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SEBI Digital Accessibility Mandate: Requirements, Applicability & Compliance (India)

The Securities and Exchange Board of India (SEBI) has established digital accessibility as a regulatory requirement for entities under its purview, recognizing that equal access to financial information and services is fundamental to investor protection. This mandate addresses the exclusion of persons with disabilities from digital financial platforms and aligns India's capital markets infrastructure with constitutional principles of equality and non-discrimination. For SEBI-regulated entities, digital accessibility is no longer a discretionary initiative. It is a compliance obligation tied to investor rights, legal accountability, and regulatory standing. Organizations must ensure their websites, mobile applications, trading platforms, and digital documents meet prescribed accessibility standards through qualified audits and documented remediation. The investor-protection rationale is clear: financial markets depend on informed participation. When digital barriers prevent persons with disabilities from accessing disclosures, executing trades, or reviewing portfolio information, the integrity of market participation is compromised.

Why SEBI Mandated Digital Accessibility

SEBI's primary mandate is to protect the interests of investors and ensure orderly development of securities markets. Digital accessibility falls directly within this mandate because exclusionary digital design prevents a significant portion of India's population from participating in capital markets on equal terms.
India has approximately 26.8 million persons with disabilities, many of whom face systematic barriers when accessing financial platforms. These barriers include inaccessible PDFs, keyboard-inaccessible trading interfaces, missing alternative text for charts, and non-compliant form controls. Such exclusions are not merely inconvenient—they constitute a denial of financial agency and economic opportunity.
SEBI's accessibility mandate aligns with India's obligations under the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD), which India ratified in 2007. It also reflects global recognition that accessible digital infrastructure is essential to financial inclusion, a priority area for Indian regulators across banking, insurance, and capital markets.

Legal and Regulatory Framework Governing SEBI Accessibility Compliance

IAAP (International Association of Accessibility Professionals) is the world's leading accessibility certification body. IAAP-certified auditors bring:

Rights of Persons with Disabilities Act, 2016

The Rights of Persons with Disabilities Act, 2016 (RPwD Act) is the primary legislation governing accessibility in India. Section 42 of the Act explicitly mandates that all content published by or on behalf of establishments be made accessible to persons with disabilities. Section 46 requires compliance with accessibility standards notified by the Central Government.SEBI-regulated entities fall within the definition of 'establishments' under the RPwD Act, making them legally obligated to ensure digital accessibility. Non-compliance exposes organizations to potential penalties under Sections 89 and 92 of the Act.

SEBI Circulars and Regulatory Directions

SEBI has issued circulars and directives requiring intermediaries and market infrastructure institutions to ensure their digital platforms are accessible. These circulars reference both Indian and international accessibility standards and emphasize the need for third-party audits by qualified professionals. The regulatory expectation is that accessibility is implemented proactively, not reactively. SEBI-regulated entities are expected to integrate accessibility into their digital governance frameworks, conduct regular assessments, and maintain compliance documentation.

IS 17802:2021 (Indian Accessibility Standard)

IS 17802:2021 is the Bureau of Indian Standards' national standard for accessibility of Information and Communication Technology (ICT) products and services. This standard is harmonized with international accessibility standards and applies to websites, mobile applications, software, and digital documents. For SEBI-regulated entities, IS 17802:2021 provides the technical benchmark against which digital platforms are evaluated. Compliance with this standard is often referenced in procurement guidelines, regulatory audits, and legal proceedings.

Guidelines for Indian Government Websites (GIGW 3.0)

While GIGW 3.0 was initially developed for government websites, it has become a de facto reference for accessibility in India's regulatory environment. SEBI-regulated entities are expected to align with GIGW 3.0 principles, particularly in areas such as document accessibility, form design, and multimedia content. GIGW 3.0 emphasizes user-centered design, testing with assistive technologies, and adherence to WCAG principles adapted for the Indian context.

WCAG 2.1 and WCAG 2.2 Level AA

The Web Content Accessibility Guidelines (WCAG), published by the World Wide Web Consortium (W3C), represent the global consensus on web accessibility. WCAG 2.1 Level AA is the minimum conformance level required under most accessibility regulations worldwide, including in India. WCAG 2.2, released in October 2023, introduces additional success criteria that address mobile accessibility, cognitive disabilities, and low-vision needs. SEBI-regulated entities are expected to align with WCAG 2.1 Level AA as a baseline, with progressive adoption of WCAG 2.2 criteria where applicable.

