Description

SEBI issues clarifications on digital accessibility requirements for regulated entities, extending compliance deadlines and establishing complaint mechanisms through SCORES.

Summary

SEBI has issued clarifications on digital accessibility requirements for regulated entities (REs) in the securities market. The circular extends the compliance deadline and establishes a framework for accessibility complaint resolution through SCORES. Digital accessibility will be included as an investor right in respective Investor Charters. REs must submit readiness status by March 31, 2026, and conduct periodic accessibility audits through certified professionals.

Key Points

  • Investors’ Right to digital accessibility to be included in Investor Charters of all regulated entities
  • Compliance deadline extended from December 14, 2025 to March 31, 2026 for readiness status submission
  • Accessibility complaints can be lodged through SCORES platform under dedicated “Accessibility” category
  • REs must conduct periodic accessibility audits through certified accessibility professionals
  • Applies to all investor-facing digital platforms including websites, mobile apps, and portals
  • Status reports to be submitted to specified reporting authorities (Stock Exchanges/Depositories for brokers/DPs, BSE Ltd for IAs/RAs, SEBI for other REs)

Regulatory Changes

  • Investor Charter Update: Digital accessibility rights to be added to Investor Charters published by SEBI for various regulated entities
  • Compliance Framework: Modified from appointing accessibility auditor by December 14, 2025 to submitting readiness status by March 31, 2026
  • SCORES Integration: New complaint category for “Accessibility” issues against REs now available on SCORES platform
  • Audit Requirement: Mandatory periodic accessibility audits by certified accessibility professionals for all digital platforms
  • References: Supersedes/clarifies 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), and SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/131 (September 25, 2025)

Compliance Requirements

For All Regulated Entities:

  1. Readiness Status Submission (by March 31, 2026):

    • Submit status of readiness and compliance to accessibility requirements
    • Cover each investor-facing digital platform separately
    • Use format specified in Annexure B
    • Submit to appropriate reporting authority:
      • Stock Brokers/Depository Participants: Stock Exchanges/Depositories
      • Investment Advisors/Research Analysts: BSE Limited
      • Other REs: SEBI at digital_acc@sebi.gov.in

  2. Complaint Resolution:

    • Respond to accessibility complaints lodged on SCORES
    • Remediate accessibility issues for complaint closure

  3. Periodic Audits:

    • Conduct regular accessibility audits of digital platforms
    • Use certified accessibility professionals
    • Cover websites, mobile apps, and portals

Entities Reporting Directly to SEBI: Alternative Investment Funds, Bankers to Issue, Self Certified Syndicate Banks, Clearing Corporations, Collective Investment Schemes, Credit Rating Agencies, Custodians, Debenture Trustees, Depositories, KYC Registration Agencies, Merchant Bankers, Mutual Funds/AMCs, Portfolio Managers, Registrars to Issue and Share Transfer Agents, Stock Exchanges, Venture Capital Funds

Important Dates

  • December 08, 2025: Circular issue date
  • March 31, 2026: Deadline for REs to submit readiness and compliance status for digital platforms
  • Previous Deadline (now modified): December 14, 2025 (originally for accessibility auditor appointment)

Impact Assessment

Market-Wide Impact:

  • Affects entire securities market ecosystem including stock exchanges, clearing corporations, depositories, and all registered intermediaries
  • Establishes digital accessibility as fundamental investor right

Operational Impact:

  • REs gain additional time (3.5 months) to prepare accessibility compliance
  • Need to assess and document readiness status for all digital platforms
  • Must establish processes for handling accessibility complaints through SCORES
  • Requires ongoing relationship with certified accessibility professionals for periodic audits

Investor Protection:

  • Enhances accessibility for persons with disabilities across all market platforms
  • Provides formal complaint mechanism through SCORES for accessibility issues
  • Mandates remediation of accessibility barriers

Compliance Burden:

  • Medium - requires assessment, documentation, and ongoing audit commitments
  • Extends to all investor-facing digital touchpoints
  • Multiple reporting channels based on entity type

Impact Justification

Affects all regulated entities including stock exchanges, clearing corporations, depositories, intermediaries, and market participants. Introduces digital accessibility as investor right with extended compliance timeline and new complaint mechanisms.