The Securities and Exchange Board of India on 25 August 2025 issued a circular extending the compliance deadline for digital accessibility norms by six months for smaller market intermediaries. The extension applies to Category II and Category III intermediaries, while the original compliance timeline remains unchanged for larger entities classified under Category I.
Background
SEBI had earlier issued digital accessibility norms requiring all registered market intermediaries to ensure that their websites, mobile applications, and digital platforms comply with accessibility standards prescribed under the Rights of Persons with Disabilities Act, 2016 (RPwD Act). These norms were part of a broader initiative to ensure that securities market infrastructure is accessible to persons with disabilities, including visual, auditory, and motor impairments.
The original compliance deadline applied uniformly to all categories of intermediaries regardless of size and operational complexity. Representations from industry associations representing smaller brokerages, registrars, and transfer agents highlighted that the cost and technical complexity of achieving full digital accessibility compliance posed a disproportionate burden on entities with limited digital infrastructure and technology budgets.
Key Provisions
The SEBI circular dated 25 August 2025 modifies the compliance framework as follows:
Extended deadline for Category II and III intermediaries: Smaller market intermediaries classified under Category II and Category III receive a six-month extension from the original compliance date. This additional time is intended to allow these entities to engage accessibility consultants and implement the required technical modifications.
Category I timeline unchanged: Large intermediaries, including major stock brokers, depositories, and clearing corporations, remain subject to the original compliance deadline. SEBI noted that these entities possess the resources and technical capacity to meet the requirements within the initially prescribed timeframe.
Phased implementation permitted: Category II and III intermediaries may adopt a phased approach, prioritising accessibility modifications to client-facing platforms and trading interfaces before addressing internal or administrative systems.
Reporting obligation: All intermediaries must submit a compliance report to SEBI within 30 days of their applicable deadline, certifying adherence to the prescribed accessibility standards and identifying any areas of partial compliance.
Implications for Practitioners
The differentiated timeline acknowledges the varied operational realities within the intermediary ecosystem but does not reduce the substantive compliance obligation. Practitioners advising smaller intermediaries should treat the extension as an implementation window, not a signal of relaxed standards.
Compliance officers at Category II and III entities should use the extended period to conduct accessibility audits of all digital touchpoints, engage qualified accessibility consultants, and implement modifications systematically. The phased approach option is useful but should not be relied upon to defer substantive compliance work.
For larger Category I entities, the circular serves as a reminder that the original deadline stands. Any entity that has not completed its accessibility modifications should accelerate implementation. The mandatory compliance report introduces accountability that SEBI may use as a basis for enforcement action against non-compliant intermediaries.