The Securities and Exchange Board of India on 29 August 2025 issued Circular No. SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/121, extending compliance timelines and updating reporting authorities for its digital accessibility requirements under the Rights of Persons with Disabilities Act, 2016. The circular modifies the original directive dated 31 July 2025, which had mandated all SEBI-regulated entities to make their investor-facing digital platforms accessible to persons with disabilities.
Background
SEBI's original circular of 31 July 2025 (Circular No. SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111) established a phased compliance framework requiring all regulated entities — brokers, depositories, mutual funds, investment advisers, research analysts, and market infrastructure institutions — to ensure their websites, mobile applications, and digital platforms comply with accessibility standards under the Rights of Persons with Disabilities Act, 2016 and rules thereunder.
The original circular set tight deadlines that several categories of regulated entities, particularly smaller Investment Advisers (IAs) and Research Analysts (RAs), found challenging. The 29 August revision provides extended timelines specifically for these categories while also reorganising the reporting structure to streamline compliance oversight.
Key Changes
Extended platform list submission: All regulated entities must submit a list of their investor-facing digital platforms and a compliance status report by 30 September 2025. This initial disclosure step identifies the scope of digital assets requiring accessibility upgrades.
Auditor appointment deadline: Entities must appoint an IAAP-certified accessibility auditor (International Association of Accessibility Professionals) by 14 December 2025. The requirement for IAAP certification ensures that audits are conducted by professionals meeting internationally recognised accessibility standards.
Accessibility audit completion: The audit of all investor-facing platforms must be completed by 30 April 2026, with auditors producing a detailed report identifying non-compliant elements.
Remediation deadline: All identified accessibility issues must be remediated by 31 July 2026, representing the final compliance date.
Reporting authority changes: The circular reorganises which entities report to which oversight body:
- Investment Advisers and Research Analysts now report to BSE Limited
- Brokers and Depository Participants report to their respective stock exchange or depository
- Market Infrastructure Institutions and other regulated entities continue reporting directly to SEBI
Implications for Practitioners
The digital accessibility mandate represents a significant new compliance obligation for the securities market ecosystem. While the extended timelines provide breathing room, the July 2026 remediation deadline means that compliance planning should begin immediately.
For larger entities such as stock exchanges, depositories, and major brokerages, the accessibility overhaul of digital platforms will be a substantial technology project. These organisations typically maintain complex web applications with multiple investor-facing interfaces, and achieving WCAG (Web Content Accessibility Guidelines) compliance across all digital assets requires systematic audit and remediation.
Smaller regulated entities — particularly individual Investment Advisers and Research Analysts with modest digital footprints — face a proportionally different challenge: identifying and engaging IAAP-certified auditors and budgeting for necessary platform modifications. The reassignment of reporting authority to BSE may simplify compliance interactions for these entities.
Practitioners advising regulated entities should note that the IAAP certification requirement for auditors narrows the pool of eligible professionals. Early engagement of qualified auditors is advisable to avoid bottlenecks as the December 2025 appointment deadline approaches.
The broader policy signal is clear: SEBI is extending the disability rights framework into financial markets infrastructure, and this is likely the beginning rather than the end of accessibility requirements in the securities sector.