Description

SEBI clarifies compliance timelines for digital accessibility requirements, extending deadline to March 31, 2026 for regulated entities to submit readiness status and introducing accessibility complaint mechanism on SCORES.

Summary

SEBI has issued clarifications on previously released digital accessibility circulars (SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111, 121, and 131 dated July 31, August 29, and September 25, 2025). The circular extends the compliance deadline from December 14, 2025 to March 31, 2026 for regulated entities (REs) to submit their readiness status on digital accessibility requirements. The “Investors’ Right to have digital accessibility” will be included in respective Investor Charters, and a new complaint mechanism for accessibility issues is being introduced on SCORES platform.

Key Points

  • Compliance deadline extended from December 14, 2025 to March 31, 2026 for submitting readiness status
  • “Investors’ Right to have digital accessibility” to be included in all applicable Investor Charters
  • New “Accessibility” complaint category available on SCORES platform for investors facing accessibility issues
  • REs must remediate accessibility issues for complaint closure
  • Periodic accessibility audits required through certified accessibility professionals
  • Different reporting authorities specified for different types of regulated entities
  • 15 categories of REs to report directly to SEBI (including AIFs, MFs/AMCs, Stock Exchanges, Depositories, etc.)

Regulatory Changes

  • Timeline Modification: Original requirement for appointment of accessibility auditor by December 14, 2025 has been replaced with submission of readiness and compliance status by March 31, 2026
  • Investor Charter Update: Digital accessibility rights will be incorporated into Investor Charters published by SEBI for various regulated entities
  • Complaint Mechanism: New accessibility-related complaint category added to SCORES platform, enabling investors to lodge complaints against REs
  • Ongoing Compliance: Mandatory periodic accessibility audits introduced for all digital platforms (websites, mobile apps, portals)

Compliance Requirements

For All Regulated Entities:

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

    • Submit status of readiness and compliance to accessibility requirements
    • Cover each investor-facing digital platform separately
    • Report to specified authorities (Stock Exchanges/Depositories for brokers/DPs, BSE Ltd. for IAs/RAs, SEBI for others)
    • Use format provided in Annexure B
    • Email submissions to SEBI: digital_acc@sebi.gov.in

  2. Complaint Remediation:

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

  3. Periodic Audits:

    • Conduct regular accessibility audits of digital platforms
    • Use certified accessibility professionals

Reporting Structure:

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

Investment Advisors & Research Analysts: Report to BSE Ltd.

Direct SEBI Reporting (15 entity types):

  • Alternative Investment Funds (AFD)
  • Bankers to Issue & SCSBs (CFD)
  • Clearing Corporations (MRD)
  • Collective Investment Schemes (IMD)
  • Credit Rating Agencies (DDHS)
  • Custodians (AFD)
  • Debenture Trustees (DDHS)
  • Depositories (MRD)
  • KYC Registration Agencies (MIRSD)
  • Merchant Bankers (CFD)
  • Mutual Funds/AMCs (IMD)
  • Portfolio Managers (IMD)
  • Registrar to Issue & STAs (MIRSD)
  • Stock Exchanges (MRD)
  • Venture Capital Funds (AFD)

Important Dates

  • December 8, 2025: Circular issue date
  • December 14, 2025: Original deadline (now superseded)
  • March 31, 2026: New deadline for submitting readiness and compliance status

Impact Assessment

Operational Impact: All regulated entities must assess and report on digital accessibility compliance across their investor-facing platforms. This includes websites, mobile applications, and portals. Entities need to engage with certified accessibility professionals for ongoing audits.

Investor Protection: Strengthens investor rights by ensuring digital platforms are accessible to persons with disabilities. The SCORES complaint mechanism provides direct recourse for accessibility-related grievances.

Compliance Burden: The extension to March 31, 2026 provides additional time (approximately 3.5 months) for entities to prepare comprehensive readiness reports rather than immediately appointing accessibility auditors.

Market-wide Impact: Affects the entire securities market ecosystem including stock exchanges, brokers, depositories, mutual funds, portfolio managers, and all other intermediaries. This is a significant inclusivity initiative impacting digital service delivery across the industry.

Reference Circulars: This clarification modifies requirements from three previous SEBI circulars issued in July, August, and September 2025 on digital accessibility requirements aligned with the Rights of Persons with Disabilities Act, 2016.

Impact Justification

Affects all regulated entities including stock brokers, depositories, mutual funds, and other intermediaries. Changes compliance timeline and introduces new complaint mechanism for accessibility issues affecting investor access.