter to maintain compliance.
For annual audits, it is recommended to retain an IAAP certified auditor or an accessibility firm employing IAAP certified professionals, ensuring continuity, consistency and credibility in year-over-year compliance reporting to SEBI.
Accessibility in Procurement and Vendor Management
Accessibility must be considered right from the procurement stage of any digital solution.
- All newly developed or purchased digital platforms must conform to accessibility standards.
- If REs are using SaaS or customized SaaS platforms, vendors must prove accessibility through third-party audits.
- Accessibility requirements must be included in all Requests for Proposal (RFPs) and procurement contracts.
- Evaluation criteria must assign weightage to accessibility readiness.
The responsibility for compliance lies with the RE, even if the digital solution is provided by a third-party vendor.
What This Means for the Indian Financial Sector?
SEBI’s circular is a clear indication that digital accessibility is no longer optional. It is a legal, ethical, and social responsibility. For the first time, there is an enforcement mechanism tied directly to investor protection and market development.
This will:
- Improve access to financial services for millions of Indians with disabilities.
- Encourage innovation in accessible fintech solutions.
- Push digital service providers to meet global accessibility standards.
- Promote inclusive growth in the Indian capital market.
How BarrierBreak Can Help?
BarrierBreak is proud to be an empanelled Web Accessibility Auditor with the Department of Empowerment of Persons with Disabilities (DEPwD), under the Ministry of Social Justice & Empowerment, Government of India and an authorized accessibility auditor with IAAP. As an empanelled accessibility auditor, BarrierBreak works closely with the Government Departments and Corporates in creating an inclusive and accessible digital environment for people with disabilities.
Our team of IAAP certified auditors holds credentials including CPACC and WAS, and is equipped to deliver comprehensive accessibility audits that meet SEBI's mandate for IAAP certified accessibility professionals.
We offer:
- Accessibility audits by IAAP-certified professionals.
- Manual testing and automated testing for websites, mobile apps, and documents.
- Accessibility training programs for your teams and vendors.
- Guidance on procurement and product development to ensure accessibility by design.
- Support in web and mobile remediation.
- Inclusive usability testing involving users with disabilities.
With over two decades of experience in accessibility, BarrierBreak is well-positioned to support Regulated Entities in meeting SEBI’s compliance deadlines with confidence. Contact BarrierBreak to get started on your digital accessibility journey.