SEBI Circular on Mandatory Compliance with Rights of Persons with Disabilities Act, 2016 for Digital Platforms

पष्ृठ सं. 1 (कुल पष्ृठ 10) Page 1 of 10
परिपत्र / CIRCULAR
SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111 31.07.2025 To,

1. All Recognised Stock Exchanges
2. All Recognised Clearing
   Corporations
3. All Registered Depositories
4. All Registered Intermediaries
5. Association of Mutual Funds in India
   (AMFI)
6. Association of Portfolio Managers in
   India (APMI)
7. BSE Administration & Supervision
   Limited (BASL)
   महोदया / महोदय, Madam/Sir,
   Subject: Rights of Persons with
   Disabilities Act, 2016 and rules made thereunder- mandatory compliance by all Regulated Entities.
8. To protect the rights and dignity of
   persons with disabilities and ensure their full and effective participation in securities market, it is necessary to

पष्ृठ सं. 2 (कुल पष्ृठ 10) Page 2 of 10 provide for their access to Digital Platforms of SEBI Regulated Entities.
2. For the purpose of this Circular, the
term “Regulated Entity or RE1
” shall refer to SEBI registered/ recognised intermediaries (for example stockbrokers, mutual funds, KYC Registration Agencies, QRTAs, etc.) and Market Infrastructure Institutions (Stock Exchanges, Depositories and Clearing Corporations) regulated by SEBI.
3. In order to facilitate such
accessibility, it is mandated that all
Digital Platforms of REs shall be compliant with the provisions of the Rights of Persons with Disabilities Act, 2016 (“RPwD Act, 2016”) and corresponding rules, specifically with regard to the following

Entities within SEBI’s purview, refer to Securities Contracts (Regulation) Act 1956, SEBI Act 1992, and Depositories Act 1996.

पष्ृठ सं. 3 (कुल पष्ृठ 10) Page 3 of 10 provisions (as amended or modified or substituted from time to time):
a. Section 40 of RPwD Act, 2016-
Accessibility b. Section 42 of RPwD Act, 2016- Access to information and communication technology.
c. Section 46 of RPwD Act, 2016-
Time limit for accessibility by service providers.

d. Rule 15(1)(c) of the Rights of
Persons with Disabilities Rules,
2017- Rules for Accessibility
4. REs shall refer to Annexure I for
detailed directions on ensuring compliance with Digital Accessibility requirement for Persons with Disabilities.
5. REs shall provide updates on the
status of implementation of accessibility provisions on all this Digital Platforms, specifically in accordance to the following milestones:

पष्ृठ सं. 4 (कुल पष्ृठ 10) Page 4 of 10
Sl. No.
समय-सीमा / Timeline क्या-क्या किना है / Milestone Within 1 month of the issuance of circular REs shall submit a list of digital platforms provided by them for the investors. REs shall submit a compliance/ action taken report pertaining to the clauses of this circular. Within 45 days of the issuance of circular Appointment of IAAP certified accessibility professionals as Auditor. Within 3 month of issuance of the circular Conduct of Accessibility Audit for the digital platforms. Within 6 months of issuance of circular Remediation of findings from the audit and ensuring compliance with this circular.

पष्ृठ सं. 5 (कुल पष्ृठ 10) Page 5 of 10
6. The compliance reporting for this
circular shall be done on annual basis within 30 days from the end of each financial year in accordance with the following manner:
Sl.
No.
Regulated Entity
Reporting authority
Stock Brokers/ Depository
Participants
Stock Exchanges / Depositories.
Investment Advisor (“IAs”)
BSE Administration & Supervision
Limited (“BASL”).
MIIs and rest of the REs
SEBI
7. Applicability: The provisions of this
circular shall be applicable to all
REs with effect from the date of this circular.
8. This circular is being issued in
exercise of the powers under
Section 11(1) of the Securities and
Exchange Board of India Act, 1992, to protect the interests of investors in securities and to promote the

