Authored by Sethupathy Rathna Kumar
SEBI has issued a circular dated 29th August 2025 (Circular No. SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/121) (“New Circular”) extending timelines and updating reporting authorities for compliance with its earlier circular on digital accessibility for persons with disabilities (Circular No. SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111 dated 31st July 2025) (“Original Circular”). The Original Circular had mandated all regulated entities[1] (“REs”) to ensure compliance with accessibility requirements pursuant to the Rights of Persons with Disabilities Act, 2016 and allied rules.
In our last month’s edition of All Things Listed (August 2024), we had covered in detail, the compliances to be undertaken by REs for ensuring accessibility of all digital platforms operated by REs for persons with disabilities (“PwDs”). The New Circular now extends those timelines and modifies certain reporting requirements as outlined below.
Extension of Timelines
SEBI has considered representations received from REs and has granted extensions to the compliance deadlines as set out below:
| S. No. | Compliance Requirement | Original Timeline | Extended Timeline |
|---|---|---|---|
| 1 | Submission of compliance/action taken report | Aug 30, 2025 | Sept 30, 2025 |
| 2. | Submission of list of digital platforms | Aug 30, 2025 | Dec 14, 2025 |
| 3. | Appointment of IAAP-certified accessibility professionals as auditor | Sept 14, 2025 | Dec 14, 2025 |
| 4. | Conduct of accessibility audit of digital platforms | Oct 31, 2025 | April 30, 2026 |
| 5. | Remediation of audit findings and ensuring compliance | Jan 31, 2026 | July 31, 2026 |
| 6. | Annual accessibility audits and submission of final report | April 30, 2026 | April 30, 2027 |
Update to Reporting Authority
The New Circular also modifies the reporting authority for Investment Advisers (“IAs”) and Research Analysts (“RAs”). Instead of BASL and SEBI, BSE Ltd. has been designated as the reporting authority for both IAs and RAs. The updated reporting authorities are:
| S. No. | Regulated Entity | Reporting Authority |
|---|---|---|
| 1 | Stock Brokers / Depository Participants | Stock Exchanges / Depositories |
| 2. | IAs and RAs | BSE Ltd |
| 3. | Market Infrastructure Institutions (MIIs) and other REs | SEBI |
Conclusion
The New Circular provides additional time for REs to align with accessibility standards and introduces clarity on the nodal reporting authority for IAs and RAs. By extending the timelines and streamlining compliance reporting, SEBI seeks to ensure effective implementation of digital accessibility obligations while balancing operational challenges faced by REs.
[1] “Regulated Entity or RE” refers to SEBI registered/ recognised intermediaries (for example stockbrokers, mutual funds, KYC Registration Agencies, QRTAs, etc.) and Market Infrastructure Institutions (Stock Exchanges, Depositories and Clearing Corporations) regulated by SEBI.
