Description

SEBI clarifies digital accessibility compliance requirements for regulated entities, extends deadline to March 31, 2026 for submission of readiness status, and introduces accessibility complaint mechanism through SCORES.

Summary

SEBI has issued clarifications on digital accessibility requirements for Regulated Entities (REs) under the Rights of Persons with Disabilities Act, 2016. The circular modifies the compliance timeline, extends the deadline for submitting accessibility readiness status to March 31, 2026, and establishes an accessibility complaint mechanism through SCORES. The circular references three earlier circulars from July-September 2025 and applies to all stock exchanges, clearing corporations, depositories, and registered intermediaries.

Key Points

  • Investors’ Right to digital accessibility will be included in respective Investor Charters of various REs
  • Deadline for appointment of accessibility auditor changed from December 14, 2025 to submission of readiness status by March 31, 2026
  • REs must submit status of readiness and compliance for each digital platform to specified reporting authorities
  • REs reporting to SEBI shall use email: digital_acc@sebi.gov.in
  • New “Accessibility” complaint category available in SCORES for investor grievances
  • REs must remediate accessibility issues for complaint closure
  • Periodic accessibility audits mandatory through certified accessibility professionals
  • Circular references three prior SEBI circulars: SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111, 121, and 131

Regulatory Changes

  • Investor Charter Amendment: Digital accessibility rights will be formally included in Investor Charters applicable to various regulated entities
  • Modified Compliance Timeline: Original December 14, 2025 deadline for accessibility auditor appointment replaced with March 31, 2026 deadline for readiness status submission
  • Reporting Structure: Three-tier reporting system established:
    • Stock Brokers/Depository Participants report to Stock Exchanges/Depositories
    • Investment Advisors and Research Analysts report to BSE Limited
    • 15 categories of REs report directly to SEBI (including AIFs, Mutual Funds, Credit Rating Agencies, Merchant Bankers, etc.)
  • Complaint Redressal: Accessibility complaints now integrated into SCORES platform with mandatory remediation requirement

Compliance Requirements

For All Regulated Entities:

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

    • Submit status of readiness and compliance for each investor-facing digital platform
    • Use format provided in Annexure B (referenced but not included in circular text)
    • Submit to appropriate reporting authority based on entity type

  2. Complaint Handling:

    • Monitor and respond to accessibility complaints lodged on SCORES
    • Remediate accessibility issues for complaint closure
    • Ensure proper resolution mechanism is in place

  3. Ongoing Compliance:

    • Conduct periodic accessibility audits of all digital platforms (websites, mobile apps, portals)
    • Use only certified accessibility professionals for audits
    • Maintain compliance with digital accessibility standards

Reporting Authorities:

  • Stock Brokers/DPs → Stock Exchanges/Depositories
  • IAs and RAs → BSE Limited (IAASB/RAASB)
  • 15 RE categories → SEBI directly (via digital_acc@sebi.gov.in)

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 submission of readiness and compliance status to reporting authorities
  • Immediate: Accessibility complaint category available in SCORES

Referenced Prior Circulars:

  • July 31, 2025: SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111
  • August 29, 2025: SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/121
  • September 25, 2025: SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/131

Impact Assessment

Market-Wide Impact:

This circular affects the entire securities market ecosystem, impacting all regulated entities with investor-facing digital platforms. The clarification provides regulatory relief by extending the compliance timeline while strengthening investor protection through the SCORES integration.

Operational Impact:

  • High Impact on Technology Infrastructure: All REs must audit and potentially upgrade websites, mobile apps, and portals for accessibility compliance
  • Process Changes: Implementation of periodic audit cycles with certified professionals
  • Complaint Management: New category of investor grievances requiring specialized remediation processes
  • Resource Allocation: Entities need to allocate budget and personnel for accessibility improvements and ongoing compliance

Investor Protection:

Positive development for investors with disabilities, providing:

  • Formal recognition of digital accessibility rights in Investor Charters
  • Clear complaint redressal mechanism through SCORES
  • Mandatory remediation obligations on REs
  • Periodic audits ensuring sustained compliance

Compliance Burden:

Moderate to high for REs depending on current state of digital platforms. The extended deadline (March 31, 2026) provides additional time for implementation, but the ongoing periodic audit requirement creates permanent compliance obligations.

Categories of Entities Directly Reporting to SEBI: Alternative Investment Funds, Bankers to an Issue, SCSBs, 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.

Impact Justification

Major compliance clarification affecting all regulated entities with extended deadline and new complaint redressal mechanism. Impacts digital platforms of brokers, depositories, mutual funds, and all market intermediaries serving investors.