Description

SEBI issues clarifications on digital accessibility requirements for regulated entities, extending compliance deadlines and introducing accessibility complaint mechanism on SCORES.

Summary

SEBI has issued clarifications on digital accessibility requirements for all regulated entities (REs) operating digital platforms. The circular extends the compliance deadline for accessibility auditor appointment, introduces a new reporting framework, and establishes an accessibility complaint mechanism on SCORES. The “Investors’ Right to have digital accessibility” will be included in respective Investor Charters.

Key Points

  • Investors’ right to digital accessibility will be included in respective Investor Charters published by SEBI
  • Compliance deadline extended from December 14, 2025 to March 31, 2026 for submitting readiness status
  • New accessibility complaint category available on SCORES for investors
  • REs must conduct periodic accessibility audits through certified accessibility professionals
  • Different reporting authorities designated based on RE category (Stock Exchanges/Depositories, BSE Ltd., or SEBI directly)

Regulatory Changes

Modified Compliance Timeline:

  • Previous requirement: Appoint accessibility auditor by December 14, 2025
  • New requirement: Submit status of readiness and compliance for each digital platform by March 31, 2026

New Complaint Mechanism:

  • Accessibility-related complaints can now be lodged on SCORES under “Accessibility” category
  • REs must remediate accessibility issues for complaint closure

Updated Investor Rights:

  • Digital accessibility rights to be formally included in Investor Charters for all regulated entities

Compliance Requirements

For All Regulated Entities:

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

    • Submit readiness and compliance status for each digital platform
    • Submit to specified reporting authorities (see reporting structure below)
    • REs reporting to SEBI: email to digital_acc@sebi.gov.in
    • Use format provided in Annexure B

  2. Accessibility Audits:

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

  3. Complaint Resolution:

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

Reporting Structure:

  • Stock Brokers/Depository Participants: Report to Stock Exchanges/Depositories
  • Investment Advisors and Research Analysts: Report to BSE Ltd.
  • 15 Categories of REs report directly to SEBI: AIFs, Bankers to Issue, SCSBs, Clearing Corporations, CIS, Credit Rating Agencies, Custodians, Debenture Trustees, Depositories, KRAs, Merchant Bankers, Mutual Funds/AMCs, Portfolio Managers, RTAs, Stock Exchanges, Venture Capital Funds

Important Dates

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

Impact Assessment

Affected Entities:

  • All SEBI-regulated entities operating investor-facing digital platforms
  • Stock brokers, depositories, mutual funds, portfolio managers, investment advisors, research analysts, and 15+ other RE categories

Operational Impact:

  • High: All REs must assess and report digital platform accessibility compliance
  • REs need to establish processes for periodic accessibility audits
  • New complaint handling workflow for accessibility issues on SCORES
  • Resource allocation required for certified accessibility professionals

Investor Benefits:

  • Enhanced accessibility rights formally recognized in Investor Charters
  • Structured complaint mechanism for accessibility issues
  • Improved digital platform accessibility for investors with disabilities

Timeline Relief:

  • Extended deadline provides additional 3.5 months for compliance preparation
  • Shift from auditor appointment to readiness status submission offers more flexibility

Reference 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 Justification

Affects all regulated entities with digital platforms, extends critical compliance deadline from December 2025 to March 2026, introduces new investor complaint mechanism for accessibility issues