Description

SEBI clarifies digital accessibility compliance requirements for regulated entities, extends auditor appointment deadline, and mandates readiness status submission by March 31, 2026.

Summary

SEBI has issued clarifications on digital accessibility requirements for regulated entities (REs) under the Rights of Persons with Disabilities Act, 2016. The circular modifies earlier requirements issued in July-September 2025, extending the accessibility auditor appointment deadline and establishing a new compliance framework. Key changes include: submission of readiness status by March 31, 2026 instead of auditor appointment by December 14, 2025; inclusion of digital accessibility rights in investor charters; establishment of accessibility complaint mechanism through SCORES; and mandatory periodic accessibility audits by certified professionals.

Key Points

  • Digital accessibility rights will be included in respective Investor Charters for all regulated entities
  • Deadline for accessibility auditor appointment (previously December 14, 2025) replaced with readiness status submission requirement by March 31, 2026
  • REs must submit compliance status for each digital platform to specified reporting authorities
  • Stock Brokers and Depository Participants report to Stock Exchanges/Depositories
  • Investment Advisors and Research Analysts report to BSE Ltd.
  • 15 categories of REs (including AIFs, MFs, AMCs, Stock Exchanges, Depositories, CRAs, etc.) report directly to SEBI
  • Accessibility-related complaints can be lodged on SCORES platform under dedicated “Accessibility” category
  • All regulated entities must conduct periodic accessibility audits through certified accessibility professionals
  • Applies to all investor-facing digital platforms including websites, mobile apps, and portals

Regulatory Changes

  • Modified Compliance Timeline: Changed from appointing accessibility auditor by December 14, 2025 to submitting readiness status by March 31, 2026
  • Investor Charter Amendment: “Investors’ Right to have digital accessibility” will be formally added to investor charters applicable to various REs
  • SCORES Integration: Accessibility complaints category already provisioned in SCORES platform for investor grievances
  • Audit Framework: Establishes ongoing requirement for periodic accessibility audits (not one-time compliance)
  • References three earlier circulars: SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111 (July 31), /121 (August 29), and /131 (September 25, 2025)

Compliance Requirements

For All Regulated Entities:

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

    • Submit status of readiness and compliance for each digital platform
    • Use format provided in Annexure B (referenced but not detailed in circular)
    • Submit to appropriate reporting authority based on entity type
    • REs reporting to SEBI: email digital_acc@sebi.gov.in

  2. Periodic Accessibility Audits

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

  3. Complaint Resolution

    • Monitor and respond to accessibility complaints on SCORES
    • Remediate accessibility issues for complaint closure
    • Ensure investor-facing platforms allow accessibility issue reporting

Reporting Structure:

  • Stock Brokers/Depository Participants: Report to Stock Exchanges/Depositories
  • Investment Advisors/Research Analysts: Report to BSE Ltd.
  • 15 Other RE Categories: Report directly to SEBI (see detailed list in Annexure A)

Important Dates

  • December 8, 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
  • Ongoing: Periodic accessibility audits required (frequency not specified)

Impact Assessment

Market-Wide Impact: This circular affects the entire securities market ecosystem, covering stock exchanges, clearing corporations, depositories, all categories of intermediaries, mutual funds, portfolio managers, and other regulated entities. The compliance burden is significant as it requires assessment and potential remediation of all digital touchpoints.

Investor Protection: Strengthens rights of persons with disabilities by formally incorporating digital accessibility into investor charters and establishing clear complaint redressal mechanism through SCORES. This represents a fundamental shift toward inclusive digital platforms in the securities market.

Operational Impact:

  • REs must audit existing digital infrastructure for accessibility compliance
  • Potential need for platform redesign or updates to meet accessibility standards
  • Ongoing cost of periodic audits by certified professionals
  • Need to establish internal processes for handling accessibility complaints
  • Extended timeline (to March 31, 2026) provides more preparation time than original December 2025 deadline

Compliance Complexity: Different reporting channels for different entity types may create coordination challenges. However, the structured approach with designated reporting authorities should streamline oversight.

Legal Framework: Issued under Section 11(1) of SEBI Act 1992 with approval of Competent Authority, ensuring strong regulatory backing for enforcement.

Impact Justification

Affects all regulated entities across the securities market including stock brokers, depositories, mutual funds, and intermediaries. High impact due to new compliance framework with periodic audits and investor complaint mechanism through SCORES.