Mandating Digital Inclusion: How SEBI Intermediaries Must Comply with the Rights of Persons with Disabilities Act, 2016

Introduction:
Imagine a visually impaired investor trying to navigate a trading app to check their portfolio, only to be blocked by inaccessible charts and buttons that don’t work with screen readers. This isn’t just frustrating—it’s exclusionary, and in India’s evolving regulatory landscape, it’s now illegal. Real stories like this highlight the urgency behind SEBI’s recent circulars on the Rights of Persons with Disabilities (RPwD) Act, 2016, which mandate digital accessibility for all regulated financial intermediaries.

With the original circular issued on July 31, 2025, and extensions granted on August 29 and September 25, 2025, SEBI is pushing Portfolio Managers, Alternative Investment Funds (AIFs), Investment Advisers (IAs), Research Analysts (RAs), and other SEBI-regulated entities to make their online platforms inclusive. This isn’t mere bureaucracy; it’s about expanding market access, building trust, and avoiding hefty penalties that could reach significant amounts.

This article demystifies the requirements, breaks down the mandatory compliance steps, offers practical guidance for intermediaries such as Portfolio Managers, AIFs, Investment Advisers, and Research Analysts, and outlines the crucial steps — along with extended timelines — for achieving digital accessibility. Whether you are a compliance officer dissecting regulations or a CEO focused on operational risk, here is what you need to know about navigating SEBI’s digital accessibility mandate.

Background and Insights – The Regulatory Imperative
The Core Issue: Mandatory Digital Accessibility
The RPwD Act, 2016 is India’s cornerstone legislation for protecting persons with disabilities, emphasizing equal opportunity in all spheres, including digital access. Section 40 mandates accessibility in information and communication technology, while Section 42 requires service providers to ensure platforms are usable by those with disabilities. SEBI’s circular effectively enforces these provisions in the securities market to protect investors and promote inclusive development.

The July 31, 2025 SEBI circular made digital accessibility compliance mandatory for all SEBI-regulated entities (REs), including stock brokers, depositories, mutual funds, Portfolio Managers, AIFs, Investment Advisers, and Research Analysts. It requires REs to audit and, if needed, remediate their digital platforms for accessibility, aligning with standards like the Web Content Accessibility Guidelines (WCAG) 2.1 (often referenced in RPwD rules). The primary goal is to ensure that the digital platforms provided by REs offer full and equal access to investors with various disabilities, including those with low vision, blindness, and other impairments.

Due to industry representations and challenges in immediate implementation, SEBI extended the timelines via an August 29, 2025 circular. Key extensions included: submission of a compliance/action taken report (with a list of digital platforms) by September 30, 2025; appointment of IAAP-certified accessibility professionals as auditors by December 14, 2025; completion of initial accessibility audits by April 30, 2026; remediation of all findings by July 31, 2026; and, starting in 2027, conducting annual accessibility audits of all platforms with reports due by April 30 each year. Depending on the type of entity, these compliance reports go either to the stock exchanges (e.g., BSE Ltd. for certain intermediaries like IAs and RAs) or directly to SEBI.

Insights for Professionals: Standards and Scope

Compliance teams must note that SEBI requires strict adherence to both global and national accessibility standards. The following standards serve as the baseline for all digital initiatives:

• Web Content Accessibility Guidelines (WCAG) 2.1 (or the latest version) – International standard for web accessibility.
• GIGW Guidelines – The latest Guidelines for Indian Government Websites, which include accessibility provisions relevant to Indian context.
• IS 17802 (Indian Standards on Accessibility Requirements for ICT Products and Services) – National standards specifying accessibility requirements for technology and digital services

Furthermore, digital platforms must be designed with “accessible by design” principles, meaning accessibility should be an integral part of the development process, not an afterthought.

Business Perspective: Why Compliance Matters
While the SEBI circulars do not detail specific monetary penalties for non-compliance, they are issued under SEBI’s mandate to protect investors and regulate the securities market. Non-compliance with these mandatory directives under a core investor protection framework introduces significant regulatory risk. For business owners, failure to provide equitable digital access could result in the exclusion of a large demographic of potential clients – leading to missed market opportunities and, critically, the erosion of customer trust. Maintaining strong compliance, conversely, builds loyalty, demonstrates due diligence, and protects the firm from regulatory action.

Digital Platforms and Compliance Expectations
The scope of SEBI’s accessibility compliance covers all types of digital platforms provided by intermediaries to investors — including websites, mobile applications, and portals. Compliance efforts must address each channel comprehensively. Below are key platforms and what is expected for each:

