SEBI Compliance & Digital Inclusion for Regulated Entities (REs)

Understanding the SEBI Mandate for Digital Accessibility

The Securities and Exchange Board of India (SEBI) has issued a crucial circular (SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111) dated July 31, 2025, making it mandatory for all Regulated Entities (REs) to comply with the provisions of the Rights of Persons with Disabilities Act, 2016 (RPwD Act, 2016) and its corresponding rules. This directive aims to protect the rights and dignity of persons with disabilities and ensure their full and effective participation in the securities market through accessible digital platforms.

This circular underscores SEBI’s commitment to fostering an inclusive digital ecosystem, aligning with the Hon’ble Supreme Court’s judgment that the right to Digital Access is an intrinsic component of the right to life and personal liberty. Compliance is not just a legal obligation but a step towards a more equitable financial landscape.

Key Requirements for REs under the SEBI Circular

The circular outlines specific provisions and milestones that REs must adhere to:

• Mandatory Digital Platform Compliance: All digital platforms of REs must be compliant with the RPwD Act, 2016, specifically Sections 40 (Accessibility), 42 (Access to information and communication technology), and 46 (Time limit for accessibility by service providers), and Rule 15(1)(c) of the RPwD Rules, 2017.
• Accessibility Standards: Digital platforms and content must strictly adhere to Web Content Accessibility Guidelines (WCAG) 2.1 (or latest), Guidelines for Indian Government Websites (GIGW), and IS 17802.
• Milestone-Based Implementation: REs must meet specific timelines:
  • Within 1 month: Submit a list of digital platforms and a compliance/action taken report.
  • Within 45 days: Appoint an IAAP certified accessibility professional as Auditor.
  • Within 3 months: Conduct an Accessibility Audit for digital platforms.
  • Within 6 months: Remediate findings from the audit and ensure compliance.
• Annual Compliance Reporting: Compliance status must be reported annually within 30 days from the end of each financial year to the respective reporting authority (Stock Exchanges/Depositories, BASL, or SEBI).
• Institutional Arrangements: Designate a Nodal Officer for digital accessibility, establish a grievance redressal mechanism for accessibility issues, and ensure review and approval by senior management.
• Accessible KYC & Registration: Digital KYC, e-KYC, and video KYC processes must include alternatives for differently-abled users, and registration forms must include disability status fields.
• Training & Awareness: Implement training modules for staff and third-party service providers on digital accessibility, emphasizing “accessible by design.”
• Procurement & Technical Compliance: All newly developed/procured digital solutions must conform to accessibility guidelines, and accessibility requirements must be part of RFPs and procurement contracts.

How We Support Regulated Entities in Achieving Compliance

We provide comprehensive services tailored to help REs meet every aspect of the SEBI circular:

• IAAP Certified Digital Accessibility Audits: Conducted by our IAAP certified professionals, ensuring adherence to all specified standards (WCAG, GIGW, IS 17802, RPwD Act). Includes usability testing by PwDs.
• Remediation & Implementation Services: Expert assistance in fixing identified accessibility issues across your digital platforms, content, and processes within the 6-month timeline.
• Nodal Officer & Grievance Mechanism Support: Guidance on designating Nodal Officers and establishing effective, accessible grievance redressal systems.
• Accessible KYC & Registration Solutions: Development and integration of alternative methods for KYC and client registration processes to accommodate PwDs.
• Training & Awareness Programs: Customized training modules for your teams to foster an “accessible by design” culture.
• Procurement & Technical Consulting: Advising on integrating accessibility requirements into your procurement processes and ensuring new solutions are compliant.
• Annual Compliance Reporting Assistance: Support in preparing and submitting your annual accessibility compliance reports to the relevant authorities.