Description
SEBI issues clarifications on digital accessibility compliance requirements for regulated entities, extending the deadline for readiness reporting to March 31, 2026, and introducing accessibility complaint mechanisms on SCORES.
Summary
SEBI has issued clarifications on digital accessibility requirements for all Regulated Entities (REs) under the Rights of Persons with Disabilities Act, 2016. Key changes include: (1) extension of accessibility auditor appointment deadline, replaced with a readiness status submission by March 31, 2026; (2) addition of “Investors’ Right to have digital accessibility” in Investor Charters; (3) introduction of accessibility-related complaint category on SCORES platform; and (4) requirement for periodic accessibility audits by certified professionals. This applies to all investor-facing digital platforms including websites, mobile apps, and portals.
Key Points
- Investors’ Right to digital accessibility will be included in respective Investor Charters for all REs
- Original December 14, 2025 deadline for accessibility auditor appointment replaced with status reporting requirement
- REs must submit readiness and compliance status for each digital platform by March 31, 2026
- New “Accessibility” complaint category added to SCORES for investor grievances
- REs must remediate accessibility issues to close complaints
- Mandatory periodic accessibility audits required through certified professionals
- Applies to all investor-facing digital platforms (websites, mobile apps, portals)
- Different reporting authorities for different RE categories: Stock Exchanges/Depositories for brokers/DPs, BSE Ltd for IAs/RAs, SEBI for MIIs and others
Regulatory Changes
References Three Previous 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)
- SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/131 (September 25, 2025)
Key Modifications:
Investor Charter Update: “Investors’ Right to have digital accessibility” to be formally included in all RE-specific Investor Charters published by SEBI
Compliance Mechanism Change: Original requirement for appointing accessibility auditor by December 14, 2025 replaced with readiness status submission requirement
SCORES Enhancement: New accessibility complaint category introduced allowing investors to lodge platform accessibility issues directly against REs
Audit Requirements: Formalized requirement for periodic accessibility audits by certified accessibility professionals
Compliance Requirements
For All Regulated Entities:
Status Reporting (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 per Annexure A
- REs reporting to SEBI: email to digital_acc@sebi.gov.in
Complaint Management:
- Monitor accessibility complaints on SCORES platform
- Remediate accessibility issues raised in complaints
- Close complaints only after issue remediation
Ongoing Audits:
- Conduct periodic accessibility audits of all digital platforms
- Use certified accessibility professionals for audits
- Cover websites, mobile apps, and portals
Reporting Authority Structure:
- Stock Brokers/Depository Participants: Report to Stock Exchanges/Depositories
- Investment Advisors & Research Analysts: Report to BSE Ltd
- Market Infrastructure Institutions (MIIs) and other REs: Report directly to SEBI
15 RE Categories 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)
Important Dates
- December 8, 2025: Circular issue date
- December 14, 2025: Original deadline for accessibility auditor appointment (now replaced)
- March 31, 2026: NEW deadline for submitting readiness and compliance status for all digital platforms
- Immediate: Accessibility complaint category active on SCORES
Impact Assessment
Market-Wide Impact: This circular affects the entire securities market ecosystem, requiring comprehensive digital accessibility compliance across all regulated entities. Estimated impact on thousands of platforms operated by brokers, depositories, mutual funds, exchanges, and other intermediaries.
Operational Impact:
- Technology Infrastructure: REs must audit and potentially remediate websites, mobile apps, and portals for accessibility compliance
- Resource Requirements: Need to engage certified accessibility professionals for audits
- Complaint Handling: New workflow required for accessibility complaints on SCORES
- Documentation: Status reporting requires assessment of each digital platform’s readiness
Investor Protection Enhancement:
- Formalizes digital accessibility as an investor right in Investor Charters
- Provides direct grievance mechanism through SCORES
- Ensures persons with disabilities have equal access to securities market platforms
- Mandatory remediation requirement strengthens enforcement
Compliance Complexity:
- Multiple platforms per RE require individual assessment
- Ongoing periodic audit requirement creates continuous compliance obligation
- Different reporting channels for different RE categories
- Integration with existing SCORES complaint management systems needed
Timeline Relief: Extension from December 14, 2025 to March 31, 2026 provides approximately 3.5 additional months for REs to assess readiness and prepare compliance status reports, acknowledging implementation challenges.
Legal Foundation: Circular issued under Section 11(1) of the Securities and Exchange Board of India Act, 1992, to protect investor interests and regulate securities markets, providing strong regulatory backing for accessibility requirements.
Impact Justification
Applies to all regulated entities (stock brokers, investment advisors, mutual funds, depositories, etc.) with mandatory digital accessibility compliance requirements and new investor complaint mechanisms. Significant operational impact requiring platform audits and remediation.