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Introduction
In a landmark move effective from 31 July 2025, the Securities and Exchange Board of India (SEBI) has mandated that all SEBI-regulated entities must ensure their digital platforms are accessible to persons with disabilities. This directive stems from a Supreme Court ruling that recognised digital access as part of fundamental rights, compelling SEBI to operationalise inclusion in the securities market. The move affects stock exchanges, brokers, mutual funds, investment advisors, and other intermediaries, instituting clear timelines, audit obligations, and reporting mandates.
Background and Context
The legal foundation: RPwD Act and the
Supreme Court judgment
The Rights
of Persons with Disabilities (RPwD) Act, 2016 requires that information and communication technology (ICT)
platforms be accessible to persons with disabilities (PwDs). SEBI’s move aligns
with Sections 40, 42 and 46 of the RPwD Act, which mandate accessibility of
services, timely accommodation, and access to ICT.
In April 2025, two key Supreme Court decisions—Pragya Prasun & Ors. v. Union of India
and Amar Jain v. Union of India—held
that digital access is a component of the
right to life and personal liberty under Article 21. The Court
specifically addressed disadvantages faced by visually impaired persons or
those with disfigurement in e-KYC and digital services, directing governmental
and regulatory agencies to institute standards.
Why this matters
·
Inclusion
in capital markets: Many digital services (trading apps, investor
portals, disclosures) remain inaccessible to PwDs, effectively excluding them
from equal participation in financial markets.
·
Investor
protection & equality: SEBI is tasked with protecting investor
interests; excluding PwDs from seamless access would run contrary to equitable
treatment objectives.
·
Global
& national convergence: The mandate brings India in line with
global best practices (e.g. WCAG 2.1, European Accessibility Act) and domestic
standards (GIGW, IS 17802).
·
Operational
clarity for industry: Prior to this, accessibility obligations
remained largely voluntary or advisory. The SEBI circular provides enforcement
teeth.
Before this, several sectors (especially government websites) were required to follow Guidelines for Indian Government Websites (GIGW) and other accessibility norms; but financial intermediaries had no clear enforceable deadline. SEBI’s step marks the first time accessibility is made a mandatory compliance parameter in securities law.
Detailed Explanation of the SEBI Mandate
Scope & applicability
SEBI’s Circular
No. SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111, issued on 31 July 2025,
applies to all Regulated Entities (REs)
under SEBI’s purview. These include but are not limited to:
·
Recognised stock exchanges and clearing
corporations
·
Depositories
·
Brokers, sub-brokers, depository participants
·
Asset management companies (AMCs), mutual funds,
registrars
·
Portfolio managers, investment advisors,
research analysts
·
KYC registration agencies, merchant bankers,
intermediary entities
The scope extends to all investor-facing digital platforms, such as:
·
Websites and web portals
·
Mobile applications
·
Investor dashboards
·
Digital communications (PDFs, emails,
disclosures, notices)
·
Multimedia content (videos, audio)
Standards & technical requirements
SEBI mandates adherence to:
1.
WCAG 2.1 (or
latest version) Level AA or above (Web Content Accessibility
Guidelines by W3C)
2.
GIGW (Guidelines
for Indian Government Websites)
3.
IS 17802
(Indian Standard for accessibility in ICT products and services)
4.
Provisions under the RPwD Act and its Rules (Rule 15(1)(c), etc.)
Some of the technical features required are:
·
Alternate
text for images
·
Tagged
PDFs, logical reading order, semantic markup
·
Captioning
/ transcripts for audio/video
·
Descriptive
audio / narration for visual content
·
Indian
Sign Language (ISL) support where applicable
·
Keyboard navigability, contrast and readability,
ARIA attributes, and compatibility with assistive technologies
·
Accessible forms, error messages, and clear
navigation flows
Timelines & phased compliance
SEBI issued a follow-up circular SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/121 on
29 August 2025, which revised or clarified timelines for certain categories
such as Investment Advisors and Research Analysts.
Under the compliance guidelines (Circular No.
SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/131, dated 25 September 2025), the following
schedules are set:
|
Milestone |
Deadline |
|
Submission of list of digital platforms + compliance
report |
30 September 2025 |
|
Appointment of IAAP-certified accessibility auditor |
14 December 2025 |
|
Conduct full accessibility audit |
30 April 2026 |
|
Remediation & compliance of audit findings |
31 July 2026 |
|
Annual accessibility audit & reporting |
30 April 2027 (and 30 days post each subsequent FY) |
Reporting lines:
·
Brokers / Depository Participants report to
exchanges / depositories
·
Investment Advisors / Research Analysts report
to BSE Ltd.
·
Market Infrastructure Institutions (MIIs), AMCs,
and other REs report directly to SEBI via a prescribed format and email channel
Governance, accountability & redressal
SEBI places responsibility at the highest
level:
·
The Managing
Director / Managing Partner / Proprietor of an RE must ensure
compliance.
·
A Nodal
Officer must be designated (or in absence, compliance officer assumes
role) to oversee accessibility tasks.
·
A grievance
redressal mechanism must be established, easily accessible to PwDs,
with escalation paths.
· Entities must ensure training, awareness and embed “accessible by design” principles in procurement, vendor contracts, and development processes.
Impact Analysis
Beneficiaries & those under pressure
Beneficiaries
·
Persons with disabilities: will gain equitable
access to trading, disclosures, KYC, statements, investor communications.
·
Small investors: can interact directly across
intermediaries without needing special effort or third-party mediation.
·
Trust & reputation: regulated entities that
implement well may build goodwill and brand value for social responsibility.
Under
pressure
·
Smaller intermediaries and advisory firms face
resource, cost, and technical challenges.
·
Technology vendors/solution providers need rapid
upskilling to deliver accessible digital solutions.