• Corporate Website/Client Portal: Used for marketing, research report distribution (for RAs), client login and account statements (for PMs), and publishing notices (for IAs/AIFs). Compliance Tip: Ensure all published content (e.g. circulars, reports, statements) is in an accessible format. PDFs and documents should be properly tagged for screen readers. Use a logical reading order on web pages with proper headings and provide alternative text (alt text) for all images.
• Mobile Applications (Apps): Used for real-time portfolio monitoring (PMs), fund investments and account management (AIFs), and subscription management (IAs/RAs). Compliance Tip: Implement a user interface that supports accessibility features: ensure screen reader compatibility, sufficient color contrast ratios, and full keyboard navigation support for users who cannot use touch screens. Additionally, include digital accessibility checks in your app’s regular audits – accessibility compliance should be part of your annual audit scope.
• e-KYC and Video KYC Systems: Used for client onboarding and identity verification processes. Compliance Tip: Provide alternative methods to accommodate users with disabilities. For example, incorporate options like human-assisted video KYC or voice-assisted KYC for visually impaired users who may struggle with standard digital KYC procedures. No client should be prevented from onboarding due to accessibility barriers.
• Explanatory Videos/Webinars: Used for financial education, product demonstrations, or investor webinars. Compliance Tip: Make all multimedia content accessible. This means adding features such as Indian Sign Language (ISL) interpretation or inset videos, closed captioning for all spoken content, and descriptive audio or transcripts for those with hearing or visual impairments. By doing so, you ensure that educational content is inclusive for all viewers.

Institutional and Technical Requirements
SEBI expects intermediaries to establish a formal internal structure for managing digital accessibility compliance:

Nodal Officer: The Managing Director, Managing Partner, or Proprietor of the entity must appoint a Nodal Officer responsible for ensuring the firm’s compliance with SEBI’s digital accessibility directives. This officer will oversee accessibility audits, coordinate necessary changes, and be accountable for timely submission of compliance reports.

Grievance Redressal: A dedicated grievance redressal mechanism for accessibility issues must be in place. This should include easy-to-use channels (special email addresses, helplines, web forms) that are accessible to persons with disabilities. Complaints about digital accessibility should be tracked and addressed promptly, with escalation to senior officers as needed to ensure resolution.

Training and Awareness: Digital accessibility practices should be integrated into the training programs for staff and relevant third-party service providers. Training modules should cover both technical guidance (use of assistive tools, developing accessible content) and behavioral awareness to foster an inclusive mindset. By educating IT teams, designers, compliance staff, and customer service teams, firms ensure everyone understands their role in maintaining an accessible platform.

Do’s and Don’ts for Businesses
To transform compliance into a strategic advantage and minimize regulatory risk, intermediaries should follow these best practices:

Do’s (Actionable Compliance):

• Do conduct comprehensive accessibility audits of all digital platforms (websites, mobile apps, investor portals) using IAAP-certified accessibility professionals. Identify and address gaps proactively.
• Do implement “accessible-by-design” principles in all new digital solutions. For example, ensure procurement contracts with tech vendors include accessibility requirements and evaluation.
• Do ensure all client onboarding forms (KYC) capture disability needs, and provide options accordingly. Include a field for clients to indicate disabilities so you can offer appropriate support from the start.
• Do document every step of your compliance efforts: Maintain detailed records of audit reports, remediation measures taken, training sessions completed, and any other evidence of due diligence. This documentation will be crucial in demonstrating compliance to regulators.

Don’ts (Risks to Avoid):

• Don’t treat accessibility compliance as a siloed IT issue. It requires a cross-functional effort. Avoid leaving it solely to the IT team – involve compliance officers, legal advisors, UX/UI designers, and business leaders to ensure holistic buy-in.
• Don’t assume existing platforms are already compliant. Even if no complaints have surfaced, conduct reviews of all legacy websites and apps. Many existing platforms need updates or upgrades to meet the new standards within the mandated timelines.
• Don’t rely solely on visual communication. Ensure that all information conveyed via charts, images, or videos is also available through alternate means (e.g., alt text for images, captions for videos, text transcripts for audio). Purely visual content will alienate those using screen readers or those with visual impairments.
• Don’t unintentionally exclude users with disabilities from account opening or other processes. For example, never reject an application from a client with a disability just because the standard process doesn’t accommodate them. You must have a manual override or assisted process (e.g., a human officer review) to handle such cases on a fair basis.

Compliance Checklist and Timeline
To manage implementation of these requirements, REs must adhere to the following updated deadlines (as per SEBI’s extensions on August 29, 2025):

Note: Investment Advisers (IAs) and Research Analysts (RAs) must report their compliance status to BSE Ltd. (the designated authority for these intermediaries), while Portfolio Managers, AIFs, and most other REs will submit reports directly to SEBI or to their respective primary regulator as instructed.

Key Takeaways
The SEBI mandate for digital accessibility is a significant step toward ensuring equality and integrity in the Indian securities market. From establishing institutional mechanisms and appointing Nodal Officers to undertaking rigorous audits and remediating findings, staying compliant requires foresight, a robust compliance framework, and strategic investment. The extended timelines provide some breathing room, but the commitment to digital inclusion remains mandatory and non-negotiable.

By embracing accessibility standards like WCAG 2.1 and related guidelines, REs do not just “tick a compliance box” — they enhance their services, protect themselves from regulatory action, and uphold the fundamental rights of persons with disabilities to participate fully in the financial markets. In essence, accessibility compliance is not only about avoiding penalties; it’s about expanding your client base and strengthening trust by ensuring no investor is left behind.

 Assess your business today: Have you appointed your Nodal Officer? Are your e-KYC alternatives in place? What’s your biggest digital accessibility challenge right now?

If you discover gaps or feel unprepared to meet these requirements, consider seeking expert help. For hands-on assistance in meeting these new mandates (and other SEBI compliance obligations), reaching out to a SEBI compliance consultant can make all the difference.