Description

SEBI issues compliance guidelines for implementation of digital accessibility requirements under the Rights of Persons with Disabilities Act, 2016 for all regulated entities.

Summary

SEBI has issued detailed compliance guidelines (Circular No. SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/131) dated September 25, 2025, for implementing digital accessibility requirements under the Rights of Persons with Disabilities Act, 2016. All regulated entities must ensure their digital platforms comply with accessibility standards through mandatory audits by IAAP certified professionals, with phased compliance deadlines starting September 2025.

Key Points

  • Compliance guidelines supplement the original circular dated July 31, 2025 (Circular No. SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111)
  • Applicable to all SEBI regulated entities including stock exchanges, clearing corporations, depositories, intermediaries, AMFI, APMI, and BSE Ltd.
  • Mandates appointment of IAAP (International Association of Accessibility Professionals) certified accessibility professionals as auditors
  • Requires accessibility audits for all digital platforms provided to investors
  • Different reporting authorities: Stock Exchanges/Depositories for brokers/DPs, BSE Ltd. for IAs and RAs, SEBI for MIIs and other REs
  • Consolidated audit reports required for entities with multiple digital platforms
  • Annual compliance submissions mandatory from April 30, 2027

Regulatory Changes

This circular establishes a comprehensive compliance framework for digital accessibility:

  1. Auditor Certification Requirement: Only IAAP certified accessibility professionals can conduct audits
  2. Phased Implementation: Multi-stage compliance process with specific deadlines
  3. Annual Reporting Obligation: Ongoing compliance requirement with annual audits and reports
  4. Centralized Submission: Email-based submission to digital_acc@sebi.gov.in for certain REs
  5. Consolidated Reporting: Entities with multiple platforms must submit consolidated reports

Compliance Requirements

Phase-wise Compliance Schedule:

1. September 30, 2025: Submit list of digital platforms provided to investors (Table-C1)

2. December 14, 2025: Appointment of IAAP certified accessibility professionals as auditors (Table-C2)

3. April 30, 2026: Conduct accessibility audit for all digital platforms and submit initial audit reports (Table-C3)

4. July 31, 2026: Complete remediation of audit findings and ensure compliance, submit final audit reports (Table-C4)

5. April 30, 2027 onwards: Annual accessibility audits and final report submission within 30 days of each financial year

Reporting Mechanism:

  • Stock Brokers/Depository Participants: Report to Stock Exchanges/Depositories
  • Investment Advisors and Research Analysts: Report to BSE Ltd.
  • Market Infrastructure Institutions (MIIs) and other REs: Report directly to SEBI via email at digital_acc@sebi.gov.in

Multiple Platform Requirement:

For regulated entities operating multiple digital platforms, consolidated audit reports must be submitted covering all platforms together by the specified deadlines.

Important Dates

  • September 30, 2025: List of digital platforms submission deadline
  • December 14, 2025: IAAP certified auditor appointment deadline
  • April 30, 2026: Initial accessibility audit completion and report submission
  • July 31, 2026: Remediation completion and final audit report submission
  • April 30, 2027: First annual compliance submission
  • Annually thereafter: Within 30 days of each financial year end

Impact Assessment

Operational Impact:

High - Regulated entities must:

  • Identify and catalog all investor-facing digital platforms
  • Engage IAAP certified professionals (may require vendor selection process)
  • Allocate resources for accessibility audits and remediation
  • Implement technical changes to achieve accessibility compliance
  • Establish annual audit and reporting processes

Compliance Impact:

High - This is a mandatory requirement with specific deadlines. Non-compliance could result in:

  • Regulatory action from SEBI
  • Inability to serve investors with disabilities
  • Reputational risk

Cost Impact:

Medium to High - Entities will incur costs for:

  • IAAP certified auditor fees
  • Accessibility audit services
  • Platform remediation and technical updates
  • Ongoing annual audit expenses

Investor Impact:

Positive - Enhanced accessibility will:

  • Enable persons with disabilities to access digital platforms independently
  • Improve overall user experience
  • Promote financial inclusion
  • Ensure compliance with Rights of Persons with Disabilities Act, 2016

Market Impact:

Medium - System-wide implementation may temporarily affect platform updates and maintenance schedules as entities prioritize accessibility compliance.

Impact Justification

Mandatory compliance requirement affecting all regulated entities with specific deadlines for accessibility audits, requiring IAAP certified professionals and annual reporting obligations starting 2027.