Authored by Sethupathy Rathna Kumar
In continuation of its regulatory push towards ensuring inclusive access to securities market infrastructure, SEBI has issued a circular dated 8 December 2025 (“Clarificatory Circular”) providing further clarifications on the digital accessibility framework applicable to regulated entities (“REs”). The Clarificatory Circular builds upon SEBI’s earlier circulars dated 31 July 2025 (Circular No. SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111) and 29 August 2025 (Circular No. SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/121) on digital accessibility of investor-facing digital platforms.
In our October edition of All Things Listed titled “SEBI ISSUES CIRCULAR EXTENDING TIMELINES FOR DIGITAL ACCESSIBILITY COMPLIANCE”, we had analysed SEBI’s circular extending timelines for digital accessibility compliance and the revised reporting framework for REs. This Clarificatory Circular supplements that framework by introducing additional compliance obligations, streamlining interim reporting requirements, and strengthening investor grievance redressal mechanisms in relation to accessibility issues.
Background
SEBI’s digital accessibility framework stems from the obligation cast on market intermediaries under the Rights of Persons with Disabilities Act, 2016, requiring digital platforms to be accessible to persons with disabilities (“PwDs”). The earlier circulars had prescribed phased timelines for appointment of accessibility auditors, conduct of accessibility audits, remediation of audit findings, and periodic reporting.
Recognising the implementation challenges highlighted by REs, SEBI had extended several compliance timelines and rationalised reporting authorities. The present Clarificatory Circular seeks to further operationalise these requirements while ensuring that investor rights relating to accessibility are effectively enforced.
Key Clarifications Issued by SEBI
1. Inclusion of Digital Accessibility as an Investor Right
SEBI has clarified that the “Investors’ Right to have digital accessibility” will be expressly included in the respective Investor Charters applicable to various categories of REs. This marks a significant shift by elevating digital accessibility from a compliance obligation to an enforceable investor right.
2. Interim Compliance Reporting in lieu of Auditor Appointment
In partial modification of the earlier requirement mandating appointment of an accessibility auditor by 14 December 2025, SEBI has now permitted REs to submit a status of readiness and compliance instead. Key aspects include:
a. REs must submit platform-wise status reports for each investor-facing digital platform by 31 March 2026.
b. REs reporting directly to SEBI are required to submit the status via the designated email ID: digital_acc@sebi.gov.in
c. The reporting must be made in the format prescribed under Annexure B of the Clarificatory Circular.
This relaxation aligns with the extended timelines discussed in our October edition and provides REs with additional time to achieve full compliance without diluting regulatory oversight.
3. Accessibility-Related Complaints on SCORES
SEBI has further strengthened enforcement by enabling investors to lodge accessibility-related complaints on the SCORES platform under a dedicated “Accessibility” complaint category. Upon receipt of such complaints:
a. REs are required to remediate the accessibility issue as a pre-condition for closure of the complaint.
b. Accessibility concerns are thereby integrated into SEBI’s formal grievance redressal framework.
4. Mandatory Periodic Accessibility Audits
Notwithstanding the interim relaxation on auditor appointment timelines, SEBI has reiterated that all REs are mandatorily required to conduct periodic accessibility audits of their digital platforms, including websites, mobile applications, and portals, through certified accessibility professionals.
Reporting Authorities
The Clarificatory Circular also reiterates the revised reporting structure, which was covered in detail in our October article. In brief:
a. Stock Brokers and Depository Participants report to stock exchanges/depositories.
b. Investment Advisers and Research Analysts report to BSE Ltd.
c. Market Infrastructure Institutions and other specified REs report directly to SEBI.
Conclusion
The Clarificatory Circular reinforces SEBI’s intent to institutionalise digital accessibility as a core component of investor protection, while simultaneously addressing operational constraints faced by REs.
