Description

SEBI issues clarifications on digital accessibility compliance requirements, extending the deadline for readiness reporting to March 31, 2026, and introducing accessibility complaint provisions on SCORES.

Summary

SEBI has issued clarifications on the digital accessibility requirements for Regulated Entities (REs) previously outlined in three circulars dated July 31, August 29, and September 25, 2025. The circular extends the compliance deadline for accessibility auditor appointment, requiring REs to submit readiness status by March 31, 2026. Investors’ right to digital accessibility will be incorporated into respective Investor Charters. REs must conduct periodic accessibility audits and investors can lodge accessibility-related complaints on SCORES platform.

Key Points

  • Investors’ Right to Digital Accessibility will be included in Investor Charters applicable to various REs
  • Deadline for submitting readiness and compliance status extended to March 31, 2026 (replacing December 14, 2025 deadline)
  • Status reports to be submitted for each digital platform to specified reporting authorities
  • REs reporting to SEBI directly shall use email: digital_acc@sebi.gov.in
  • Accessibility complaint category now available on SCORES platform
  • REs must remediate accessibility issues for complaint closure
  • Periodic accessibility audits mandatory through certified accessibility professionals
  • Different reporting authorities for different categories of REs (Stock Exchanges/Depositories, BSE Ltd., or SEBI)

Regulatory Changes

Modified Compliance Timeline:

  • Original requirement for accessibility auditor appointment by December 14, 2025 has been replaced
  • New requirement: Submit readiness and compliance status by March 31, 2026

Investor Charter Update:

  • “Investors’ Right to have digital accessibility” to be added to respective Investor Charters published by SEBI

Complaint Mechanism:

  • “Accessibility” complaint category provisioned in SCORES platform
  • Investors can lodge accessibility-related complaints against REs
  • REs must remediate issues for complaint closure

Audit Requirements:

  • Mandatory periodic accessibility audits of digital platforms (websites, mobile apps, portals)
  • Audits must be conducted through certified accessibility professionals

Compliance Requirements

For All Regulated Entities:

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

    • Submit status of readiness and compliance to accessibility requirements
    • Separate submission required for each digital platform
    • Submit to specified reporting authority based on RE category
    • Use prescribed format in Annexure B

  2. Reporting Channels:

    • Stock Brokers/Depository Participants → Stock Exchanges/Depositories
    • Investment Advisors and Research Analysts → BSE Ltd.
    • MIIs and other REs → SEBI directly at digital_acc@sebi.gov.in

  3. Accessibility Audits:

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

  4. Complaint Handling:

    • Monitor accessibility complaints on SCORES
    • Remediate accessibility issues promptly
    • Close complaints after issue resolution

REs Reporting Directly to SEBI: Alternative Investment Funds, Bankers to an Issue, Self Certified Syndicate Banks, 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

Important Dates

  • December 08, 2025: Circular issued
  • March 31, 2026: Deadline for REs to submit readiness and compliance status for digital accessibility requirements
  • Ongoing: Accessibility complaint category active on SCORES platform
  • Ongoing: Periodic accessibility audits required

Referenced 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)

Impact Assessment

Industry-Wide Impact: This circular affects all categories of regulated entities in the securities market ecosystem. The digital accessibility mandate represents a significant shift toward inclusive investing, ensuring persons with disabilities have equal access to financial markets.

Operational Impact:

  • REs must assess all digital touchpoints (websites, mobile apps, portals) for accessibility compliance
  • Investment required in certified accessibility professionals for audits
  • Potential need for technology upgrades and platform modifications
  • Enhanced complaint handling processes for accessibility issues
  • Documentation and reporting burden for compliance status

Compliance Benefits:

  • Extended deadline (March 31, 2026) provides reasonable time for assessment and planning
  • Clear reporting structure reduces ambiguity
  • Phased approach allows REs to prioritize critical platforms

Investor Protection:

  • Strengthens rights of investors with disabilities
  • Formal complaint mechanism through SCORES ensures accountability
  • Mandatory remediation links compliance to investor grievance redressal
  • Periodic audits ensure sustained compliance

Market Development:

  • Expands market accessibility to underserved investor segments
  • Aligns Indian securities market with global accessibility standards
  • Promotes inclusive growth and financial inclusion

Risk Considerations:

  • Non-compliance may result in regulatory action
  • Accessibility complaints could affect RE reputation
  • Implementation costs for platform modifications
  • Need for ongoing monitoring and periodic audits

Impact Justification

Affects all regulated entities including stock exchanges, brokers, depositories, mutual funds, and intermediaries. Introduces significant compliance obligations for digital platform accessibility with new reporting and audit requirements.