Accessibility Audit for SEBI‑Regulated Entities: A Simple Step‑by‑Step Guide

Making your digital platforms usable for persons with disabilities isn’t just good practice—it’s now mandatory for all SEBI‑regulated entities. This guide walks you through exactly what to do, by when, and how to stay compliant.

What counts as a “digital platform”?

Your website, web portals, mobile apps, and any client‑facing digital touchpoints used by investors or clients. The circular applies to all SEBI‑regulated entities (brokers, RAs, MIIs, etc.).

Your compliance timeline (do these on time)

• Within 1 month of circular date:

  1. Submit a list of all investor‑facing digital platforms; 2) Submit a compliance/action‑taken report.

• Within 45 days: Appoint an IAAP‑certified accessibility auditor.

• Within 3 months: Get your accessibility audit done for all platforms.

• Within 6 months: Fix (remediate) all audit findings and meet the requirements.

  
  

Step 1: Appoint your Accessibility Nodal Officer

Designate a senior, accountable person to own accessibility, publish their contact details, and make them the point‑of‑contact for SEBI. For RAs: the individual RA can be the nodal officer; for non‑individuals, pick the principal officer/MD/partner or a trained designee.

Publish on your website: name, email, phone; plus an accessibility grievance escalation route (email/helpline/webform and TAT).

Step 2: Set up an accessibility grievance mechanism

Add a simple, visible way for users to report accessibility issues (email, helpline, web form), with an escalation path to senior officers.

Step 3: Prepare & submit two quick items

• List of digital platforms (all sites/apps/touch points).

• Self‑assessment & action‑taken report against the circular’s requirements (mark status and remarks). Use a simple table and mention about “Not started/In progress/Complete/NA.”

  
  

Step 4: Make your web & documents accessible

• Add alt text to images.

• Ensure tagged PDFs, correct reading order and headings.

• Add captions/ISL/descriptive audio to videos where applicable.

  
  

  These are baseline WCAG 2.1 techniques and are explicitly called out.

  
  

Step 5: Train your team (and vendors)

Bake accessibility into content and product workflows—cover behavior, assistive tools, and inclusive design. Make “accessible by design” the default.

Step 6: Make KYC flows inclusive

Offer alternatives like human‑assisted video KYC, voice‑assisted flows, and accepting scanned document uploads. Add a disability‑status field and a helpdesk callback option in KYC forms; allow a human officer to override automated rejections to ensure equity.

Step 7: Get an IAAP‑certified audit and fix gaps

Conduct a comprehensive audit (websites, mobile apps, portals) via IAAP professionals, aligned to WCAG, GIGW, and the RPwD Act. Then implement a remediation plan and complete fixes in time. Continue with annual audits thereafter.

Step 8: Update procurement & vendor contracts

Require accessibility conformance (WCAG 2.1/IS 17802/GIGW) for any new builds or SaaS; ensure vendors audit their products and share results. Put accessibility criteria into RFPs and evaluations. Responsibility ultimately remains with the RE.

What standard should you follow?

SEBI points to WCAG 2.1 (or latest), GIGW, IS 17802, and the RPwD Act & Rules as your baseline for digital accessibility across platforms and documents.

Where to report ongoing compliance

Report to the respective authority as specified (Stock Exchanges/Depositories/BASL/SEBI), and keep it updated annually.

Quick internal checklist (copy‑paste for your team)

• Nodal Officer appointed & published on website.

• Grievance channel live with escalation & TAT.

• Digital platform inventory submitted.

• Self‑assessment/action‑taken report submitted.

• Alt text, tagged PDFs, captions/ISL done.

• Staff/vendor training completed.

• IAAP audit done; remediation tracked to closure; annual audit calendar set.

• KYC flows inclusive + form fields updated.

• Procurement/RFPs include accessibility clauses and audits.