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SEBI requires regulated entities to make their digital platforms and published content accessible under the Rights of Persons with Disabilities Act, 2016, and its associated rules. The July 31, 2025 circular covers more than websites: it also addresses mobile apps, portals, investor documents, KYC processes, and new or procured digital services. Its named reference points are WCAG 2.1 or the latest version, the latest Guidelines for Indian Government Websites (GIGW), and Indian Standard IS 17802.
Who and what the SEBI directions cover
SEBI’s July 31, 2025 Circular 2025/111 defines a regulated entity as a SEBI-registered or recognised intermediary, or a market infrastructure institution regulated by SEBI. Examples include stockbrokers, mutual funds, KYC Registration Agencies (KRAs), registrars and transfer agents (RTAs), stock exchanges, depositories, and clearing corporations.
The duty is not limited to a public-facing homepage. The circular directs regulated entities to make all their digital platforms accessible and addresses websites, mobile applications, portals, and content published on them. It also covers investor-facing circulars, notices and documents; KYC and related processes; and digital solutions developed or procured by the entity, including SaaS products. The regulated entity remains responsible when a vendor supplies the technology.
Which laws and technical references apply
The circular cites sections 40, 42 and 46 of the Rights of Persons with Disabilities Act, 2016, and Rule 15(1)(c) of the Rights of Persons with Disabilities Rules, 2017. Its named technical and guidance references are WCAG 2.1 or the latest version, the latest GIGW guidance, and IS 17802, the Indian Standard on Accessibility Requirements for ICT Products and Services.
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These are baseline references for digital initiatives; the circular does not reproduce every individual success criterion. The December 2025 reporting format asks entities to state whether each platform meets minimum AA-level accessibility under the latest WCAG. That reporting field should not be mistaken for a list of all the criteria in the July circular. Entities need to assess their platforms against the applicable, current standards and guidance.
What accessible platforms and content need to include
Websites, apps and portals
Assess each investor-facing platform, rather than treating the website homepage as a proxy for the whole service. The circular calls for a comprehensive accessibility audit across websites, mobile apps and portals, and usability testing by persons with disabilities. Its references to WCAG, GIGW, the RPwD Act and Rules, and SEBI directions provide the basis for that assessment.
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Videos, images and documents
SEBI names Indian Sign Language (ISL) video, closed captions, descriptive audio and alternative text for images. For example, a KYC explainer video should include captions and ISL interpretation. Investor-facing PDFs and other documents should have accessible structure, including tagged PDFs, logical reading order, proper headings and image alt text. The circular’s annexure points to W3C PDF techniques and says to follow revised accessibility standards for text documents where applicable.
Accessible KYC, registration and investor support
For KYC, e-KYC and video KYC, the circular gives examples of alternative ways to complete the process: human assistance, scanned-document uploads, and voice assistance for blind and low-vision users. Registration forms must include a disability-status field and provide for requested accommodations, such as a helpdesk callback.
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An automated rejection should not be the final decision on an application from a person with a disability. The circular requires designated human review and an authority able to override the automated outcome and approve the application case by case.
Governance, training and accessibility complaints
Compliance must be reviewed and approved by the managing director, managing partner or proprietor, as applicable. A senior officer should be designated as nodal officer. If no officer is formally named, the compliance officer or proprietor is deemed to serve in that role. The nodal officer coordinates audits, remediation, guidelines and grievance redressal, and acts as the contact for SEBI.
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Entities must establish an accessibility-specific grievance process with usable email, helpline or web-form channels and escalation to senior officers. The December 2025 clarification also says investors can submit digital-platform accessibility complaints against regulated entities through SCORES, where an “Accessibility” category is provisioned. The entity must remediate the issue to close the complaint.
Accessibility training belongs in internal programs for staff and third-party service providers who develop or publish digital content. SEBI’s July 31, 2025 circular, Annexure I, section 3.1, states: “The Digital Platform shall be ‘accessible by design’.”
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Audits, remediation and procurement
The July circular calls for a comprehensive accessibility audit of websites, apps and portals through IAAP, with usability testing by persons with disabilities. It also requires a remediation plan, implementation of that plan, and annual audits through IAAP-certified professionals. The audit should take account of the latest WCAG and GIGW guidance, the RPwD Act and Rules, and SEBI directions.
