SEBI has mandated that all regulated entities, including Research Analysts (RAs), ensure digital accessibility for persons with disabilities in accordance with the Rights of Persons with Disabilities Act, 2016 (RPWD Act). This article provides a comprehensive technical analysis of the digital accessibility compliance requirements.
Regulatory Basis
Primary Circular: SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111
SEBI issued the circular on July 31, 2025, mandating all REs to ensure digital accessibility for persons with disabilities in accordance with the RPWD Act.
Compliance Guidelines
SEBI issued compliance guidelines on September 25, 2025 (Circular No. SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/131), setting timelines for implementation.
Key Requirements
1. Compliance with RPWD Act
REs must comply with the Rights of Persons with Disabilities Act, 2016 and corresponding Rights of Persons with Disabilities Rules, 2017.
2. Digital Platforms
All digital platforms operated by SEBI regulated entities must be accessible to persons with disabilities.
3. Accessibility Standards
REs must comply with:
- Web Content Accessibility Guidelines (WCAG)
- Guidelines for Indian Government Websites (GIGW)
- IS 17802 standards
- RPWD standards
4. IAAP-Certified Professional
Each RE must appoint an IAAP-certified accessibility professional within 45 days.
5. Independent Assessment
The IAAP-certified professional must conduct an independent, qualified assessment.
6. Usability Testing
The assessment must include usability testing with actual participants who have disabilities.
Implementation Timeline
| Requirement | Timeline |
|---|---|
| Appoint IAAP-certified professional | Within 45 days of circular |
| Conduct independent assessment | As per guidelines |
| Implement accessibility measures | As per guidelines |
What Must Be Accessible
1. Websites
All RA websites must be accessible.
2. Mobile Applications
All RA mobile apps must be accessible.
3. Digital Documents
All digital documents must be accessible.
4. Online Portals
All online portals must be accessible.
Compliance Requirements
1. Appoint Accessibility Professional
- IAAP-certified professional
- Qualified to conduct assessments
- Capable of usability testing
2. Conduct Assessment
- Independent assessment
- Against WCAG, GIGW, IS 17802, RPWD standards
- With usability testing with PwDs
3. Implement Measures
- Remediate accessibility issues
- Implement accessibility features
- Ensure ongoing compliance
4. Monitor Compliance
- Regular monitoring
- Periodic assessments
- Update as standards evolve
Common Compliance Gaps
1. No Accessibility Professional
Some RAs do not appoint an accessibility professional.
Solution: Appoint an IAAP-certified accessibility professional.
2. No Accessibility Assessment
Some RAs do not conduct accessibility assessments.
Solution: Conduct independent accessibility assessments.
3. No Remediation
Some RAs do not remediate accessibility issues.
Solution: Implement accessibility measures.
4. No Usability Testing
Some RAs do not conduct usability testing with PwDs.
Solution: Conduct usability testing with actual participants who have disabilities.
Consequences of Non-Compliance
1. Regulatory Action
SEBI may take action for non-compliance.
2. Legal Liability
Non-compliance with the RPWD Act may result in legal liability.
3. Reputational Damage
Non-compliance can damage the RA's reputation.
Conclusion and How Anuj Desai & Associates Can Help
Digital accessibility is a critical compliance requirement under the RPWD Act.
Anuj Desai & Associates offers specialized services to help RAs comply with digital accessibility requirements:
- Accessibility professional identification
- Accessibility assessment
- Remediation planning
- Usability testing
- Compliance audit and advisory
Contact us today to ensure your digital platforms comply with accessibility requirements. Our team will guide you through the process.
Disclaimer: This article is for informational purposes only and does not constitute legal advice. Readers are advised to consult qualified professionals for legal and compliance matters. Anuj Desai & Associates is a SEBI compliance consulting firm based in India.