Description

SEBI clarifies digital accessibility compliance requirements for Regulated Entities, extending submission deadline to March 31, 2026 and enabling accessibility-related complaints through SCORES.

Summary

SEBI has issued clarifications on its digital accessibility circulars (Circular Nos. 111, 121, and 131 dated July 31, August 29, and September 25, 2025). The circular extends the compliance submission deadline from December 14, 2025 to March 31, 2026, and introduces a mechanism for investors to lodge accessibility-related complaints through SCORES. All Regulated Entities (REs) must submit their digital accessibility readiness status and conduct periodic accessibility audits through certified professionals.

Key Points

  • Investors’ Right to have digital accessibility will be included in respective Investor Charters applicable to various REs
  • REs must submit status of readiness and compliance to accessibility requirements by March 31, 2026 (instead of appointing accessibility auditor by December 14, 2025)
  • Accessibility-related complaints can now be lodged on SCORES under “Accessibility” category
  • REs must remediate accessibility issues for complaint closure
  • All REs must conduct periodic accessibility audits of digital platforms through certified accessibility professionals
  • Applies to all investor-facing digital platforms including websites, mobile apps, and portals

Regulatory Changes

  • Timeline Extension: The requirement for appointment of accessibility auditor by December 14, 2025 has been replaced with submission of readiness status by March 31, 2026
  • Investor Charter Updates: Digital accessibility rights will be formally included in Investor Charters for all categories of REs
  • Complaint Mechanism: New “Accessibility” complaint category provisioned in SCORES platform for investors to report accessibility issues
  • Remediation Requirement: REs must resolve accessibility issues raised through complaints for closure

Compliance Requirements

For All Regulated Entities:

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

    • Submit readiness and compliance status for each digital platform
    • Use format specified in Annexure B
    • Submit to specified reporting authorities (see below)
    • REs reporting directly to SEBI must 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 Handling:

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

Reporting Authorities:

Stock Brokers/Depository Participants: Report to Stock Exchanges/Depositories

Investment Advisors & Research Analysts: Report to BSE Ltd.

Direct SEBI Reporting (15 categories including):

  • Alternative Investment Funds (AFD)
  • Mutual Funds/AMCs (IMD)
  • Portfolio Managers (IMD)
  • Credit Rating Agencies (DDHS)
  • Stock Exchanges (MRD)
  • Depositories (MRD)
  • Clearing Corporations (MRD)
  • Custodians (AFD)
  • Merchant Bankers (CFD)
  • Registrar to an Issue and Share Transfer Agents (MIRSD)
  • KYC Registration Agencies (MIRSD)
  • Debenture Trustees (DDHS)
  • And others (see Annexure A)

Important Dates

  • December 08, 2025: Circular issue date
  • December 14, 2025: Original deadline for accessibility auditor appointment (now superseded)
  • March 31, 2026: NEW deadline for submitting readiness and compliance status

Impact Assessment

Market-Wide Impact: This circular affects all categories of market intermediaries and infrastructure institutions including stock exchanges, brokers, mutual funds, depositories, investment advisors, research analysts, and other registered entities.

Investor Protection: Enhances digital accessibility rights for persons with disabilities, ensuring equal access to financial markets and services. The SCORES complaint mechanism provides investors with a formal channel to report accessibility barriers.

Operational Impact: REs will need to:

  • Assess current digital platform accessibility compliance
  • Engage certified accessibility professionals for audits
  • Implement remediation measures for non-compliant platforms
  • Establish processes for handling accessibility complaints
  • Budget for ongoing accessibility audits and improvements

Timeline Relief: The extension to March 31, 2026 provides additional time for REs to properly assess and document their accessibility compliance status, reducing immediate compliance pressure while maintaining the focus on accessibility improvements.

Legal Framework: Issued under Section 11(1) of the Securities and Exchange Board of India Act, 1992, with approval of Competent Authority.

Impact Justification

Affects all Regulated Entities including stock exchanges, brokers, mutual funds, depositories and intermediaries. Changes compliance timeline and introduces new complaint mechanism for accessibility issues impacting investor rights.