Description
SEBI clarifies digital accessibility compliance requirements for regulated entities, extending the deadline for status submission to March 31, 2026, and introducing accessibility complaint mechanism through SCORES.
Summary
SEBI has issued clarifications on digital accessibility requirements for all Regulated Entities (REs) pursuant to the Rights of Persons with Disabilities Act, 2016. The circular modifies the compliance timeline originally set for December 14, 2025, now requiring REs to submit their readiness status by March 31, 2026. Key changes include the inclusion of digital accessibility in Investor Charters, establishment of accessibility complaint mechanism through SCORES, and mandatory periodic accessibility audits through certified professionals.
Key Points
- Investors’ Right to digital accessibility will be included in respective Investor Charters applicable to various regulated entities
- Compliance deadline extended from December 14, 2025 to March 31, 2026 for status submission
- REs must submit readiness and compliance status for each digital platform to specified reporting authorities
- New accessibility complaint category established in SCORES for investor grievances
- Mandatory periodic accessibility audits required through certified accessibility professionals
- Applies to all investor-facing digital platforms including websites, mobile apps, and portals
- REs reporting to SEBI must submit status to digital_acc@sebi.gov.in
Regulatory Changes
Modified Compliance Timeline:
- Original requirement for appointing accessibility auditor by December 14, 2025 has been replaced
- New requirement: Submit status of readiness and compliance by March 31, 2026
Investor Charter Amendment:
- “Investors’ Right to have digital accessibility” to be incorporated into respective Investor Charters published by SEBI for various regulated entities
Complaint Mechanism:
- Accessibility-related complaints can now be lodged on SCORES platform
- New “Accessibility” complaint category provisioned in SCORES
- REs must remediate accessibility issues for complaint closure
Audit Requirements:
- All REs must conduct periodic accessibility audits of digital platforms
- Audits must be performed through certified accessibility professionals
- Covers websites, mobile apps, and portals
Compliance Requirements
For All Regulated Entities:
Status Submission (by March 31, 2026):
- Submit readiness and compliance status for each investor-facing digital platform
- Use format provided in Annexure B (referenced but not detailed in circular)
- Submit to specified reporting authorities as per Annexure A
Reporting Channels:
- Stock Brokers/Depository Participants: Report to Stock Exchanges/Depositories
- Investment Advisors and Research Analysts: Report to BSE Ltd.
- Other REs (see detailed list): Report directly to SEBI at digital_acc@sebi.gov.in
Entities Reporting to SEBI:
- Alternative Investment Funds (AIFs)
- Bankers to an Issue (BTI) and Self Certified Syndicate Banks (SCSBs)
- Clearing Corporations
- Collective Investment Schemes (CIS)
- Credit Rating Agencies (CRAs)
- Custodians
- Debenture Trustees (DTs)
- Depositories
- KYC Registration Agencies (KRAs)
- Merchant Bankers (MBs)
- Mutual Funds (MFs)/Asset Management Companies (AMCs)
- Portfolio Managers
- Registrar to an Issue and Share Transfer Agents (RTAs)
- Stock Exchanges
- Venture Capital Funds (VCFs)
Complaint Handling:
- Monitor accessibility complaints on SCORES platform
- Remediate reported accessibility issues
- Close complaints after successful remediation
Ongoing Audits:
- Conduct periodic accessibility audits
- Engage certified accessibility professionals
- Cover all digital platforms (websites, mobile apps, portals)
Important Dates
- December 08, 2025: Circular issue date
- December 14, 2025: Original accessibility auditor appointment deadline (now superseded)
- March 31, 2026: Deadline for REs to submit readiness and compliance status for digital platforms
Impact Assessment
Market-Wide Impact: This circular affects the entire securities market ecosystem, covering all regulated entities from stock exchanges to individual intermediaries. The mandatory digital accessibility requirements represent a significant operational change requiring technology upgrades and process implementations across the industry.
Operational Impact:
- REs need to assess current digital platforms against accessibility standards
- Investment required in accessibility audits and remediation efforts
- Ongoing compliance monitoring and periodic audits add to operational costs
- Technology teams must implement accessibility features across websites, mobile apps, and portals
Investor Protection:
- Enhances market access for persons with disabilities
- Strengthens investor rights through inclusion in Investor Charters
- Provides formal grievance mechanism through SCORES for accessibility issues
- Promotes inclusive financial market participation
Compliance Impact:
- Extension to March 31, 2026 provides additional time for preparation
- Reporting requirement creates accountability mechanism
- Ongoing audit requirements ensure continuous compliance
- Non-compliance may result in regulatory action and investor complaints
Legal Framework: Circular issued under Section 11(1) of the Securities and Exchange Board of India Act, 1992, demonstrating regulatory commitment to investor protection and market development aligned with Rights of Persons with Disabilities Act, 2016.
Reference Circulars:
- SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111 dated July 31, 2025
- SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/121 dated August 29, 2025
- SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/131 dated September 25, 2025
Impact Justification
High importance and impact as it affects all regulated entities including stock exchanges, clearing corporations, depositories, intermediaries, mutual funds, and other market participants. Mandates critical accessibility compliance for digital platforms and introduces new investor complaint mechanism.