·
Auditors certified under IAAP could see capacity
crunch, possibly high fees due to limited supply.
Practical implications
For
Businesses / Regulated Entities
·
Budgeting & resourcing: costs for audits,
remediation, re-development, staff training, vendor contracts.
·
Procurement: all new digital tools and SaaS must
be accessibility-compliant.
·
Governance: ensure accountability, embed
accessibility into policy, processes, quality checks.
·
Reporting burden: periodic audits and
submissions.
For
Taxpayers / Investors
·
Investors with disabilities will have better
usability and independence.
·
No direct tax impact, but cost burdens on
intermediaries may partly translate into service charges or pricing pressure.
For
Auditors / CAs / Assurance Professionals
·
Demand for certified accessibility auditors will
rise.
·
CAs or auditors with digital/tech expertise may
expand service lines into accessibility assurance.
·
Third-party firms may need collaboration with
accessibility professionals (designers, engineers).
Risks & challenges
·
Scarce
IAAP-certified auditors: Some smaller advisers have flagged auditor
scarcity and high cost estimates.
·
Technical
gaps: Legacy systems, older platforms, or vendors may resist large
refactoring.
·
Enforcement
& follow-up: How rigorously SEBI enforces penalties or compliance
in practice remains a question.
· Uniform interpretation: Discrepancies in how WCAG or IS 17802 interpret in context of financial portals may arise.
Common Misunderstandings
·
Some believe only public websites are affected — no: investor
portals, apps, digital communications also fall under mandate.
·
Assumption that automatic tools alone suffice — on the contrary, manual
and usability testing (esp. with PwDs) is required.
·
That smaller
firms are exempt — all SEBI-regulated intermediaries are covered,
though timelines may differ.
·
Confusing accessibility
with security or privacy requirements — while linked, accessibility is
a distinct compliance axis.
· Thinking one-time compliance is enough — SEBI mandates annual audits and ongoing reporting.
Expert Commentary
From my two decades in finance and taxation,
this regulation is a watershed. While the intent is laudable and overdue, the
real challenge lies in execution. Smaller intermediaries might struggle with
the technical and fiscal burden; a phased or capacity-building support from
SEBI or industry bodies would be helpful. Over time, though, the move can set a
new benchmark — financial inclusion is incomplete without digital inclusion.
As one industry consultant puts it:
“The circular is progressive, but the ecosystem (auditors, developers) must scale swiftly; otherwise, compliance will become pro forma, not substantive.”
Conclusion & Action Steps
SEBI’s mandate is a seminal turn for India’s
financial sector: digital accessibility is no longer optional but a regulated
necessity. The industry now must shift from advisory compliance to structural
transformation.
Key
takeaways & next steps for entities:
1.
Prepare
inventory: Catalogue all digital assets (websites, apps, investor
tools).
2.
Appoint nodal
officer: Ensure top-level accountability and oversight.
3.
Engage
certified auditors early: Given limited availability, secure funding
and contracts early.
4.
Conduct audits
& remediation: Use inclusive testing with PwDs, adopt WCAG / IS
17802 standards.
5.
Embed
accessibility in procurement: All future digital tools, RFPs, vendor
agreements must include accessibility compliance clauses.
6.
Train staff
& vendors: Sensitize teams about assistive technologies,
accessible UI/UX, and inclusive communication.
7.
Set up
grievance redressal mechanism: Provide easy channels for PwDs to log
issues and get resolution.
8.
Annual review
& reporting: Conduct periodic audits and file timely compliance
reports as per SEBI’s schedule.
Going forward, expect further
clarifications, industry bodies issuing best practices, and possibly central
government or SEBI offering templates or audit accreditation programs. The pace
of technology (AI, voice UI, generative interfaces) may also play into how
accessibility evolves in securities markets.
In sum: this is not just a regulatory compliance step — it is a structural shift bridging financial markets and disability rights, reinforcing that inclusive access must be intrinsic, not afterthought.
FAQs
Q1.
Does this mandate apply to non-SEBI regulated firms like NBFCs or banks?
No. This SEBI circular applies only to SEBI-regulated
entities / intermediaries under its jurisdiction (exchanges, brokers,
funds, advisors). Other regulators may issue their own mandates.
Q2.
What if a firm cannot find an IAAP-certified auditor?
That is a real challenge, especially for smaller players. Firms should
proactively engage auditors early, even reserve slots or consortium with peer
firms. SEBI may provide flexibility in interim, but non-compliance is risky.
Q3.
Can automated accessibility scanning tools suffice?
No. While automated scans catch many issues, manual testing and usability testing with PwDs are
mandatory to ensure real-world accessibility. The rules demand depth beyond
automation.
Q4.
Will SEBI impose penalties for non-compliance?
While the circular itself focuses on timelines and reporting, SEBI has
enforcement powers under the SEBI Act (e.g. under Section 11). Repeated
non-compliance may invite regulatory action, show cause notices or
restrictions.
Q5.
Does this impose additional tax on firms?
Not directly. There is no specific tax on accessibility compliance. However,
firms may incur capital or operating
expenditure for remediations, audits, development, training, which
would be allowed under normal business expense deductions.
References
/ Source Links
1.
SEBI compliance guidelines on digital accessibility
circular (SEBI)
2.
TaxGuru on SEBI compliance guidelines and timelines
3.
BarrierBreak commentary on SEBI’s mandate
4.
Moneycontrol report on small advisers’ concerns
5.
Leglobal on SEBI’s circular and scope
6.
Deque blog on SEBI’s new standard
7.
Business Today coverage of SEBI directive
8.
Taxmann note on timeline extension
9.
King Stubb & Kasiva legal insight
10. Legality Simplified overview