Description
SEBI clarifies digital accessibility compliance requirements, extends deadline to March 31, 2026 for REs to submit readiness status, and introduces accessibility complaint mechanism via SCORES.
Summary
SEBI has issued clarifications on digital accessibility requirements for Regulated Entities (REs) through circular HO/13/19/13(2)2025-ITD-1_VIAP/I/187/2025 dated December 08, 2025. The circular extends the compliance deadline and introduces a streamlined reporting mechanism. REs must now submit their digital accessibility readiness status by March 31, 2026, instead of appointing accessibility auditors by December 14, 2025. The “Investors’ Right to have digital accessibility” will be included in respective Investor Charters, and investors can lodge accessibility-related complaints through SCORES.
Key Points
- Extends deadline from December 14, 2025 to March 31, 2026 for REs to submit accessibility readiness status
- Investors’ Right to digital accessibility to be included in Investor Charters for all REs
- REs must submit compliance status for each digital platform to specified reporting authorities
- Accessibility-related complaints can be lodged via SCORES under “Accessibility” category
- REs required to conduct periodic accessibility audits through certified accessibility professionals
- Different reporting authorities designated for different types of REs (Stock Exchanges/Depositories, BSE Ltd., or directly to SEBI)
- 15 categories of REs will report directly to SEBI including AIFs, Mutual Funds, Stock Exchanges, Credit Rating Agencies, and others
Regulatory Changes
This circular modifies the implementation timeline and compliance mechanism for three previous SEBI circulars on digital accessibility:
- 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)
The circular introduces a new compliance framework that replaces the earlier requirement for appointing accessibility auditors by a specific deadline with a broader readiness assessment and reporting mechanism.
Compliance Requirements
For All Regulated Entities:
- Submit status of readiness and compliance to accessibility requirements for each digital platform by March 31, 2026
- Report to specified authorities:
- Stock Brokers/Depository Participants: Report to Stock Exchanges/Depositories
- Investment Advisors and Research Analysts: Report to BSE Ltd.
- Other REs: Report directly to SEBI at digital_acc@sebi.gov.in
- Conduct periodic accessibility audits of all digital platforms (websites, mobile apps, portals) through certified accessibility professionals
- Remediate accessibility issues raised through SCORES complaints for complaint closure
REs Reporting Directly to SEBI (15 categories): 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, Registrars and Share Transfer Agents, Stock Exchanges, and Venture Capital Funds
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 REs to submit readiness and compliance status
Impact Assessment
Market-Wide Impact: This circular affects the entire securities market ecosystem, covering all regulated entities including stock exchanges, brokers, depositories, mutual funds, and intermediaries. The extension provides REs with additional time to assess and achieve compliance with digital accessibility standards.
Investor Protection: Introduces formal mechanism for investors with disabilities to seek redress for accessibility issues through SCORES, strengthening investor protection and inclusive market participation.
Operational Impact: REs must allocate resources for:
- Comprehensive assessment of all digital platforms
- Engaging certified accessibility professionals for audits
- Implementing remediation measures for accessibility gaps
- Establishing processes to handle accessibility-related complaints
Compliance Burden: While the deadline extension provides relief, REs face ongoing obligations for periodic audits and complaint resolution, requiring sustained investment in accessibility infrastructure and expertise.
Impact Justification
Affects all regulated entities in securities market with new compliance reporting requirements and introduces investor complaint mechanism for accessibility issues