In a significant step towards inclusion in the securities market, SEBI has issued a circular titled ‘Rights of Persons with Disabilities Act, 2016 and Rules made thereunder – Mandatory Compliance by all Regulated Entities’ (“Circular”) dated 31st July 2025 (SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111) mandating accessibility of all digital platforms operated by SEBI regulated entities (“REs”) for persons with disabilities (“PwDs”). The move follows the Hon’ble Supreme Court’s judgment in Pragya Prasun and Ors. v. Union of India and Ors. and Amar Jain v. Union of India and Ors. (April 30, 2025), which held that the right to digital access is intrinsic to the right to life and personal liberty. The Circular sets out the following compliance measures:

1.Scope and Applicability: The circular applies to all REs, including stock exchanges, depositories, clearing corporations, stockbrokers, mutual funds, portfolio managers and other SEBI-registered intermediaries. All digital platforms (websites, mobile apps, portals, etc.) must comply with the Rights of Persons with Disabilities Act, 2016, associated rules and standards such as Web Content Accessibility Guidelines (WCAG) 2.1, Guidelines for Indian Government Websites (GIGW) and IS 17802: Indian Standards on Accessibility Requirements for Information and Communication Technology Products and Services.;

2.Institutional Arrangements: REs must designate a senior ‘Nodal Officer’ who shall be responsible for digital accessibility compliance, establish an accessibility grievance redressal mechanism and ensure annual compliance reporting to the relevant authority.

3.Mandatory Features: Digital platforms must include Indian Sign Language (ISL) videos, closed captioning, descriptive audio, and alt text for images. Documents must follow accessible PDF standards (tagging, headings, logical reading order).

4.Inclusive Onboarding: e-KYC, digital KYC, and video KYC processes must offer alternative methods such as human-assisted verification, voice-assisted KYC and document uploads. REs must have safeguards against automated rejection of applications from PwDs without human review.

5.Audits and Remediation: SEBI has given the following time-bound compliance roadmap to ensure accessibility is achieved.

• Within 1 month: Submit a list of digital platforms and a compliance/ action-taken report.
• Within 45 days: Appoint IAAP-certified accessibility auditors.
• Within 3 months: Conduct a full accessibility audit.
• Within 6 months: Remediate audit findings and achieve compliance.
  Annual accessibility audits and usability testing by PwDs are mandatory thereafter.

6.Procurement and Technical Compliance: All newly developed or procured digital solutions, including SaaS products must comply with accessibility standards. Request for Proposals (RFPs) and procurement contracts must include accessibility as an evaluation criterion.

Conclusion

This circular is a step towards a more digitally accessible securities market for PwDs as it mandates defined timelines, certified audits, and ‘accessibility by design’ principles. It embeds inclusivity into market infrastructure and requires REs to invest in technology, training, and process redesigns to meet these obligations, ultimately fostering a more equitable financial ecosystem.