SEBI mandates digital accessibility compliance for all regulated entities

Introduction

On 31.07.2025, SEBI issued SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111, whereby SEBI is instructing all SEBI-regulated entities to ensure that complete digital accessibility exists for disabled persons across all platforms in adherence to the Rights of Persons with Disabilities Act, 2016 (“RPwD”), and the rules framed thereunder. This is consequent to the Supreme Court landmark judgment dated 30.04.2025 in Pragya Prasun & Ors. v. Union of India (W.P.(C) 289/2024) and Amar Jain v. Union of India & Ors. (W.P.(C) 49/2025), which, inter alia, declared the right to digital access as an inalienable facet of the right to life and personal liberty and issued binding directions to make accessible the digital KYC and other public-facing systems. SEBI’s circular gives an operational shape to these constitutional and statutory imperatives relating to the securities market by laying down standards, institutional responsibilities, audit and remediation timelines, and reporting requirements on an ongoing basis for all market infrastructure institutions and intermediaries.

The circular is issued under Section 11(1) of the SEBI Act, 1992, for protecting investors’ interests and developing the market and regulating the securities market so that non-disability rights are on par with the main regulatory objectives of market integrity and equal access.

Law and Amendments

The circular by SEBI lays down a structured compliance framework involving governance, process design, audits, remediation, and reporting, with clear timelines and accountability at senior leadership levels. Within 1 month of issuance, REs should create an inventory of all investor-facing digital platforms (websites, apps, portals) and submit a report showing compliance/action taken in regard to the clauses of the circular-giving visibility to the digital estate and first-level implementation efforts. Each RE must appoint an IAAP-certified accessibility professional within 45 days who must conduct an independent, qualified assessment against WCAG, GIGW, IS 17802, and RPwD standards, as well as possess the capability to conduct usability testing with actual participants who have disabilities. REs are to comprehensively audit all digital platforms within 3 months following the issuance of the circular, which includes engaging people with disabilities to document usability gaps to be systematically remediated, moving from automated scanning to the assessment through lived experience. 

Audit remediation must be completed by REs within 6 months of circular issuance as per the circular’s stipulations. Governance rules specify that the circular on compliance must be endorsed by the Managing Director/Managing Partner/Proprietor and that a senior Nodal Officer for digital accessibility must be appointed to provide single point accountability. In the absence of such a formal designation, the Compliance Officer or the Proprietor shall be treated as the Nodal Officer for this circular. If a Nodal Officer is not formally designated, the Compliance Officer or the Proprietor shall be deemed to be the Nodal Officer for ensuring compliance. As for content and communication, circulars, notices, statements, and investor documents must be made available in accessible formats: tagged PDFs with logical reading order, headings, alternate text, and conformance to WCAG PDF techniques, along with multimedia support, such as ISL, closed captions, and descriptive audio where applicable. Client lifecycle processes ought then to have their digital KYC/e-KYC/video KYC provide accessible alternatives-human-assisted video KYC, scanned document uploads, voice-assisted KYC-and have disability-status fields as mandatory so as to trigger targeted support such as callbacks from the helpdesk.

The fundamentals lie in denying any client with disability an application of rejection unless a nominated human officer prefers the override of automated rejections to ensure equity in access. Training and awareness constitute another pillar of compliance–REs must commit to embedding accessibility into the training conducted for their staff and third-party developers while focusing on “accessible by design”, on-the-job application of assistive technologies, and the behavioural best practices in day-to-day content and UX workflows. Regarding procurement and technology, all newly developed or procured digital solutions, be it SaaS or customised SaaS, should comply with provisions of WCAG, IS 17802, GIGW, and RPwD. Accessibility requirements and evaluation weightage for accessibility readiness must be explicitly mentioned in RFPs and contracts, with the responsibility of platform accessibility resting with the RE and not the vendor.

The circular mandates that compliance reporting will be entity-specific: stock brokers and depository participants to stock exchanges/depositories; investment advisers to BASL; MIIs and other REs to SEBI, while annual reporting must be undertaken within 30 days post financial year-end, following this mapping. Based on the circular’s relative timelines from 31.07.2025, indicative planning dates would fall around late August 2025 (1‑month milestone), mid‑September 2025 (45‑day milestone), late October 2025 (3‑month milestone), and late January 2026 (6‑month milestone). These are planning estimates only. SEBI’s circular specifies only relative timelines, not fixed calendar dates.

Conclusions

SEBI Statement as a Regulation from 31.07.2025: This was the first circular in India, advancing towards inclusion of disability rights within financial market regulation, operationalising what Justice DY Chandrachud meant when he said that “access to the digital space is an important facet of Article 21.” The framework calls for compliance with WCAG 2.1 (or latest), GIGW, and the enforceable standard of IS 17802, thereby setting a high but unambiguous level of perceivability to robustness that allows operability with assistive technologies, a multilingual content approach, and media to be made inclusive. The design of the circular embodies best-practice regulatory engineering: leadership responsibility, a designated Nodal Officer, grievance channels specific to accessibility, certified independent audits with lived-experience testing, controls on procurements, and yearly attestation together, moving accessibility from ad hoc patches to a lifecycle governance requirement.

Most importantly, the e-KYC and onboarding guidelines, alternative accessible pathways, human override of automated declines, disability-status capture with proactive facilitations, solve the very pain points that the Supreme Court had recognised and bridge the loop between legal entitlements and ground-level market access for the visually impaired, acid attack survivors, and other individuals with disabilities. For regulated firms, the message is clear: accessibility is not some ancillary compliance feature but a central aspect of investor protection, equitable access, and ESG-conformant governance, with near-term deliverables, auditable artefacts, and ongoing yearly scrutiny. Companies that implement “accessible by design” in content, UX, engineering, testing, and vendor management won’t just comply with the letter of the law but also increase market reach, reduce legal risk, and enhance overall user experience, a competitive advantage built on inclusion. With near-immediate effectiveness and a six-month remediation horizon, the moment to act is now: take stock of digital assets; hire IAAP-accredited auditors; undertake thorough audits with PwD usability; finance and implement remediation; embed training, grievance redressal, and procurement controls; and integrate accessibility into governance reporting cycles to reflect sustained compliance and investor-focused stewardship.