On 30 April 2025, the Supreme Court of India held that digital access is part of the right to life under Article 21. The cases behind it — Pragya Prasun and Amar Jain — were brought by acid attack survivors who couldn't complete "blink to verify" liveness checks, and by a blind petitioner shut out of digital KYC. Three months later, SEBI turned that judgment into obligations for the entire securities market.
If you run a broking app, a mutual fund platform, an advisory practice, or anything else SEBI regulates, this now applies to you. Below is a plain reading of the circulars — what they require, the timeline as it stands today, and how we'd approach it if we were in your seat.
The short version
- Every SEBI-regulated entity must make its websites, mobile apps, portals, and documents accessible to persons with disabilities.
- The baseline is WCAG 2.1 or later, GIGW, IS 17802, and the Rights of Persons with Disabilities Act, 2016.
- Audits must be carried out by IAAP-certified accessibility professionals and must include usability testing by persons with disabilities.
- KYC must offer accessible alternatives, and no application from a person with a disability can be rejected without human review.
- You need a Nodal Officer, an accessibility-specific grievance channel, staff training, and accessibility written into vendor contracts.
Where this comes from
The main circular is SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111, dated 31 July 2025, titled "Rights of Persons with Disabilities Act, 2016 and rules made thereunder — mandatory compliance by all Regulated Entities". It draws on Sections 40, 42, and 46 of the RPwD Act, which cover accessibility, access to information and communication technology, and time limits for service providers.
It didn't arrive out of nowhere. In November 2024, in Rajive Raturi v. Union of India, the Supreme Court ruled that accessibility standards under the RPwD Rules had to be mandatory rather than advisory. The April 2025 judgment then applied that thinking to digital services specifically. SEBI's circular is the securities market's response, and the RBI made parallel changes to its own KYC directions in August 2025.
Who it applies to
The circular covers every "Regulated Entity": SEBI-registered or recognised intermediaries, and market infrastructure institutions. In practice, that includes:
- Stock brokers and depository participants
- Mutual funds and asset management companies
- Investment advisers and research analysts
- Portfolio managers, AIFs, and venture capital funds
- Registrars and transfer agents, and KYC registration agencies
- Stock exchanges, depositories, and clearing corporations
- Custodians, merchant bankers, debenture trustees, credit rating agencies, and bankers to an issue
Where you report depends on who you are. Brokers and depository participants report through their exchange or depository, and investment advisers and research analysts report to BSE Ltd. Everyone else, including the market infrastructure institutions, reports to SEBI directly.
Which standards count
SEBI lists four references as the baseline for compliance: WCAG 2.1 or the latest version, the latest Guidelines for Indian Government Websites (GIGW), IS 17802 (India's ICT accessibility standard), and the RPwD Act and Rules.
The circular itself doesn't name a conformance level, but SEBI's reporting format asks whether each platform meets "a minimum level of accessibility at AA level" under the latest WCAG. So AA is the target. You'll see some vendors claim SEBI mandates WCAG 2.2 — it doesn't say that. Still, "or latest version" points to 2.2 today, and auditing against 2.2 AA means you won't be caught out when the reference moves. That's what we'd recommend.
What you actually have to do
Governance
Your MD, managing partner, or proprietor must review and approve compliance. A senior officer must be designated as Nodal Officer and serves as SEBI's point of contact. If nobody is named, your Compliance Officer or proprietor is treated as the Nodal Officer by default.
Grievances
You need a grievance mechanism specific to accessibility — channels like email, a helpline, and web forms that persons with disabilities can actually use, with a route to escalate to senior officers. Since December 2025, investors can also raise accessibility complaints on SCORES, and a complaint isn't closed until the problem is fixed.
Websites, apps, and documents
Digital platforms must be accessible by design. The circular calls out captions, audio description, alt text, and Indian Sign Language — its own example is a KYC explainer video with both captions and ISL. Circulars, notices, and investor documents must be accessible too: tagged PDFs, a logical reading order, proper headings, and alt text. For most firms, the PDF backlog turns out to be bigger than the website.
KYC and onboarding
This is where the Supreme Court case started, and SEBI is specific about it. Digital KYC, e-KYC, and video KYC must offer alternatives, such as human-assisted video KYC, scanned document uploads, or voice-assisted KYC for people with visual impairments. KYC forms need a disability-status field and options like a helpdesk call-back. An application from a person with a disability can be rejected only after review by a designated human officer, who can override an automated rejection.
Audits
You must commission a comprehensive audit of your websites, apps, and portals by IAAP-certified accessibility professionals, and it must include usability testing by persons with disabilities. An automated scan doesn't meet that bar, and neither does a checklist review on its own. The findings feed a remediation plan, and the audits recur.
Training and procurement
Staff, and the third-party vendors who build or publish your content, need accessibility training. Any new or procured solution must conform to WCAG, IS 17802, GIGW, and the RPwD Act, and accessibility should be written into RFPs and contracts and weighted in evaluation. Crucially, SEBI is explicit that responsibility for a platform's accessibility lies with you — not your SaaS vendor.
The timeline, as it stands
The dates have moved a few times. Here's the sequence:
- 31 July 2025: the main circular is issued, effective immediately.
- 29 August 2025: first extension. Platform lists and action-taken reports are due by 30 September 2025, and investment adviser and research analyst reporting moves to BSE.
- 25 September 2025: compliance guidelines set out reporting formats, including the auditor's IAAP ID, and ask for one consolidated audit report per entity.
- 8 December 2025: clarification. A readiness and compliance status for each platform is due by 31 March 2026, replacing the earlier auditor-appointment deadline, and accessibility complaints move onto SCORES.
- 31 July 2026: latest extension. Audit and remediation are now due by 31 October 2026, with all other provisions unchanged.
- 30 April 2027: first annual compliance reporting.
Three common misreadings
- "Our vendor handles accessibility." SEBI puts the responsibility on the regulated entity. Ask your vendors for their audit reports, but the obligation stays with you.
- "An automated scan will do." The circular requires IAAP-certified professionals and usability testing by persons with disabilities. A scanner report meets neither requirement.
- "It's just the website." Mobile apps, portals, PDFs, videos, KYC flows, and grievance channels are all in scope.
How we'd approach it
- List every digital platform you run: websites, apps, client portals, KYC flows, and wherever your documents live.
- Confirm your Nodal Officer and put your MD's sign-off process in place.
- Audit your highest-risk journeys first — account opening and KYC, login, placing an order or investing, and raising a complaint.
- Run usability sessions on those same journeys with people who use screen readers, magnification, and other assistive technology.
- Fix whatever blocks people outright first, then work down by severity. Keep a record of what you fixed and when.
- Clear the PDF backlog, starting with investor-facing documents.
- Set up the accessibility grievance channel, and test it with assistive technology.
- Add accessibility clauses to vendor contracts, and ask existing vendors for their audit evidence.
- Train the people who design, build, and publish your content.
- Put the next audit in the calendar now, so 30 April 2027 isn't a scramble.
If 31 October feels close, it is. But this is doable in stages, and every fix you make helps a real investor get through your product today — which is the point of all of it.