पष्ृठ सं. 6 (कुल पष्ृठ 10) Page 6 of 10 development of, and to regulate the securities market. (www.sebi.gov.in) पर इन शीषमकों
9. This circular is available at
www.sebi.gov.in under the link
“Legal → Circulars”.
भवदीय / Yours faithfully,
दीपािंकि चटजी / Deepankar Chatterjee
उप महाप्रबिंधक / Deputy General Manager
फोन / Phone: 022-26449643
ई-मेल / Email: deepankarc@sebi.gov.in
संलग्न / Encl.: उपरोक्ियनसु यर / As above

पष्ृठ सं. 7 (कुल पष्ृठ 10) Page 7 of 10
Annexure-I
Directions on Digital Accessibility for Persons with Disabilities (PwDs) A. Executive Summary Recently, writ petitions were filed before the Hon’ble Supreme Court of India to formulate appropriate rules and guidelines for conducting Digital Know Your Client (“KYC”) /e-KYC/video KYC (Know Your Customer) process through alternative methods with a view to ensuring that the process is more inclusive and accessible to all persons with disabilities in accordance with the provisions of the Rights of Persons with Disabilities Act, 2016 (“RPwD Act, 2016”) and rules made thereunder. The Hon’ble Supreme Court, in its judgment dated April 30, 2025, in the matter of Pragya Prasun & Ors. Vs. Union of India and Ors. [WP(C)/289/2024] and Amar Jain vs. Union of India & Ors. [WP(C)/49/2025] pertaining to Digital Accessibility for persons with disabilities, has inter alia held that the right to Digital Access is an intrinsic component of right to life and personal liberty. In line with the judgment of the Hon’ble Supreme Court dated April 30, 2025, SEBI has directed its efforts towards strengthening the accessibility of Digital Platforms in the securities market. In order to promote an inclusive digital ecosystem in the Indian Securities Market, this Annexure outlines a set of actionable directions to ensure digital accessibility. These directions are divided into thematic sections for better comprehension and execution by SEBI Regulated Entities (REs). Hereafter, the term “Digital Accessibility” shall inherently be understood as “Digital Accessibility for Persons with Disabilities” in order to prioritize digital accessibility for all persons with disabilities – including but not limited to acid attack survivors suffering from permanent facial/eye disfigurement, persons with blindness and low vision, and other similarly placed individuals. B. Scope All REs shall ensure that their Digital Platforms and content published on the digital platform shall strictly adhere to the accessibility standards and guidelines, including:

1. Web Content Accessibility Guidelines (“WCAG”) 2.1 or latest version.
2. Accessibility guidelines as described in the latest version of Guidelines for
   Indian Government Websites (“GIGW”).

पष्ृठ सं. 8 (कुल पष्ृठ 10) Page 8 of 10
3. IS 17802: Indian Standards on Accessibility Requirements for Information and
Communication Technology (“ICT”) Products and Services.
4. Provisions of the Rights of Persons with Disabilities Act, 2016 and
corresponding rules for digital accessibility mentioned in this Circular. These standards shall serve as the baseline for compliance under this circular and must be referred to in all digital initiatives.
C. Directions for ensuring Digital Accessibility
Section 1: Institutional Arrangement
1.1. The compliance with this circular shall be reviewed and approved by
Managing Director or the Managing Partner or the Proprietor of the REs, as may be applicable. REs shall designate any senior officer as the Nodal Officer for digital accessibility compliance. In the absence of an officially designated Nodal Officer, the Compliance Officer or the Proprietor shall be deemed to be the Nodal Officer for ensuring digital accessibility compliance.
1.2. The major roles and responsibilities of the Nodal Officer shall be to ensure
digital accessibility for every investor by ensuring that activities, including but not limited to conducting accessibility audits, mitigation of accessibility audit findings, implementation of accessibility guidelines, and timely redressal of grievance. The Nodal Officer shall serve as the contact point for SEBI in any matter pertaining to digital accessibility.
1.3. A grievance redressal mechanism specific to accessibility issues shall be
institutionalized within the REs. Channels such as email, helpline, and web forms must be user-friendly for PwDs. The system must include provisions for escalation to senior officers.
1.4. The reporting of compliance with respect to this circular shall be done by
the REs to their respective authority(ies) as per the reporting mentioned in this Circular.
Section 2: Web and Document Accessibility
2.1. The Digital Platforms of the REs shall include features such as Indian Sign
Language (ISL) videos, closed captioning, descriptive audio, and alternate text for images. For instance, an explainer video on KYC must include captions and ISL interpretation.

