- What changed (Sep 30 filing extension) & who must comply
- Checklist you can tick off today
- Budgets & vendor notes (IAAP auditors, docs, ISL/captions)
- Template wording for your submission & website footer
The short
- Scope: Applies to all SEBI Regulated Entities (brokers, AMCs, RTAs/QRTAs, KRAs, MIIs, depositories, etc.). Baselines: WCAG 2.1+, GIGW, IS 17802, annual IAAP-certified audits & grievance redressal.
- By Sep 30, 2025: File list of digital platforms + compliance / action-taken report (extension from Aug 30).
- Next gates: Appoint IAAP auditor by Dec 14, 2025 → complete audit by Apr 30, 2026 → remediate by Jul 31, 2026 → annual report by Apr 30, 2027.
Who must file & to whom
- Brokers/DPs: File to your stock exchange/depository.
- Investment Advisers / Research Analysts: File to BSE Ltd. (updated authority).
- Others (incl. AMCs, KRAs, RTAs/QRTAs, MIIs): File to SEBI as specified.
Quick checklist (copy/paste)
File by Sep 30
- Inventory all digital platforms (websites, mobile apps, portals, onboarding flows, PDF content).
- Prepare Action-Taken Report against circular clauses (institutional arrangements, training, audits, grievance).
- Nominate Nodal Officer (senior officer/Compliance) and enable an accessibility grievance channel.
Start now for next gates
- Engage IAAP-certified accessibility auditor; book audit slots early.
- Bake WCAG 2.1 AA+ into dev sprints; fix PDFs (tagging, alt text, reading order).
- Include ISL/captions/audio-description in investor videos; update RFPs to include accessibility.
Deadlines at a glance
| Requirement | Original | Revised |
|---|---|---|
| Submit list of digital platforms + compliance/action-taken report | Aug 30, 2025 | Sep 30, 2025 |
| Appoint IAAP-certified auditor | Sep 14, 2025 | Dec 14, 2025 |
| Complete accessibility audit | Oct 31, 2025 | Apr 30, 2026 |
| Remediate audit findings | Jan 31, 2026 | Jul 31, 2026 |
| Annual accessibility report (CEO/CTO sign-off) | Apr 30, 2026 | Apr 30, 2027 |
Source SEBI circular (Jul 31, 2025) + extension circular (Aug 29, 2025).
Budgets (illustrative; tune to scope)
| Org profile | Audit (IAAP) | Remediation (dev/design/docs) | ISL/Captions & training |
|---|---|---|---|
| Small broker / RIA (1 site + 1 app) | ₹3–7 lakh | ₹8–15 lakh | ₹2–5 lakh |
| Mid AMC / RTA (multi-site + app + PDFs) | ₹12–25 lakh | ₹25–60 lakh | ₹6–12 lakh |
| MII / large platform (complex flows) | ₹30–60 lakh | ₹1.0–1.5 crore | ₹15–30 lakh |
Vendor notes
- Auditors: Prioritize IAAP-certified teams with PwD usability testing.
- Tooling: Automated scans help, but manual audits drive compliance. Ensure PDF tagging and mobile gestures are covered.
- Docs & video: Standardize accessible templates; pre-book captions/ISL vendors for earnings/webinars.
Template wording (use as base)
1) Board / Senior Officer attestation (for submission)
We confirm that [Entity Name] has inventoried all investor-facing digital platforms and initiated compliance with SEBI’s Digital Accessibility Circular (SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111). A Nodal Officer has been designated. An IAAP-certified auditor will be appointed by Dec 14, 2025; the audit will be completed by Apr 30, 2026, followed by remediation by Jul 31, 2026. We will submit the annual accessibility report within 30 days of financial year-end.
2) Accessibility notice (for website/app footer)
We are committed to inclusive access. If you face difficulty using our website/app, please write to accessibility@[domain] or call [phone]. We provide ISL interpretation, captions, audio description, and alternative onboarding support on request.
Penalties & enforcement (practical view)
Non-compliance can trigger regulatory action under the SEBI Act and directions via your reporting authority. Beyond penalties, operational risk is immediate: blocked onboarding, investor complaints, and reputational damage. Treat this like CSCRF-grade hygiene: audit → fix → train → monitor annually.