Description

SEBI clarifies digital accessibility compliance requirements for regulated entities, extending the deadline for status submission to March 31, 2026, and establishing complaint mechanisms through SCORES.

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 extends the compliance deadline, requiring REs to submit their digital accessibility readiness status by March 31, 2026, instead of appointing accessibility auditors by December 14, 2025. The circular also establishes an “Accessibility” complaint category in SCORES for investors to report accessibility-related issues on digital platforms.

Key Points

  • “Investors’ Right to have digital accessibility” will be included in respective Investor Charters for various regulated entities
  • REs must submit status of readiness and compliance for each digital platform by March 31, 2026
  • Stock Brokers and Depository Participants report to Stock Exchanges/Depositories
  • Investment Advisors and Research Analysts report to BSE Ltd.
  • Other regulated entities including AIFs, Mutual Funds, Credit Rating Agencies, and Clearing Corporations report directly to SEBI at digital_acc@sebi.gov.in
  • Investors can lodge accessibility complaints through SCORES platform under “Accessibility” category
  • REs must remediate accessibility issues for complaint closure
  • Periodic accessibility audits mandatory through certified accessibility professionals

Regulatory Changes

This circular modifies and clarifies three previous SEBI circulars issued on digital accessibility:

  • 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)

Key changes include extending the compliance deadline and establishing clearer reporting structures and investor grievance mechanisms.

Compliance Requirements

Reporting Requirements

  • Submit status of readiness and compliance for each investor-facing digital platform (websites, mobile apps, portals) by March 31, 2026
  • Use specified reporting authorities based on entity type (see Annexure A)
  • Entities reporting to SEBI must use email: digital_acc@sebi.gov.in
  • Follow prescribed format in Annexure B for status submission

Operational Requirements

  • Respond to and remediate accessibility-related complaints filed through SCORES
  • Conduct periodic accessibility audits of all digital platforms
  • Use certified accessibility professionals for audits
  • Ensure compliance with digital accessibility standards for all investor-facing platforms

Entities Reporting Directly to SEBI

15 categories including: Alternative Investment Funds, Clearing Corporations, Credit Rating Agencies, Custodians, Debenture Trustees, Depositories, KYC Registration Agencies, Merchant Bankers, Mutual Funds/AMCs, Portfolio Managers, Registrar to an Issue and Share Transfer Agents, Stock Exchanges, Venture Capital Funds, Bankers to an Issue, and Collective Investment Schemes.

Important Dates

  • December 8, 2025: Circular issue date
  • December 14, 2025: Original deadline for accessibility auditor appointment (now superseded)
  • March 31, 2026: New deadline for submitting digital accessibility readiness and compliance status

Impact Assessment

Market-Wide Impact

This circular impacts the entire securities market ecosystem, affecting all regulated entities including stock exchanges, brokers, depositories, mutual funds, and other intermediaries. The requirement mandates significant technology and compliance investments across the industry.

Investor Protection

Strengthens investor protection by ensuring persons with disabilities have equal access to digital platforms. The SCORES complaint mechanism provides enforceable recourse for accessibility issues.

Operational Impact

  • REs need to conduct accessibility assessments of all digital platforms
  • Investment required in accessibility audits and certified professionals
  • Technology upgrades may be necessary to meet accessibility standards
  • Ongoing compliance burden through periodic audits and complaint resolution
  • Enhanced accountability through mandatory remediation of accessibility issues

Issued under Section 11(1) of the Securities and Exchange Board of India Act, 1992, giving it legal enforceability. Non-compliance could result in regulatory action.

Impact Justification

Affects all SEBI regulated entities including stock brokers, depositories, mutual funds, and other intermediaries. Establishes mandatory digital accessibility standards and investor complaint mechanisms.