Description

SEBI clarifies digital accessibility compliance requirements for regulated entities, extending the accessibility auditor appointment deadline and introducing a phased compliance approach with reporting by March 31, 2026.

Summary

SEBI has issued clarifications on its earlier circulars regarding digital accessibility requirements for Regulated Entities (REs). The circular provides relief by modifying the compliance timeline and introduces a phased approach. Instead of appointing accessibility auditors by December 14, 2025, REs must submit a status report of their readiness and compliance by March 31, 2026. The circular also integrates investors’ right to digital accessibility into Investor Charters and enables accessibility-related complaints through SCORES platform.

Key Points

  • Investors’ Right to Digital Accessibility will be included in respective Investor Charters applicable to various REs
  • Extended deadline: REs must submit status of readiness and compliance by March 31, 2026 (instead of appointing accessibility auditor by December 14, 2025)
  • REs reporting to SEBI shall share status via email at digital_acc@sebi.gov.in
  • Investors can lodge accessibility-related complaints against REs on SCORES under “Accessibility” complaint category
  • REs must remediate accessibility issues for complaint closure
  • All REs must conduct periodic accessibility audits through certified accessibility professionals
  • Applies to all investor-facing digital platforms including websites, mobile apps, and portals

Regulatory Changes

Reference Circulars Modified:

  • 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 Regulatory Updates:

  • Integration of digital accessibility rights into Investor Charters
  • Establishment of SCORES complaint category for accessibility issues
  • Modified compliance timeline providing more time for REs to achieve readiness
  • Mandatory periodic accessibility audits by certified professionals

Compliance Requirements

For All Regulated Entities:

  1. Status Reporting (by March 31, 2026):

    • Submit status of readiness and compliance for each digital platform
    • Report to specified authorities based on entity type (see reporting structure below)
    • Use prescribed format (Annexure B) for submission

  2. Accessibility Complaint Handling:

    • Monitor and respond to accessibility complaints on SCORES
    • Remediate accessibility issues for complaint closure

  3. Periodic Accessibility Audits:

    • Conduct regular accessibility audits of all digital platforms
    • Use certified accessibility professionals for audits
    • Cover websites, mobile apps, and portals

Reporting Structure:

  • Stock Brokers/Depository Participants: Report to Stock Exchanges/Depositories
  • Investment Advisors and Research Analysts: Report to BSE Ltd.
  • Market Infrastructure Institutions and other REs: Report to SEBI

Entities Reporting Directly to SEBI (15 categories): 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, Registrars and Share Transfer Agents, Stock Exchanges, Venture Capital Funds

Important Dates

  • December 14, 2025: Original deadline for appointment of accessibility auditor (now modified)
  • March 31, 2026: New deadline for submitting status of readiness and compliance to accessibility requirements
  • December 8, 2025: Circular issue date

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 other intermediaries. The extension provides necessary breathing room for entities to achieve compliance with digital accessibility standards.

Operational Impact:

  • Relief for REs: The extended timeline (from December 14, 2025 to March 31, 2026) provides additional time for entities to assess and report their digital accessibility readiness
  • Investor Protection: Integration with SCORES enables systematic tracking and resolution of accessibility complaints
  • Compliance Burden: REs must establish processes for periodic accessibility audits and complaint remediation
  • Technology Requirements: All investor-facing digital platforms must be evaluated and upgraded to meet accessibility standards

Social Impact: Strengthens financial inclusion by ensuring persons with disabilities have equal access to securities market platforms and services, aligning with the Rights of Persons with Disabilities Act, 2016.

Legal Authority: Issued under Section 11(1) of the Securities and Exchange Board of India Act, 1992, to protect investor interests and regulate securities markets.

Impact Justification

Affects all regulated entities including stock brokers, depositories, mutual funds, and other intermediaries. Introduces mandatory digital accessibility compliance with investor complaint mechanism through SCORES. Provides relief by extending deadline from December 14, 2025 to March 31, 2026 for reporting.