Accessibility requirements should be included when buying or commissioning digital services: the circular says new or procured solutions must conform to its named baselines and calls for accessibility to be covered in requests for proposals and procurement contracts. Outsourcing development or using SaaS does not transfer the regulated entity’s responsibility for compliance.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.SEBI circulars and current timeline
| Date and document | What it established |
|---|---|
| July 31, 2025 — Circular 2025/111 | Issued the digital accessibility directions and original milestones for platform inventory, reporting, auditor appointment, audit, remediation and annual reporting. |
| August 29, 2025 — Circular 2025/121 | Extended early reporting dates to September 30, 2025; auditor appointment to December 14, 2025; accessibility audit to April 30, 2026; and remediation to July 31, 2026. |
| September 25, 2025 — Circular 2025/131 | Issued compliance guidelines tied to the July 31 circular. |
| December 8, 2025 — clarification | Required each regulated entity to submit readiness and compliance status for every digital platform by March 31, 2026, replacing the earlier auditor-appointment compliance milestone. It also addressed periodic audits by certified accessibility professionals and SCORES complaints. |
| July 31, 2026 — further SEBI notice | Officially confirms a further extension of audit and remediation timelines. A secondary legal summary reports October 31, 2026 as the revised date; the specific date should be checked against the notice’s official attachment, whose text was not available in extractable form in the sources reviewed for this article. |
Reporting destinations depend on entity category. The circulars direct brokers and depository participants to report through stock exchanges or depositories, investment advisers and research analysts to BSE Ltd., and market infrastructure institutions and other specified entities to SEBI. The December clarification’s annexure assigns SEBI departments for categories including AIFs, clearing corporations, credit rating agencies, custodians, KRAs, merchant bankers, mutual funds and AMCs, portfolio managers, RTAs and VCFs. Check the relevant circular annexure for the exact authority and route for your entity rather than relying on this summary.
A practical implementation sequence
- Inventory the service. List every website, app, portal, investor document, KYC journey and procured digital service in scope. Identify the entity and business owner responsible for each.
- Assign accountability. Confirm the required senior-level review and approval, designate the nodal officer, and provide accessible complaint channels with escalation.
- Assess against the references. Engage qualified accessibility professionals to assess the platforms against current WCAG and GIGW guidance, IS 17802, the RPwD Act and Rules, and SEBI directions. Include disabled-user usability testing.
- Fix content and workflows as well as interfaces. Include documents, video and image alternatives, KYC accommodations, and human review of disability-related application rejections in the remediation scope.
- Put findings into a tracked remediation plan. Assign owners and follow-through for existing-platform upgrades, procured solutions and vendor work. Keep evidence of the assessment, fixes and outstanding issues.
- Report through the applicable route and maintain the cycle. Use the applicable circular annexure for reporting authority and format, then continue with periodic and annual audits and an accessibility grievance process.
Common implementation mistakes to avoid
- Auditing only the main website: include apps, portals, documents, investor journeys and procured services in the inventory and audit scope.
- Treating automated checks as the whole audit: SEBI calls for audits through IAAP and usability testing by persons with disabilities; plan for both.
- Leaving accessibility to a vendor: specify requirements in procurement documents and contracts, but retain internal ownership for compliance and remediation.
- Relying only on automated KYC decisions: ensure designated human review and override authority for applications from persons with disabilities.
- Using an outdated deadline or reporting route: distinguish the original circular from later extensions and clarifications, and check the annexure for the entity’s category.
Documenting a page visually is not an accessibility audit
A screenshot can help teams record how a page looked at a particular moment, but it cannot establish WCAG conformance, replace assistive-technology evaluation, or substitute for usability testing by persons with disabilities. ScreenshotNeo is a website screenshot API and MCP server for developers; it may be used to capture a visual reference, not to certify regulatory compliance. See ScreenshotNeo and its API documentation.
For example, a team can capture a page while keeping its own accessibility audit and testing process separate:
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curl -G "https://api.screenshotneo.com/v1/shot" -d access_key=YOUR_API_KEY --data-urlencode url=https://example.com -o shot.webpScreenshotNeo says it removes cookie/consent banners, newsletter popups and chat widgets before capture, and that bot checks, blank pages and failed loads are not billed. It also offers an MCP server for AI agents. These functions do not assess accessibility or satisfy SEBI’s audit requirements.
Or skip the browser setup
A single GET request can return an image or PDF capture. Cookie banners, popups and chat widgets are removed before the shot; bot checks, blank pages and failed loads are never billed. An MCP server lets AI agents take screenshots. The free plan includes 1,000 screenshots a month with no card, and paid plans start at $5 for 3,000. These are screenshot and workflow features, not an accessibility audit or compliance finding.
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