Description
SEBI issues clarifications on digital accessibility compliance requirements for regulated entities, extending the deadline for readiness status submission to March 31, 2026.
Summary
SEBI has issued clarifications on digital accessibility requirements for all Regulated Entities (REs) under the Rights of Persons with Disabilities Act, 2016. The circular modifies previous requirements issued in July, August, and September 2025, extending the compliance deadline and establishing new reporting mechanisms. REs must now submit their readiness status by March 31, 2026, and implement accessibility complaint resolution through SCORES. The “Investors’ Right to have digital accessibility” will be included in respective Investor Charters.
Key Points
- Deadline extended: REs must submit status of readiness and compliance by March 31, 2026 (previously December 14, 2025 for accessibility auditor appointment)
- Investors’ right to digital accessibility will be included in all applicable Investor Charters published by SEBI
- New accessibility complaint category provisioned in SCORES for investor grievances
- REs must remediate accessibility issues for complaint closure
- Mandatory periodic accessibility audits through certified accessibility professionals required
- Applies to all investor-facing digital platforms including websites, mobile apps, and portals
Regulatory Changes
Modified Compliance Timeline:
- Original requirement for accessibility auditor appointment by December 14, 2025 has been replaced
- New requirement: Submit readiness and compliance status for each digital platform by March 31, 2026
Investor Charter Updates:
- “Investors’ Right to have digital accessibility” to be incorporated into respective Investor Charters for various REs
Complaint Mechanism:
- Accessibility-related complaints can now be lodged against REs on SCORES platform
- Dedicated “Accessibility” complaint category already provisioned
- REs obligated to remediate accessibility issues for complaint closure
Ongoing Compliance:
- Periodic accessibility audits mandated for all digital platforms
- Audits must be conducted through certified accessibility professionals
Compliance Requirements
All Regulated Entities must:
Submit Status Report by March 31, 2026:
- Provide readiness and compliance status for each investor-facing digital platform
- Use format specified in Annexure B
- Submit to designated reporting authorities (see Annexure A)
- REs reporting to SEBI: Email to digital_acc@sebi.gov.in
Reporting Authorities by Entity Type:
- Stock Brokers/Depository Participants → Stock Exchanges/Depositories
- Investment Advisors/Research Analysts → BSE Ltd.
- AIFs, MFs/AMCs, Portfolio Managers, Stock Exchanges, CRAs, Depositories, and 10 other entity types → SEBI directly
Address Accessibility Complaints:
- Monitor and respond to accessibility complaints lodged on SCORES
- Remediate accessibility issues to close complaints
Conduct Periodic Audits:
- Regular accessibility audits of all digital platforms (websites, mobile apps, portals)
- Use certified accessibility professionals only
Applicable to:
- All Recognised Stock Exchanges
- All Recognised Clearing Corporations
- All Registered Depositories
- All Registered Intermediaries
- AMFI (Association of Mutual Funds in India)
- APMI (Association of Portfolio Managers in India)
- BSE Limited (IAASB and RAASB)
Important Dates
- December 08, 2025: Circular issue date
- March 31, 2026: Deadline for REs to submit readiness and compliance status for digital accessibility
- December 14, 2025: Original deadline for accessibility auditor appointment (now superseded)
Referenced Earlier Circulars:
- SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111 (July 31, 2025)
- SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/121 (August 29, 2025)
- SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/131 (September 25, 2025)
Impact Assessment
Industry-Wide Impact:
- Affects all regulated entities operating investor-facing digital platforms in India’s securities market
- Requires significant technology and compliance investments across the industry
- Extends to 15+ categories of REs including stock exchanges, mutual funds, brokers, depositories, and intermediaries
Investor Protection:
- Enhances accessibility for persons with disabilities across all securities market digital platforms
- Establishes formal grievance mechanism through SCORES for accessibility issues
- Formalizes accessibility as an investor right in Investor Charters
Operational Impact:
- REs must audit existing digital infrastructure for accessibility compliance
- Ongoing requirement for periodic audits adds to operational costs
- Need to engage certified accessibility professionals
- Complaint remediation obligation may require dedicated resources
Timeline Relief:
- Extension to March 31, 2026 provides REs additional time (3+ months) to assess and report readiness
- Shift from auditor appointment to status reporting reduces immediate pressure while maintaining accountability
Compliance Burden:
- Multiple reporting channels based on RE type may create administrative complexity
- Format requirements (Annexure B) standardize reporting across industry
- SCORES integration streamlines investor complaint process
Impact Justification
Affects all regulated entities with digital platforms. Extends critical compliance deadline and introduces new investor complaint mechanism for accessibility issues. Mandatory periodic audits required for all REs.