SEBI Mandates Digital Accessibility for Persons with Disabilities: A Complete Guide

Introduction: A Milestone in Financial Inclusion

Imagine logging into your trading app, trying to check your investments, only to find the interface almost impossible to navigate because of a visual or physical impairment. Frustrating, right? For millions of persons with disabilities (PwDs) in India, this has long been a reality.

On 31 July 2025, the Securities and Exchange Board of India (SEBI) took a historic step to change this scenario. The regulator mandated that all SEBI-regulated entities ensure their digital platforms are fully accessible to PwDs. This isn’t just a corporate courtesy—it's a legally enforceable requirement, marking a major stride toward inclusive capital markets in India.

From stock exchanges and mutual fund portals to investment advisors and mobile trading apps, all investor-facing digital interfaces now fall under this mandate. SEBI’s move signifies a paradigm shift: digital inclusion is no longer optional; it’s a fundamental right.

In this guide, we will explore the legal framework, technical standards, timelines, and practical steps for compliance, while highlighting what this means for investors, businesses, auditors, and taxpayers.

 

The Legal Foundation: RPwD Act and Supreme Court Judgments

RPwD Act, 2016: Framing the Mandate

The Rights of Persons with Disabilities (RPwD) Act, 2016 forms the statutory backbone of SEBI’s directive. Sections 40, 42, and 46 explicitly require all public-facing services—including digital platforms—to be accessible to PwDs. This includes accessible content, timely accommodations, and removal of digital barriers.

Until now, many private financial intermediaries treated accessibility as a voluntary goal. Government platforms adhered to the Guidelines for Indian Government Websites (GIGW), but private-sector entities lacked enforceable obligations. SEBI’s directive finally operationalizes these rights for capital market participants.

Supreme Court Intervention

The push for enforceable digital accessibility came from two landmark Supreme Court rulings in April 2025:

• Pragya Prasun & Ors. v. Union of India
• Amar Jain v. Union of India

The Court recognized digital access as part of the right to life and personal liberty under Article 21 of the Constitution. It highlighted the challenges faced by visually impaired individuals and those with physical impairments when accessing online financial services, including e-KYC, trading platforms, and investor disclosures.

The verdict instructed regulators to establish clear accessibility standards, laying the groundwork for SEBI’s directive.

 

Why This Mandate Matters

Equal Access to Capital Markets

India’s capital markets are increasingly digital. Trading apps, mutual fund portals, investor dashboards, and online disclosures are central to participation. Yet, PwDs often find these platforms inaccessible. SEBI’s intervention ensures that every investor, regardless of ability, can engage in financial markets independently.

Investor Protection and Fairness

SEBI has always prioritized investor protection. Excluding PwDs from digital services contradicts this mandate. Accessibility is no longer peripheral—it is integral to fair and equitable investor treatment.

Alignment with Global Standards

This move aligns India with international accessibility frameworks, including:

• WCAG 2.1 Level AA
• European Accessibility Act
• Domestic standards: GIGW, IS 17802

Previously, compliance was advisory; now, it is legally binding for all SEBI-regulated entities (REs).

 

Understanding the SEBI Directive

Scope and Applicability

SEBI Circular SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111 applies to all regulated entities:

• Stock exchanges and clearing corporations
• Depositories and depository participants
• Brokers and sub-brokers
• Asset management companies, mutual funds, registrars
• Portfolio managers, investment advisors, research analysts
• KYC registration agencies, merchant bankers, and other intermediaries

The directive covers all investor-facing digital platforms, including:

• Websites and portals
• Mobile applications
• Investor dashboards and online tools
• PDFs, emails, notices, and multimedia content (videos/audio)

 

Technical Standards and Requirements

SEBI mandates adherence to multiple accessibility frameworks:

• WCAG 2.1 Level AA
• GIGW Guidelines
• IS 17802 (India’s ICT accessibility standard)
• Provisions under the RPwD Act and Rules

Key technical features include:

• Alternate text for images
• Tagged PDFs with logical reading order
• Captions or transcripts for multimedia
• Audio descriptions for visual content
• Indian Sign Language (ISL) support where relevant
• Keyboard navigation, high-contrast readability, ARIA attributes
• Accessible forms, error messages, and clear navigation

Tip: Firms can enhance usability by testing platforms with real PwDs rather than relying solely on automated tools.

 

Timelines and Phased Compliance

SEBI provided clear deadlines:

Milestone	Deadline
Submission of digital platform inventory + compliance report	30 Sept 2025
Appointment of IAAP-certified accessibility auditor	14 Dec 2025
Full accessibility audit	30 Apr 2026
Remediation and compliance	31 Jul 2026
Annual accessibility audit & reporting	30 Apr 2027 & yearly thereafter

Reporting lines are structured for clarity: brokers report to exchanges, advisors report to BSE Ltd., and AMCs report directly to SEBI.