Who Must Comply With the SEBI Digital Accessibility Mandate

SEBI's accessibility mandate applies broadly across the securities market ecosystem. The following categories of entities are subject to compliance obligations.

SEBI-Registered Intermediaries
Stockbrokers, depository participants, investment advisers, portfolio managers, mutual fund distributors, and research analysts are all required to ensure their digital platforms meet accessibility standards. This includes both customer-facing platforms and internal digital systems used for compliance and reporting.
Investor-Facing Digital Platforms
Any digital platform through which investors access information, execute transactions, or manage portfolios must be accessible. This includes trading terminals, online account portals, mobile trading applications, and robo-advisory platforms.
Mobile Applications and Trading Platforms
Mobile applications are explicitly covered under accessibility mandates. Given the prevalence of mobile-first investing in India, SEBI expects that mobile trading apps, mutual fund apps, and demat account management apps comply with mobile accessibility standards, including support for screen readers, touch target sizing, and gesture alternatives.
Public Websites, Portals, and Digital Communications
Corporate websites, investor education portals, disclosure repositories, and digital investor communications (including PDFs, presentations, and video content) must be accessible. This includes annual reports, offer documents, scheme information documents, and regulatory filings published in digital formats.

What SEBI Expects From Regulated Entities

SEBI's regulatory expectations go beyond surface-level compliance. Organizations are expected to demonstrate measurable, verifiable accessibility aligned with recognized standards.

Accessibility Audits by Qualified Professionals
SEBI expects accessibility audits to be conducted by professionals with recognized credentials. The International Association of Accessibility Professionals (IAAP) is the global credentialing body for accessibility practitioners. Audits conducted by IAAP-certified professionals carry regulatory credibility because they reflect adherence to established methodologies and ethical standards. Automated scanning tools alone are insufficient. SEBI expects manual testing with assistive technologies, expert evaluation against WCAG success criteria, and contextualized recommendations that reflect Indian regulatory requirements.
WCAG AA Compliance Across Digital Assets
WCAG 2.1 Level AA conformance is the minimum standard expected. This means all digital assets—websites, mobile apps, PDFs, multimedia content—must meet the 50 success criteria defined at Level A and Level AA. Organizations must address perceivability (alternative text, captions, color contrast), operability (keyboard navigation, focus management), understandability (clear language, predictable behavior), and robustness (compatibility with assistive technologies).
Formal Gap Identification and Remediation
Compliance is not achieved through audits alone. SEBI expects a documented remediation process that addresses identified gaps systematically. This includes prioritization frameworks, remediation timelines, developer training, and quality assurance protocols. Gap reports should clearly identify non-conformant elements, explain the impact on users with disabilities, and provide technical remediation guidance aligned with WCAG success criteria.
Submission-Ready Compliance Documentation
Regulated entities must maintain compliance documentation that can be presented to SEBI or produced in legal proceedings. This includes audit reports, remediation logs, testing evidence, and accessibility statements published on digital platforms. Accessibility statements should declare the conformance level achieved, identify any known limitations, provide contact information for accessibility feedback, and outline the organization's ongoing commitment to accessibility.

Common Misinterpretations About SEBI Accessibility Compliance

Regulatory clarity is essential. Several misconceptions persist about the scope and nature of SEBI's accessibility mandate.

Is accessibility only required for government websites?

No. While government websites are subject to specific accessibility mandates under GIGW, SEBI-regulated entities in the private sector are equally obligated under the RPwD Act and SEBI circulars. The obligation applies to all establishments serving the public, including commercial entities in the securities market.

Are PDFs and documents excluded from accessibility requirements?

No. PDF documents, Excel spreadsheets, PowerPoint presentations, and other digital documents fall within the scope of accessibility mandates. Annual reports, offer documents, scheme information documents, and regulatory disclosures published in PDF format must be accessible, including proper tagging, reading order, alternative text, and table structure.

Are automated tools sufficient for demonstrating compliance?

