EquiView Blog
A Chronological Guide to SEBI's Digital Accessibility Circulars (2025-2026)
Quick answer: SEBI has issued six circulars on digital accessibility between May 2025 and July 2026, beginning with accessible digital KYC on May 23, 2025 and, most recently, extending the audit and remediation deadline to October 31, 2026 (circular dated July 31, 2026). Together they require every SEBI-regulated entity to make investor-facing digital platforms accessible to persons with disabilities. They also require audits by IAAP-certified professionals, a designated nodal officer, and a status report that was due by March 31, 2026.
The six circulars at a glance
| # | Date | Focus | Key outcome |
|---|---|---|---|
| 1 | 23 May 2025 | Digital KYC | Onboarding must be accessible and inclusive |
| 2 | 31 Jul 2025 | Core mandate | Accessibility compliance for all regulated entities, with standards and a nodal officer |
| 3 | 29 Aug 2025 | IA & RA timelines | Extended deadlines for investment advisers and research analysts; reporting authorities updated |
| 4 | 25 Sep 2025 | Timelines & formats | Compliance guidelines with milestone dates and standard submission formats |
| 5 | 8 Dec 2025 | Clarifications | Investor Charter, SCORES complaints, status report by March 31, 2026 |
| 6 | 31 Jul 2026 | Audit extension | Audit and remediation deadline extended to October 31, 2026 |
Why SEBI introduced these rules
Investors now open accounts, complete KYC, read research and trade almost entirely online. For people with visual, hearing, motor or cognitive disabilities, an inaccessible app or portal can mean exclusion from the market altogether.
The regulatory push builds on India's Rights of Persons with Disabilities Act, 2016, and on a Supreme Court judgment in April 2025 that treated digital access as part of the right to life and liberty. SEBI's circulars turn that principle into specific obligations for the securities market.
Circular 1 (May 23, 2025): Accessible digital KYC
What it did: Directed intermediaries to make digital KYC and account opening inclusive for persons with disabilities.
Why it matters: KYC is the entry point. If a blind or motor-impaired investor cannot complete onboarding independently, nothing else in your platform matters to them.
What to check: Screen reader compatibility of KYC forms, accessible OTP and verification steps, alternatives to purely visual or gesture-based steps (such as some video KYC actions), and clear error messages.
Circular 2 (July 31, 2025): The core accessibility mandate
What it did: This is the central circular. It requires SEBI-regulated entities to make their digital platforms accessible in line with the RPwD Act.
Who is covered: Stock brokers, mutual funds and AMCs, portfolio managers, depositories, clearing corporations, KYC registration agencies, market infrastructure institutions and other registered intermediaries.
Standards referenced:
- WCAG 2.1 or the latest version (in practice, teams are moving to WCAG 2.2 AA)
- Guidelines for Indian Government Websites (GIGW)
- IS 17802, the Indian standard for accessible ICT
- The RPwD Act, 2016
Governance requirements:
- Nodal officer: appoint a person responsible for accessibility compliance, audits, remediation and grievances
- Accessible documents: tagged PDFs, logical reading order, alternative text for images
Circular 3 (August 29, 2025): IA and RA timelines and reporting channels
SEBI responded to requests for more time by extending timelines for investment advisers (IAs) and research analysts (RAs), and updated who receives compliance reports.
Reporting channels
- Stock brokers and depository participants report through their stock exchange or depository
- Investment advisers and research analysts report through BSE
- Most other regulated entities report directly to SEBI
Circular 4 (September 25, 2025): Compliance guidelines, milestones and reporting formats
This circular issued the consolidated compliance guidelines. It fixed the milestone dates and set out standard formats so submissions are consistent.
Milestones (as updated by the July 2026 circular)
| Milestone | Date |
|---|---|
| Submit list of digital platforms | September 30, 2025 |
| Appoint IAAP-certified auditor | December 14, 2025 |
| Complete accessibility audit | October 31, 2026 (originally April 30, 2026) |
| Complete remediation | October 31, 2026 (originally July 31, 2026) |
| Annual audit and final report (annual compliance, within 30 days of each financial year) | April 30, 2027 |
What entities submit
- List of investor-facing digital platforms
- Details of the IAAP-certified auditor
- Initial audit report
- Final audit report after remediation
Why it matters: The formats cover platform details, audit scope, findings, remediation timelines and supporting evidence. A vague or incomplete audit report is now a compliance risk in itself.
Circular 5 (December 8, 2025): Clarifications, Investor Charter and SCORES
This circular refined the framework and added the investor-facing elements.
