Description

SEBI provides clarifications on digital accessibility requirements for regulated entities, extending compliance deadlines and establishing new reporting mechanisms through SCORES.

Summary

SEBI has issued clarifications on its digital accessibility circulars (referenced circulars from July 31, August 29, and September 25, 2025). The circular extends the compliance deadline for accessibility auditor appointment from December 14, 2025 to March 31, 2026, when regulated entities must submit their readiness status. Digital accessibility is now being incorporated into Investor Charters, and a new complaint mechanism for accessibility issues has been established through SCORES.

Key Points

  • “Investors’ Right to have digital accessibility” will be included in respective Investor Charters for various regulated entities
  • Compliance deadline extended: REs must submit readiness status by March 31, 2026 instead of appointing accessibility auditor by December 14, 2025
  • New complaint mechanism: Investors can lodge accessibility-related complaints through SCORES under “Accessibility” category
  • REs must remediate accessibility issues for complaint closure
  • Periodic accessibility audits required for all digital platforms (websites, mobile apps, portals) through certified accessibility professionals
  • Compliance 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

  • Extension of compliance timeline for accessibility requirements
  • Introduction of readiness and compliance status reporting format (Annexure B)
  • Integration of digital accessibility rights into Investor Charters
  • New SCORES complaint category for accessibility-related issues
  • Defined reporting structure with three tiers: Stock Exchanges/Depositories, BSE Ltd., and SEBI direct reporting

Compliance Requirements

For All Regulated Entities:

  • Submit status of readiness and compliance for each digital platform by March 31, 2026
  • Use specified format (Annexure B) for submission
  • Submit to appropriate reporting authority:
    • Stock Brokers/Depository Participants: Report to Stock Exchanges/Depositories
    • Investment Advisors/Research Analysts: Report to BSE Ltd.
    • Other REs (15 categories including AIFs, MFs, CRAs, etc.): Report to SEBI at digital_acc@sebi.gov.in
  • Conduct periodic accessibility audits through certified accessibility professionals
  • Remediate accessibility issues raised through SCORES complaints

Entities Reporting Directly to SEBI: Alternative Investment Funds, Bankers to an Issue, Clearing Corporations, Collective Investment Schemes, Credit Rating Agencies, Custodians, Debenture Trustees, Depositories, KYC Registration Agencies, Merchant Bankers, Mutual Funds/AMCs, Portfolio Managers, RTAs, Stock Exchanges, and Venture Capital Funds

Important Dates

  • December 08, 2025: Circular issue date
  • December 14, 2025: Original deadline for accessibility auditor appointment (now modified)
  • March 31, 2026: New deadline for submitting readiness and compliance status to reporting authorities

Impact Assessment

Market-Wide Impact: This circular affects all regulated entities in the securities market, providing much-needed clarity and extended timelines for digital accessibility compliance. The extension from December 14, 2025 to March 31, 2026 gives REs additional time to assess and report their digital accessibility status.

Investor Protection: The inclusion of digital accessibility rights in Investor Charters strengthens investor protection, particularly for persons with disabilities. The SCORES complaint mechanism provides investors with a direct channel to report accessibility issues.

Operational Impact: REs must evaluate all investor-facing digital platforms (websites, mobile apps, portals) for accessibility compliance and engage certified accessibility professionals for periodic audits. The requirement to remediate issues for complaint closure may require resource allocation and technical infrastructure upgrades.

Compliance Burden: While the extended timeline reduces immediate pressure, REs must still prepare comprehensive status reports by March 31, 2026, and establish ongoing audit processes with certified professionals.

Impact Justification

Affects all regulated entities including stock exchanges, clearing corporations, depositories, intermediaries, and market participants with modified compliance timelines and new reporting requirements for digital accessibility