The recent circulars issued by the Securities and Exchange Board of India (SEBI) w.r.t. digital accessibility for Persons with Disability (PwD) has sent the SEBI intermediaries in a tailspin. It is an onerous ask, the deadlines are closing and there is a flood of queries about “what to do?”
Yesterday, a SEBI Registered Research Analyst client approached us. He was anxious about the additional compliances, its costs and reporting requirements.
“Kruti, I have just started my business, hardly a few clients. I don’t even have a client login interface. How am I supposed to comply with this circular? Don’t even ask about the audit. I have heard that these auditors charges more than what I have earned so far in fees. There should be exemption for very small operations like mine.”
While SEBI’s intention about creating a more inclusive and equitable digital ecosystem in the securities market is noteworthy but most smaller intermediaries are not happy with this abrupt and costly demand.
“I don’t think there is a way out. Compliance is required”.
“You are right, Kruti. That’s what I am asking for. Please help me with the compliance”.
“Okay, let me share a note with you.”
This is the note I shared with him later. Hope you find it useful. Read on.
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On July 31, 2025, SEBI issued a landmark circular mandating all Regulated Entities (REs), including Investment Advisers (IAs), Research Analysts (RAs), Portfolio Managers (PMS) and Alternative Investment Funds (AIFs) to ensure their digital platforms comply with the Rights of Persons with Disabilities Act, 2016 (RPwD Act) and its Rules, 2017.
The circular, effective from July 31, 2025, outlines a robust framework for digital accessibility, with specific mandates and timelines tailored to REs.
All REs are required to ensure that their digital platforms like websites, mobile applications, web portals, etc., should comply with the requirements of SEBI circular w.r.t digital accessibility for Rights of Persons with Disabilities.
Adherence to Accessibility Standards: The key requirements for the website(s) and other the digital platforms:
All digital platforms (e.g., websites, apps, client dashboards) and content published on the digital platforms must comply with:
- Web Content Accessibility Guidelines (WCAG) 2.1 (AA level or latest version): Global standards for accessible web content.
- Guidelines for Indian Government Websites (GIGW) (recommended): National standards for usability and accessibility.
- Indian Standard (IS) 17802: Indian Standards on Accessibility Requirements for Information and Communication Technology (ICT) products and services, covering websites, apps, and digital documents that align with global frameworks.
- The Rights of Persons with Disabilities Act, 2016 and corresponding rules for digital accessibility.
More details about WCAG
The website and other digital platforms should comply with Web Content Accessibility Guidelines (WCAG) 2.1, Level AA which is an international standard developed by W3C.
The four principles of WCAG 2.1 are – Perceivable, Operable, Understandable, and Robust (POUR)
(P) Perceivable – Information and user interface must be presentable to users in such a way that they can be easy to perceive.
(O) Operable – User interface components should be easy to use with a keyboard, safe to interact with, and simple to navigate.
(U) Understandable – Information and content posted must be clear, predictable, and easily understandable.
(R) Robust – Content must be robust to be interpreted by wide users’ agents including assistive technologies.
How to prepare for compliance?
Here are the actionable steps:
1. Reporting of digital assets:
All REs, as on the date of the circular, were required to submit the details of their website and client facing portals to the respective authorities.
2. Appointment of Nodal Officer:
The nodal officer should be a senior officer or the compliance officer, in case there is no senior officer. The major roles and responsibilities of the Nodal Officer include implementation of accessibility guidelines, and timely redressal of grievances.
3. Website readiness:
The website and other digital portals have to be compliant with the Accessibility Standards mentioned above.
The digital platforms should have mandatory features like screen-reader-compatible interfaces, alternative text for images, Indian Sign Language (ISL) videos, closed captions, and audio descriptions for videos.
4. Accessible Documentation:
All client-facing documents (e.g., agreements, risk disclosures, fee schedules) must be available in accessible formats like tagged PDFs, large print, proper use of headings, alt text, or audio versions to support assistive technologies.
The client registration forms / on-boarding forms shall include a mandatory field to indicate disability status and options to select specific provisions such as helpdesk callback for assistance.
Click here to know more about PDF techniques.
5. Staff Training:
Conduct internal training and awareness programs for employees and third-party service providers involved in website/app development or content management.
The training module must include behavioural training, assistive tools and inclusive experience for normal as well as differently abled users.
What are the immediate reporting and audit requirements?
1: Readiness report of the website
The REs are required to submit readiness status report of the website by March 31, 2026.
For the same, they can appoint International Association of Accessibility Professionals (IAAP)-certified experts to help with the same.
Click here to get a list of Empanelled Web Accessibility Auditors with the Department of Empowerment of Persons with Disabilities.
The format for submitting a status of readiness and compliance to the accessibility requirements is given by SEBI in Annexure B here.
2: Conduct the audit and submit the report.
The accessibility audit should be completed and an audit report should be submitted to the reporting authorities. The said accessibility audit shall include usability testing by persons with disabilities.
The format for submission of the initial audit is given by SEBI here.
Annual compliance is to be submitted within 30 days of each Financial Year, effective April 30, 2027.
Here are the authorities to whom reporting needs to be done:
Is there an exemption for individual RA and RIA?
As we write this, there is no exemption for any RE whether it is a individual RA or RIA or an entity with a small setup.
What is the cost of these audits?
There are no fixed charges quoted by the auditors. The charges will depend on the content of your digital platforms as well as the number of pages your website has.
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While the rights and accessibility safeguards for persons with disabilities are an essential and progressive step, the practical implementation of these requirements has created genuine concerns for small or individual Investment Advisers and Research Analysts. With limited financial and operational capacity, the high costs of website upgrades, accessibility audits, and ongoing compliance can be disproportionately burdensome for such entities.
In our view, although the intention behind the regulation is noble, a uniform compliance approach may unintentionally disadvantage smaller market participants. SEBI should consider the representations made by IAs and RAs and adopt a more balanced framework—whether through phased implementation, cost-effective alternatives, or suitable exemptions for entities whose size and business model do not create accessibility barriers.