 

Governance and Accountability

Each regulated entity must:

• Assign a Managing Director, Partner, or Proprietor accountable for accessibility
• Appoint a Nodal Officer (or delegate to the compliance officer)
• Implement a grievance redressal mechanism accessible to PwDs
• Integrate accessibility principles in staff training, vendor contracts, and procurement policies

This top-down approach ensures accessibility is embedded in organizational culture, not just technical checkboxes.

 

Impact on Stakeholders

Who Benefits

• Persons with Disabilities: Improved access to trading platforms, KYC processes, and investor communications
• Small investors: Direct access to financial intermediaries without relying on third parties
• Regulated entities: Enhanced reputation and goodwill by demonstrating inclusive practices

Who Faces Pressure

• Smaller intermediaries: Financial and technical constraints
• Technology vendors: Rapid skill upgrades needed for accessible solutions
• IAAP-certified auditors: Potential capacity challenges, higher fees

Practical Implications

For Businesses / Regulated Entities

• Budget allocations for audits, remediation, and training
• Procurement of tools and software meeting accessibility standards
• Integration of accessibility in internal governance
• Periodic reporting and audits

For Investors

• Improved usability, independence, and financial participation
• Potential indirect cost impact from intermediary compliance efforts

For Auditors / Assurance Professionals

• Rising demand for certified accessibility audits
• Opportunities to expand into specialized accessibility assurance services
• Collaboration between audit firms and accessibility experts

 

Common Misconceptions

1. “Only public websites are affected” – False. All investor-facing digital interfaces are covered.
2. “Automation is enough” – False. Manual testing with PwDs is mandatory.
3. “Small firms are exempt” – False. All SEBI-regulated entities are included.
4. “Accessibility equals security” – False. Accessibility is distinct from cybersecurity.
5. “One-time compliance is sufficient” – False. Annual audits and continuous reporting are required.

 

Expert Perspectives

Financial and regulatory experts view this mandate as transformative, albeit with execution challenges:

“The circular is progressive. But auditors, developers, and intermediaries must scale rapidly. Otherwise, compliance risks becoming a formality rather than meaningful inclusion.” – Industry Consultant

From a taxation and finance perspective, this initiative opens new avenues for auditors and professionals to provide specialized digital accessibility services, enhancing compliance and investor trust.

 

Actionable Steps for Regulated Entities

1. Catalog digital assets – Create a complete inventory of websites, apps, and tools
2. Appoint a Nodal Officer – Ensure top-level accountability
3. Engage certified auditors early – Reserve slots due to limited availability
4. Conduct audits and remediation – Test platforms with PwDs
5. Embed accessibility in procurement – Include compliance clauses in RFPs and contracts
6. Train staff and vendors – Raise awareness on assistive technologies
7. Set up grievance mechanisms – Provide simple reporting channels for PwDs
8. Implement annual review and reporting – Conduct audits and submit timely reports

Firms should also monitor emerging AI and voice-based technologies, which can enhance accessibility.

 

Conclusion: A Historic Step Toward Inclusive Finance

SEBI’s digital accessibility mandate is more than compliance—it’s a commitment to equitable financial participation. By embedding accessibility into policies, technology, and governance, India can set a global benchmark for integrating disability rights into capital market participation.

For regulated entities, this represents both a responsibility and an opportunity—to enhance reputation, improve usability, and foster trust. For investors, particularly PwDs, it ensures independence, dignity, and fairness in accessing financial markets.

At Manika TaxWise, we advocate for proactive compliance, strategic planning, and awareness of these mandates to protect both businesses and investors in a rapidly evolving financial ecosystem.

 

FAQs

Q1. Does this mandate cover banks or NBFCs?
No. Only SEBI-regulated entities are included. Other regulators may issue separate directives.

Q2. What if IAAP-certified auditors are unavailable?
Engage auditors early, collaborate with peers, or seek SEBI guidance. Interim flexibility may be allowed, but non-compliance carries risks.

Q3. Are automated accessibility tools enough?
No. Real-world usability testing with PwDs is mandatory.

Q4. Will SEBI impose penalties for non-compliance?
Yes. Penalties under the SEBI Act include notices and operational restrictions for repeated violations.

Q5. Are there tax implications?
No direct taxes apply. Costs for audits, remediation, and development are treated as business expenses.

 

References

• SEBI Compliance Guidelines on Digital Accessibility
• TaxGuru: SEBI Circular Analysis
• BarrierBreak: Accessibility in Indian Financial Markets
• Moneycontrol: Industry Perspectives
• Leglobal: Scope of SEBI Circular
• Deque Blog: Technical Accessibility Standards
• Business Today: SEBI Directive Coverage
• Taxmann: Timeline Extensions
• King Stubb & Kasiva: Legal Insight