SEBI Mandates Accessibility Readiness Reporting for Digital Platforms

CIRCULAR HO/13/19/13(2)2025-ITD-1_VIAP/I/187/2025; Dated: 08.12.2025

1. Background

SEBI has issued a clarification on its earlier circular relating to digital accessibility compliance by all regulated entities (REs). The clarification addresses queries raised by intermediaries and market infrastructure institutions and outlines a more practical, phased approach to readiness assessment and reporting.

Digital accessibility norms are intended to ensure that investors—especially those with disabilities—can access, navigate, and use digital platforms and investor-facing systems without barriers.

2. Investor’s Right to Digital Accessibility

SEBI has mandated that “Investor’s Right to Digital Accessibility” be integrated as a component of all Investor Charters issued by regulated entities.

This requirement:

• Recognises digital accessibility as a core investor protection right
• Reinforces SEBI’s commitment to inclusive access across securities market platforms
• Ensures that investors are aware of their entitlement to accessible digital services and grievance escalation avenues

3. Revised Compliance Timelines

Instead of appointing an auditor by December 14, 2025, REs are now required to:

• Submit the readiness and compliance status of each digital platform by March 31, 2026
• Use the standardised format prescribed by SEBI for platform-level reporting

This revision provides regulated entities with additional time to evaluate current accessibility gaps, upgrade systems, and prepare structured compliance information.

4. Digital Platform Coverage

The reporting requirement applies to:

• Mobile applications
• Web portals and investor interfaces
• Onboarding platforms
• Transaction, account management, or market access platforms
• Any digital touchpoint used by investors or clients

Each digital platform must be evaluated separately for its accessibility status.

5. Grievance Redressal Via SCORES

Regulated entities must:

• Track, acknowledge, and resolve accessibility-related complaints through the SCORES grievance redressal system
• Ensure that accessibility concerns receive the same priority and complaint closure requirements as other investor grievances

This ensures standardised grievance transparency and supervisory monitoring.

6. Audit and Assurance Requirements

Although the immediate auditor appointment requirement has been deferred, SEBI has clarified that:

• REs must conduct regular accessibility audits
• Audits must be performed by qualified and certified accessibility professionals
• Audit outcomes must be used for ongoing remediation and platform enhancement

The expectation is for periodic technical review, using recognised accessibility standards (e.g., WCAG), rather than ad hoc or one-time assessment.

7. Compliance Intent

SEBI’s regulatory intent behind the clarification is to:

• Promote digital inclusion and accessibility equity
• Provide REs with practical and phased compliance timelines
• Ensure structured self-assessment and reporting rather than compliance only via auditor certification
• Embed accessibility into core consumer protection and market transparency frameworks

8. Key Compliance Actions for REs

Regulated entities should now:

• Map all digital platforms and assess current accessibility readiness
• Use the prescribed SEBI format for reporting readiness by March 31, 2026
• Ensure integration of accessibility rights into Investor Charters
• Strengthen internal SOPs, product design, technology standards, and remediation timelines
• Put formal mechanisms in place to handle accessibility complaints through SCORES
• Schedule periodic audits with certified accessibility professionals

Failure to comply may invite regulatory review, investor complaints, supervisory measures, or digital platform usage restrictions.

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