- Investor Charter: digital accessibility is now part of it, recognizing accessibility as an investor right
- Status report: entities must submit a readiness and compliance status report by March 31, 2026
- SCORES complaints: investors can raise accessibility complaints, and entities must resolve them as part of complaint closure
- Periodic audits: audits must be repeated by certified professionals
Circular 6 (July 31, 2026): Audit and remediation extended to October 31, 2026
Responding to representations from regulated entities and reviewing their compliance status, SEBI extended the deadline for conducting accessibility audits of digital platforms and remediating the audit findings.
- What changed: the combined audit and remediation deadline is now October 31, 2026. Earlier, the audit was due by April 30, 2026 and remediation by July 31, 2026.
- What did not change: all other provisions of the earlier circulars (dated July 31, August 29, September 25 and December 8, 2025) remain in force and mandatory.
- Why it matters: the extension is time to audit, remediate and validate fixes properly, not a pause on the framework.
Master timeline (2025-2026)
| Date | Event |
|---|---|
| May 23, 2025 | Digital KYC accessibility circular |
| July 31, 2025 | Core digital accessibility mandate |
| August 29, 2025 | Timeline extensions for IAs and RAs, and updated reporting authorities |
| September 25, 2025 | Compliance guidelines: milestone dates and reporting formats |
| September 30, 2025 | Platform list due |
| December 8, 2025 | Fifth circular with clarifications and SCORES mechanism |
| December 14, 2025 | IAAP-certified auditor to be appointed |
| March 31, 2026 | Readiness and compliance status report due |
| April 30, 2026 | Original accessibility audit deadline (extended to October 31, 2026) |
| July 31, 2026 | Original remediation deadline; sixth circular extends audit and remediation to October 31, 2026 |
| October 31, 2026 | Revised deadline: accessibility audit and remediation to be completed |
| April 30, 2027 | First annual audit compliance and final report due |
What these circulars mean in practice
- Work to the October 31, 2026 deadline: both the audit and remediation of its findings must be complete by then, and the extension changed nothing else in the framework.
- Inventory every investor-facing platform: websites, mobile apps, trading terminals, investor portals and onboarding flows, including those run by vendors on your behalf.
- Use an IAAP-certified auditor: automated scans alone will not meet the expectation. Manual testing with assistive technologies is needed.
- Remediate by severity: fix problems that block login, OTP, onboarding, orders and payments first.
- Set up governance: a nodal officer, a grievance process and accessible documents.
- Prepare for SCORES complaints: make sure your support team can log, escalate and close accessibility complaints with evidence.
- Keep re-auditing: new releases can break accessibility, so build checks into your release cycle.
For help with the audit step, read our guide on how to find an IAAP-certified accessibility auditor and our comparison of accessibility audit vs VAPT.
How EquiView can help
EquiView helps SEBI-regulated entities with accessibility audits, remediation guidance, accessible document support and compliance documentation. If you are unsure where you stand against these six circulars, we can run a readiness review and give you a prioritized fix list.
Book a free readiness consultation to see where you stand against SEBI's six accessibility circulars.
Frequently asked questions
What are SEBI's digital accessibility circulars?
They are six circulars issued between May 2025 and July 2026 that require SEBI-regulated entities to make their investor-facing digital platforms accessible to persons with disabilities, with defined standards, audits, timelines and reporting.
Which entities must comply?
Stock brokers, mutual funds and AMCs, portfolio managers, depositories and depository participants, clearing corporations, KYC registration agencies, market infrastructure institutions and other SEBI-registered intermediaries.
Which accessibility standards apply?
WCAG 2.1 or the latest version, GIGW, IS 17802 and the provisions of the RPwD Act, 2016.
Who can conduct the audit?
IAAP-certified accessibility professionals.
What were the key deadlines?
Platform list by September 30, 2025; auditor appointment by December 14, 2025; status report by March 31, 2026; audit completion and remediation by October 31, 2026 (extended from April 30, 2026 and July 31, 2026 by the circular dated July 31, 2026); first annual audit compliance by April 30, 2027.
Can investors file accessibility complaints?
Yes. Accessibility complaints can be raised through SEBI's SCORES platform, and entities must address them as part of complaint closure.
Who is the nodal officer?
The person designated by the regulated entity to oversee accessibility compliance, audits, remediation and grievance handling.
Is accessibility compliance a one-time exercise?
No. The framework expects periodic audits, so compliance has to be maintained across releases and updates.