Description

SEBI issues clarifications on digital accessibility requirements for Regulated Entities, extending compliance deadline and introducing accessibility complaint mechanism on SCORES.

Summary

SEBI has issued clarifications on digital accessibility requirements for Regulated Entities (REs), modifying the compliance timeline and framework established under three earlier circulars (SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111, 121, and 131 dated July 31, August 29, and September 25, 2025). The “Investors’ Right to have digital accessibility” will be included in respective Investor Charters. Instead of appointing accessibility auditors by December 14, 2025, REs must submit a readiness and compliance status by March 31, 2026. A new accessibility complaint category has been provisioned in SCORES for investors to lodge complaints against REs.

Key Points

  • Investors’ Right to digital accessibility to be included in Investor Charters applicable to various REs
  • Original deadline of December 14, 2025 for appointing accessibility auditor has been replaced with status submission requirement
  • REs must submit readiness and compliance status for each digital platform by March 31, 2026
  • Stock Brokers/Depository Participants report to Stock Exchanges/Depositories
  • Investment Advisors and Research Analysts report to BSE Ltd.
  • Other REs including MIIs report directly to SEBI at digital_acc@sebi.gov.in
  • New “Accessibility” complaint category available on SCORES platform
  • REs must remediate accessibility issues to close complaints
  • Periodic accessibility audits required through certified accessibility professionals
  • Circular applies to all investor-facing digital platforms including websites, mobile apps, and portals

Regulatory Changes

  • Investor Charter Amendment: “Investors’ Right to have digital accessibility” will be added to respective Investor Charters published by SEBI for various REs
  • Compliance Timeline Extension: The December 14, 2025 deadline for appointing accessibility auditors has been replaced with a March 31, 2026 deadline for submitting readiness status
  • Complaint Mechanism: New accessibility-related complaint category introduced in SCORES platform, enabling investors to lodge complaints against REs for accessibility issues
  • Reporting Structure: Three-tier reporting structure established:
    • Stock Brokers/Depository Participants → Stock Exchanges/Depositories
    • Investment Advisors/Research Analysts → BSE Ltd.
    • All other REs → SEBI directly

Compliance Requirements

All Regulated Entities must:

  1. Status Submission (by March 31, 2026): Submit readiness and compliance status for each investor-facing digital platform to specified reporting authorities

  2. Accessibility Audits: Conduct periodic accessibility audits of all digital platforms (websites, mobile apps, portals) through certified accessibility professionals

  3. Complaint Resolution: Respond to and remediate accessibility-related complaints lodged on SCORES platform

Reporting Authorities:

  • Stock Brokers/Depository Participants → Stock Exchanges/Depositories
  • Investment Advisors and Research Analysts → BSE Ltd.
  • 15 categories of REs report directly to SEBI, including: AIFs, Bankers to Issue, Clearing Corporations, CIS, Credit Rating Agencies, Custodians, Debenture Trustees, Depositories, KRAs, Merchant Bankers, Mutual Funds/AMCs, Portfolio Managers, RTAs, Stock Exchanges, and Venture Capital Funds

Important Dates

  • December 08, 2025: Circular issue date
  • December 14, 2025: Original accessibility auditor appointment deadline (now replaced)
  • March 31, 2026: New deadline for REs to submit readiness and compliance status for each digital platform

Reference Circulars:

  • July 31, 2025: SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111
  • August 29, 2025: SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/121
  • September 25, 2025: SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/131

Impact Assessment

Positive Impacts:

  • Investor Protection: Enhances accessibility for persons with disabilities, expanding market participation
  • Timeline Relief: Extended deadline provides REs more time to assess and implement accessibility compliance
  • Clear Accountability: Structured reporting mechanism ensures systematic monitoring
  • Grievance Redressal: SCORES integration provides investors formal channel for accessibility complaints

Operational Impact:

  • Broad Applicability: Affects all REs across market ecosystem including stock brokers, depositories, mutual funds, portfolio managers, merchant bankers, clearing corporations, and other intermediaries
  • Technology Investment: REs need to invest in accessibility audits and potential platform modifications
  • Ongoing Compliance: Periodic audits create continuous compliance obligation
  • Complaint Management: REs must establish processes to handle and remediate accessibility complaints

Market Impact:

  • Promotes inclusive digital infrastructure across securities market
  • Aligns with Rights of Persons with Disabilities Act
  • May require significant technology and process upgrades across industry
  • Sets precedent for accessibility standards in financial services digital platforms

Issued under Section 11(1) of the Securities and Exchange Board of India Act, 1992, with approval of Competent Authority.

Impact Justification

Affects all Regulated Entities including stock brokers, mutual funds, depositories, and other market intermediaries. Introduces new compliance framework for digital accessibility with revised deadlines and establishes investor complaint mechanism.