No. Automated accessibility scanning tools detect only a subset of accessibility issues—typically 25 to 40 percent of WCAG violations. Manual testing by qualified auditors using assistive technologies is essential for comprehensive evaluation. SEBI expects audits to include keyboard navigation testing, screen reader testing, and cognitive accessibility review.

Does mobile app accessibility differ from website accessibility?

Yes. While the underlying principles are consistent, mobile accessibility introduces platform-specific considerations such as touch target sizing, gesture alternatives, orientation support, and integration with mobile-specific assistive technologies like VoiceOver (iOS) and TalkBack (Android). Both iOS and Android apps must meet WCAG 2.1 Level AA mobile success criteria.

Does mobile app accessibility differ from website accessibility?

Yes. While the underlying principles are consistent, mobile accessibility introduces platform-specific considerations such as touch target sizing, gesture alternatives, orientation support, and integration with mobile-specific assistive technologies like VoiceOver (iOS) and TalkBack (Android). Both iOS and Android apps must meet WCAG 2.1 Level AA mobile success criteria.

Consequences of Non-Compliance

Non-compliance with SEBI's digital accessibility mandate exposes organizations to regulatory, legal, and reputational risks.

Regulatory risk includes potential enforcement actions by SEBI, which may involve directives to remediate, restrictions on digital services, or penalties for failure to meet investor protection standards. SEBI's regulatory framework emphasizes accountability, and accessibility non-compliance may be viewed as a failure to safeguard investor interests.

Legal exposure arises under the RPwD Act, which provides for penalties and compensation for discrimination against persons with disabilities. As digital accessibility jurisprudence develops in India, organizations face increasing risk of litigation, complaints to accessibility authorities, and adverse publicity.

Reputational impact can be significant. In an era where environmental, social, and governance (ESG) considerations influence investor decisions, accessibility non-compliance signals poor governance and disregard for inclusivity. Organizations that fail to ensure accessible digital platforms risk damage to brand reputation and stakeholder trust.

Investor trust implications are direct. When persons with disabilities cannot access trading platforms, review portfolio statements, or participate in shareholder meetings conducted digitally, trust in the organization—and by extension, the broader market—erodes. Accessibility is a precondition for equitable market participation.

How Organizations Typically Approach SEBI Accessibility Compliance

A structured compliance approach reduces risk and ensures verifiable outcomes. Most organizations follow a phased methodology.

Discovery
It involves scoping digital assets subject to accessibility requirements, identifying stakeholder roles, and establishing compliance objectives aligned with SEBI expectations and applicable standards.
Audit
It is conducted by qualified professionals who evaluate digital platforms against WCAG 2.1 Level AA, IS 17802:2021, and relevant SEBI directives. Audits produce detailed gap reports that document non-conformant elements, explain user impact, and provide remediation guidance.
Remediation
It addresses identified gaps through code-level fixes, content updates, design modifications, and workflow changes. Development teams work from prioritized remediation plans, typically addressing critical barriers first, followed by moderate and minor issues.
Validation
It confirms that remediation efforts have achieved the intended accessibility outcomes. This involves re-testing remediated elements, conducting end-to-end user journey testing, and validating compliance with WCAG success criteria.
Ongoing compliance
It embeds accessibility into organizational governance. This includes accessibility policies, developer training programs, procurement standards for third-party tools, and periodic audits to detect regressions.

Organizations seeking SEBI accessibility compliance often engage firms that provide audit, remediation, and validation services through IAAP-certified professionals. Flexxited, for example, offers structured accessibility audit programs aligned with Indian regulatory requirements. Further details are available at /sebi-digital-accessibility-audit.

FAQs

Everything you need to know about SEBI Digital Accessibility Mandate.

Next Steps for SEBI-Regulated Entities

Organizations subject to SEBI's digital accessibility mandate should begin with a comprehensive understanding of their current accessibility posture. This involves inventorying digital assets, evaluating existing accessibility measures, and identifying gaps relative to WCAG 2.1 Level AA and IS 17802:2021.

Engaging qualified accessibility professionals to conduct a formal audit provides the evidentiary foundation for compliance. Audit findings should inform a structured remediation plan with defined timelines, accountability mechanisms, and validation protocols.

Organizations seeking guidance on SEBI accessibility audit processes, IAAP-certified audit services, and compliance documentation can review detailed information at /sebi-digital-accessibility-audit.

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