On 8 December 2025, the Securities and Exchange Board of India (SEBI) released a critical clarification titled “Clarification on the Digital Accessibility Circulars of SEBI.” The circular provides clear direction for all Regulated Entities (REs) on how to meet digital accessibility requirements aligned with the Rights of Persons with Disabilities (RPwD) Act, 2016, and global accessibility standards such as WCAG 2.1/2.2 AA.
This clarification removes ambiguity, introduces a phased compliance process, and elevates digital accessibility to the status of an investor righ,t which can be considered a landmark moment for Accessibility Compliance in India.
Why SEBI Issued the New Digital Accessibility Circular
In 2025, SEBI released three foundational circulars in July, August, and September mandating accessibility across all investor-facing digital platforms. However, questions arose around deadlines, reporting workflows, and implementation expectations.
The December 2025 clarification circular resolves those issues and defines a clear compliance roadmap for REs.
SEBI Recognizes Digital Accessibility as an Investor Right under the RPwD Act
The circular makes a historic statement:
“Investors’ Right to have digital accessibility” will be included in the Investor Charters of all Regulated Entities.”
This is the first time a financial regulator in India has explicitly defined digital accessibility as a formal investor protection right.
It aligns with the RPwD Act, which requires all service providers to offer accessible digital experiences for persons with disabilities. By integrating accessibility into Investor Charters, SEBI signals that accessibility is not a technical add-on; it is a fundamental requirement for fair, equitable participation in India’s financial markets.
Updated SEBI Compliance Requirements
SEBI has removed the earlier requirement to appoint a certified accessibility auditor by 14 December 2025. Instead, it has introduced a more practical requirement:
“All REs must submit a Digital Accessibility Readiness & Compliance Status Report by 31 March 2026.”
This report must cover every investor-facing digital platform, including:
- Public websites
- Mobile apps (iOS and Android)
- Trading platforms and interfaces
- Digital onboarding systems
- Investment and portfolio portals
- Any platform used by investors for transactions, support, or information
Annexure B Reporting Format: What REs Must Include
Each RE must provide:
- URL of every platform
- Whether it meets WCAG 2.1/2.2 AA minimum accessibility compliance
- Remarks on accessibility gaps, timelines, and current readiness
This structured template enables SEBI to assess industry-wide accessibility maturity.
New “Accessibility” Complaint Category in SCORES
SEBI has added a dedicated “Accessibility” category on the SCORES grievance portal. Investors can now raise complaints if they:
- Cannot access a website or mobile app
- Face barriers using digital services
- Encounter non-WCAG compliant elements
- Experience inaccessible forms, charts, or documents
REs must fix the accessibility issue to close the complaint. This makes accessibility enforceable, not optional.
SEBI Reporting Requirements Explained: Who Reports to Whom (Annexure A)
SEBI has removed confusion about escalation and reporting through Annexure A.
Key Examples:
- Stock Brokers & Depository Participants: Report to Stock Exchanges/Depositories
- Investment Advisers (IAs) & Research Analysts (RAs): Report to BSE Ltd.
- AMCs, Mutual Funds, RTAs, KRAs, Custodians, Merchant Bankers: Report directly to SEBI
- Market Infrastructure Institutions (MIIs): Report to SEBI
These mappings ensure auditability and reduce compliance errors.
Periodic Accessibility Audits Required by SEBI
While the immediate deadline for auditor appointment is removed, SEBI has retained the requirement that:
“All REs must conduct periodic accessibility audits through certified accessibility professionals.”
This aligns with the RPwD Act and global standards like WCAG 2.1/2.2, emphasizing that accessibility is not a one-time exercise but a continuous improvement process.
How REs Can Achieve Digital Accessibility Compliance in India Before the Deadline
To comply with SEBI’s 2025-2026 accessibility guidelines, REs should adopt a structured and proactive approach.
1. Conduct a Baseline Accessibility Audit
Evaluate websites, apps, and digital workflows against WCAG 2.1/2.2 AA by conducting periodic accessibility audits.
2. Map All Digital Assets for Annexure B
Include every platform where investors:
- Register
- Transact
- Request support
- View portfolios
- Receive communications
3. Build a Remediation Roadmap
Prioritize:
- Critical user journeys
- High-impact accessibility issues
- Barriers that may trigger SCORES complaints
4. Implement Accessibility Governance
Create an internal structure to manage standards, tooling, testing, and approvals.
5. Engage Certified Accessibility Experts
This ensures accurate, credible audit results and reduces compliance risk. At Pivotal Accessibility, we are a DEPwD Empanelled organization with a team of IAAP-certified professionals geared towards helping organizations achieve and maintain accessibility compliance.
6. Train Product, UI/UX, and Engineering Teams
Accessibility must be built into processes, not retrofitted.
7. Monitor User Feedback
Accessibility complaints from investors are an opportunity to improve compliance.
Why SEBI’s Digital Accessibility Mandate Is a Landmark for Inclusive Finance in India
This circular is among India’s most important regulatory updates for digital inclusion. It signals:
- Strong alignment with the RPwD Act, 2016
- Integration of global WCAG standards into Indian financial regulation
- Increased accountability for accessibility failures
- Recognition of persons with disabilities as equal investors
- Movement toward a more inclusive financial ecosystem
SEBI has now positioned accessibility as an essential part of investor protection, alongside privacy, security, and transparency.
How to move forward?
The December 2025 SEBI clarification circular establishes a clear, enforceable pathway for digital accessibility compliance in India’s financial sector.
With the 31 March 2026 deadline for readiness reporting and the mandate for ongoing audits, REs must adopt accessibility as a strategic priority.
Early movers will benefit from:
- Reduced compliance risk
- Higher investor trust
- Improved user experience
- Broader market reach, including India’s 70+ million persons with disabilities
Accessibility is now integral to India’s financial innovation story, and SEBI has made it clear that the future of digital finance must be inclusive, accessible, and equitable.
If your organisation needs support in meeting SEBI’s new digital accessibility requirements, Pivotal Accessibility can guide you from assessment to full compliance. Our certified accessibility experts help you audit, remediate, and prepare Annexure B reporting with accuracy and confidence.
Speak to our team today and make your digital platforms accessible and compliant.