The Securities and Exchange Board of India, through Circular No. SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111 dated 31 July 2025, directed all regulated entities to make their digital platforms accessible to persons with disabilities in compliance with the Rights of Persons with Disabilities Act, 2016 (RPwD Act). The circular establishes a phased compliance framework covering websites, mobile applications, digital documents, and investor-facing processes across the entire securities market ecosystem.
Background
The circular follows the Supreme Court's judgment of April 2025 recognising digital access as a fundamental right under Article 21 of the Constitution. Despite the RPwD Act, 2016 mandating accessibility across all public-facing services, the financial sector had largely operated without specific digital accessibility standards. An assessment conducted by SEBI revealed significant gaps in the accessibility of investor-facing platforms operated by stock exchanges, depositories, mutual fund houses, brokers, and investment advisers.
Globally, financial regulators have increasingly required digital accessibility compliance, with the European Accessibility Act and the US Section 508 standards establishing precedents. SEBI's circular positions India's securities market among the jurisdictions with explicit accessibility mandates for financial platforms.
Key Provisions
The circular prescribes the following compliance requirements:
Scope of applicability: All SEBI-regulated entities — including stock exchanges, depositories, clearing corporations, mutual funds, portfolio managers, investment advisers, research analysts, and registered brokers — must ensure their investor-facing digital platforms meet prescribed accessibility standards.
Technical standards: Compliance must be achieved against the Web Content Accessibility Guidelines (WCAG) 2.1 (Level AA or latest version), the Guidelines for Indian Government Websites (GIGW) 3.0, and IS 17802, the Indian Standard for ICT accessibility.
Platform inventory: By 30 September 2025, each regulated entity must submit a comprehensive list of all its investor-facing digital platforms along with a report on existing accessibility measures.
Certified auditor appointment: By 14 December 2025, every entity must appoint an accessibility auditor certified by the International Association of Accessibility Professionals (IAAP) to conduct a full accessibility review.
Remediation deadline: All identified accessibility issues must be remediated by 31 July 2026, with platforms meeting the prescribed standards across all parameters.
Specific accessibility features: Websites and applications must include Indian Sign Language (ISL) videos for key investor communications, captions and audio descriptions for multimedia content, alt-text for images, and keyboard-navigable interfaces. Digital documents must be published as tagged PDFs with logical structure.
KYC process inclusivity: Digital KYC, e-KYC, and video KYC processes must be designed to be inclusive, with human-assisted alternatives available for persons who cannot complete automated verification.
Implications for Practitioners
This circular creates a comprehensive compliance obligation that will require regulated entities to undertake significant technology and process upgrades. The phased timeline provides a structured implementation path, but the 31 July 2026 final remediation deadline leaves limited room for delay given the technical scope of the changes required.
Securities law practitioners advising regulated entities should coordinate with technology teams to initiate the platform audit process immediately. The IAAP certification requirement for auditors may present a bottleneck, as the pool of certified accessibility auditors in India remains limited. Early engagement with qualified auditors will be essential to meeting the December 2025 appointment deadline.
For disability rights advocates and investor protection practitioners, the circular creates an enforceable framework to hold financial market participants accountable for digital inclusion. Non-compliance may expose entities to regulatory action by SEBI as well as claims under the RPwD Act before the Chief Commissioner for Persons with Disabilities.