2025-12-08

Clarification on the Digital Accessibility circulars of SEBI

The Securities and Exchange Board of India (SEBI) issued this circular to clarify digital accessibility requirements for Regulated Entities (REs) and postpone the mandatory appointment of accessibility auditors. REs must submit a status of readiness and compliance for their digital platforms by March 31, 2026, to specified reporting authorities instead of meeting the earlier December 2025 deadline. Additionally, the regulation mandates that accessibility complaints be lodged via SCORES and requires periodic accessibility audits of all investor-facing digital platforms by certified professionals.

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Page 1 of 4 CIRCULAR HO/13/19/13(2)2025-ITD-1_VIAP/I/187/2025 December 08, 2025 To, All Recognised Stock Exchanges All Recognised Clearing Corporations All Registered Depositories All Registered Intermediaries Association of Mutual Funds in India (AMFI) Association of Portfolio Managers in India (APMI) BSE Limited (Investment Adviser Administration and supervisory body-IAASB) BSE Limited (Research Analysts Administration and supervisory body-RAASB) Reference: S/N Circular No. Issue Date 1 SEBI/HO/ITD-1/ITD_VIAP/P/CIR/ 2025/111 July 31, 2025 2 SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/121 August 29, 2025 3 SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/131 September 25, 2025 Sir/Madam, Subject: Clarification on the Digital Accessibility circulars of SEBI

  1. Clarification is hereby issued on the above referenced SEBI circulars on Digital accessibility requirements in Digital Platforms of Regulated Entities(REs).
  2. The “Investors’ Right to have digital accessibility” will be included in the respective Investor Charters applicable to various REs, published by SEBI.
  3. REs are required to carry out the following compliance: a. Instead of meeting the compliance requirement for appointment of accessibility auditor by December 14, 2025, REs shall submit a status of their readiness and compliance to the accessibility requirements for

Page 2 of 4 each of their digital platforms latest by March 31, 2026 to the specified reporting authorities (refer Annexure A). The REs reporting to SEBI shall share the status on the email id digital_acc@sebi.gov.in. b. REs may refer to Annexure B for format of submitting a status of readiness and compliance to the accessibility requirements for each of their investor facing digital platforms. c. Any investor facing accessibility related issues on digital platforms of REs, shall be able to lodge accessibility related complaints against REs on SCORES. A complaint category related to “Accessibility” is already provisioned in SCORES. In response to the accessibility related complaint, the RE shall remediate the accessibility related issue for the closure of the complaint. d. All REs shall conduct periodic accessibility audits of their digital platforms including websites, mobile apps and portals through certified accessibility professionals 4. This circular is being issued in exercise of powers conferred under Section 11 (1) of the Securities and Exchange of India Act, 1992, to protect the interests of investors in securities and to promote the development of, and to regulate the securities market. 5. This circular is issued with the approval of Competent Authority. 6. This circular is available on SEBI website at www.sebi.gov.in under the category “Legal” and drop “Circulars”. Yours faithfully, Deepankar Chatterjee Deputy General Manager Phone: 022-26449643 Email: deepankarc@sebi.gov.in

Page 3 of 4 Annexure A Specified reporting authorities Table 1: Specified reporting authorities for REs S/N Regulated Entity Reporting Authority 1 Stock Brokers/ Depository Participants Stock Exchanges/Depositories 2 Investment Advisor (“IAs”) and Research Analysts (“RAs”) BSE Ltd. 3 MIIs and rest of the REs SEBI Table 2: List of REs submitting compliance directly to SEBI S/N REs submitting compliance directly to SEBI Concerned Departments 1 Alternative Investment Funds(AIFs) AFD 2 Bankers to an Issue (BTI) and Self Certified Syndicate Banks (SCSBs) CFD 3 Clearing Corporations MRD 4 Collective Investment Schemes(CIS) IMD 5 Credit Rating Agencies (CRAs) DDHS 6 Custodians AFD 7 Debenture Trustees (DTs) DDHS 8 Depositories MRD 9 KYC Registration Agencies (KRAs) MIRSD 10 Merchant Bankers (MBs) CFD 11 Mutual Funds (MFs)/ Asset Management Companies (AMCs) IMD 12 Portfolio Managers IMD 13 Registrar to an Issue and Share Transfer Agents (RTAs) MIRSD 14 Stock Exchanges MRD 15 Venture Capital Funds (VCFs) AFD

Page 4 of 4 Annexure B Format of submitting a status of readiness and compliance to the accessibility requirements for digital platforms – Applicable to all REs. Subject: [RE Registration No.]-[RE name]-[RE category] -Submission of status of readiness and compliance to the accessibility requirements for digital platforms Body: Table 1: Digital platform wise accessibility Sl. No. URL of digital platform Is minimum level of accessibility at AA level as per latest WCAG guidelines (Yes / No) Remarks on Status of readiness and compliance to the accessibility requirements 1 2 3 4 5