पष्ृठ सं. 9 (कुल पष्ृठ 10) Page 9 of 10
2.2. All circulars, notices, and investor documents published on the Digital
Platforms of the RE’s (website, mobile application, etc.) in PDF or other formats must follow accessible document standards—such as tagged PDFs, logical reading order, proper use of headings, and alt text. The RE shall follow the PDF techniques (https://www.w3.org/TR/WCAG20- TECHS/pdf) covered in WCAG 2.1 for the same. If a revised standard for accessibility of Text documents is published by W3C (World Wide Web Consortium, the owner of WCAG standards) the compliance to the venue standard should be ensured.
Section 3: Training and Awareness
3.1. Training modules that give detailed understanding on digital accessibility
(website, mobile application, etc.) shall be part of all internal training programs for staff and third-party service providers who are developing and publishing content for dissemination via Digital Platforms. The Digital Platform shall be “accessible by design”. Trainings should emphasize on design wise digital accessibility. The trainings should cover behavioural training, assistive tools, and inclusive experience for normal as well as differently abled users.
Section 4: Registration and e-KYC
4.1. All REs shall ensure that digital KYC, e-KYC, and video KYC processes
include alternatives to accommodate differently abled users/clients. For example, human-assisted video KYC, allowing scanned document uploads, or voice-assisted KYC for visually impaired users.
4.2. KYC and client registration forms shall include a mandatory field to indicate
disability status and options to select specific provisions such as helpdesk call back for assistance. Any application of a client with disability shall be rejected by the REs only after a review by a designated human officer and the said officer shall be empowered to override automated rejections and approve applications on a case by case basis, thereby ensuring equitable access to services of the REs for persons with disabilities.
Section 5: Digital Accessibility Audits and Remediation
5.1. All REs shall initiate a comprehensive accessibility audit of their digital
platforms including websites, mobile apps, portals through International Association of Accessibility Professionals (“IAAP”). The audit shall follow

पष्ृठ सं. 10 (कुल पष्ृठ 10) Page 10 of 10 the latest WCAG, GIGW guidelines and RPwD Act and sules made thereunder and also SEBI from time to time. The said accessibility audit shall include usability testing by persons with disabilities.
5.2. Based on the audit findings, REs shall prepare and implement a plan for
remediation of audit observations.
5.3. Existing digital platforms must be upgraded to meet accessibility standards
within the transition timeline.
5.4. All REs shall conduct annual accessibility audits of their digital platforms
including websites, mobile apps, portals through IAAP certified accessibility professionals and reports shall be submitted as per the mechanism specified in direction 1.4 in Section 1 of this Annexure.
Section 6: Procurement and Technical Compliance
6.1. All newly developed/procured digital solutions shall conform to latest
WCAG, IS17802, GIGW guidelines and the provisions of the RPwD Act, 2016 and rules made thereunder. In case of Software as a Service (“SaaS”)/ customised SaaS products, vendors must seek conformance with the accessibility guidelines by conducting audit of their product/service in accordance to WCAG 2.1 (or latest) accessibility guidelines. The responsibility to ensure the accessibility of a Digital Platform shall lie with the REs.
6.2. Accessibility requirements shall be part of all Request for Proposals
(“RFPs”) and procurement contracts of the REs and evaluation criteria of the REs shall assign due weightage to accessibility readiness. -------x-------