India: SEBI Mandates Digital Accessibility for all Regulated Entities

Authors: Avik Biswas, Ivana Chatterjee and Varun Rao

The Supreme Court of India, in its judgment dated April 30, 2025, in the matter of Pragya Prasun & Ors. Vs. Union of India and Ors. and Amar Jain vs. Union of India & Ors., pertaining to Digital Accessibility for persons with disabilities, has inter alia held that the right to digital access is an intrinsic component of the right to life and personal liberty. The Supreme Court acknowledged the discriminatory impact of electronic KYC (Know Your Customer) practices on persons with disabilities (such as persons with blindness or low vision) and acid attack survivors (who suffer from facial disfigurement or severe burns) or similarly placed individuals. Pursuant to this, it mandated the Central Government, its ministries, the Reserve Bank of India, SEBI, and the Telecom Authority of India to frame and enforce appropriate accessibility standards for all.

In light of the above, on 31 July 2025, the SEBI issued a circular mandating Regulated Entities to comply with the prescribed digital accessibility requirements (discussed below) and certain provisions of the Rights of Persons with Disabilities Act, 2016 and its corresponding rules (“RPWD Law”). The intent of the circular is to provide for an inclusive digital ecosystem in the securities market not only to persons with blindness and low vision or acid attack survivors suffering from permanent facial/eye disfigurement but also to similarly placed individuals.

For the purpose of the circular, the term “Digital Accessibility” has been explained to mean “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.

 

The key provisions of the circular have been set out below:

a. The digital platforms of a Regulated Entity should be compliant with the RPWD Law, specifically with regard to the following provisions:

• Section 40 of the RPWD Law- Accessibility
• Section 42 of the RPWD Law- Access to information and communication technology
• Section 46 of the RPWD Law- Time limit for accessibility by service providers
• Rule 15(1)(c) of the Rights of Persons with Disabilities Rules, 2017- Rules for Accessibility

 

b. Regulated Entities are required to ensure that their digital platforms and content published on such digital platforms adhere to the accessibility standards and guidelines, including:

• Web Content Accessibility Guidelines 2.1 or the latest version
• Accessibility guidelines as described in the latest version of the Guidelines for Indian Government Websites
• IS 17802: Indian Standards on Accessibility Requirements for Information and Communication Technology Products and Services

 

c. The digital platforms of the Regulated Entities 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. All circulars, notices, and investor documents published on the digital platforms of the Regulated Entities (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. The Regulated Entities 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), Regulated Entities should comply with those as well.

 

d. Regulated Entities must ensure that training modules on digital accessibility (including websites, mobile applications, and related platforms) form an integral part of all internal training programs for employees and third-party service providers involved in developing and publishing content on digital platforms. Such platforms shall be designed to be “accessible by design.” The training should emphasise accessibility in design and functionality, and cover behavioural sensitisation, use of assistive technologies, and creation of inclusive user experiences for both persons with disabilities and other users.

 

e. All Regulated Entities must 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.

 

f. All Regulated Entities must undertake a comprehensive accessibility audit of their digital platforms, including websites, mobile applications, and portals, through professionals accredited by the International Association of Accessibility Professionals (“IAAP”). Such audits shall be conducted in accordance with the latest Web Content Accessibility Guidelines (WCAG), the Guidelines for Indian Government Websites (GIGW), the RPWD Law, as well as directions issued by SEBI from time to time. The audit shall mandatorily include usability testing by persons with disabilities. Based on the audit findings, Regulated Entities shall prepare and implement a remediation plan to address the observations identified. Existing digital platforms shall be upgraded to comply with prescribed accessibility standards within the stipulated transition timeline. All Regulated Entities shall conduct annual accessibility audits of their digital platforms, including websites, mobile applications, and portals, through IAAP-certified accessibility professionals. The audit reports shall be submitted in accordance with the provisions of the circular.

 

g. The Managing Director or the Managing Partner or the proprietor of the Regulated Entities shall be responsible for ensuring compliance with the provisions of the circular. Regulated Entities must also designate any senior officer as the Nodal Officer for digital accessibility compliance. The primary roles and responsibilities of the Nodal Officer shall include ensuring digital accessibility for all investors by overseeing activities such as conducting accessibility audits, addressing and mitigating audit findings, implementing applicable accessibility guidelines, and ensuring timely redressal of grievances. The Nodal Officer shall also act as the designated point of contact for SEBI on all matters relating to digital accessibility.

 

h. A dedicated grievance redressal mechanism for accessibility-related issues shall be established by the Regulated Entities. The grievance channels—such as email, helpline, and web forms—must be designed to be user-friendly and accessible for persons with disabilities (PWDs). The mechanism shall also provide for the escalation of unresolved complaints to designated senior officers.

 

i. All newly developed or procured digital solutions shall comply with the latest WCAG, IS17802, GIGW guidelines, and the RPWD Law. In case of SaaS/customised SaaS products, vendors must ensure conformance through WCAG-based audits, with Regulated Entities bearing ultimate responsibility; accordingly, accessibility requirements shall be incorporated into all RFPs, procurement contracts, and evaluation criteria.

Key Action Points for Human Resources and In-house Counsel

All Regulated Entities must review their existing practices and procedures and take necessary steps to ensure compliance with the Circular. Key requirements include making digital platforms accessible in line with prescribed standards, conducting training on digital accessibility, designating a Nodal Officer, and establishing a dedicated grievance redressal mechanism, among other measures.

 

 

 

 

 

 

¹The Gratuity Act applies to establishments where 10 or more persons are employed or were employed in the last 12 months in the preceding year. Section 4A of the Gratuity Act empowers the State Governments to frame rules requiring employers to mandatorily obtain an insurance policy that covers their liabilities under the legislation. 

²W.P. Nos. 9358/2024 and other connected petitions.