15 questions Research Analysts, Investment Advisers and brokers ask about the accessibility mandate. Every answer is written by PB Shruti, an accessibility auditor, and cites the clause it rests on.
The deadline to appoint an IAAP auditor, complete the audit and fix its findings is 31 January 2027. See what the extension covers
“The responsibility to ensure the accessibility of a Digital Platform shall lie with the REs.”
All SEBI-regulated entities are covered, including Stockbrokers, Research Analysts, Investment Advisers, Mutual Funds and Asset Management Companies, Portfolio Managers, Alternative Investment Funds (AIFs), other regulated intermediaries and Market Infrastructure Institutions.
SEBI Circular No. 2025/111
Yes. The requirement is not restricted to large organisations. Individual and corporate Research Analysts and Investment Advisers are covered, along with other applicable SEBI-regulated entities.
SEBI Circular No. 2025/111, paragraph 7
Client-facing digital platforms are covered. That means websites, web applications, portals, Android and iOS applications, and the investor-facing content and documents published through them.
SEBI Circular No. 2025/111, Annexure I, Section B and Section 2.2
The requirements focus on digital platforms provided for investors and clients. Platforms that are purely administrative and do not interact with or serve clients are distinguishable from the client-facing platforms covered.
SEBI Circular No. 2025/111, paragraph 1 and Annexure I, Section B
Yes. The regulated entity remains responsible for the accessibility of its client-facing digital platforms, including services and tools provided by third parties or embedded into those platforms.
SEBI Circular No. 2025/111, Annexure I, Section 6.1
It depends, and it is assessed case by case. The key consideration is whether the website forms part of the Research Analyst's client-facing digital services, not merely whether it is publicly accessible.
SEBI Circular No. 2025/111, Annexure I, Sections B and 2.2
The SEBI-regulated entity is responsible. Outsourcing website development, hosting or maintenance does not transfer the regulatory responsibility to the developer.
SEBI Circular No. 2025/111, Annexure I, Sections 6.1 and 6.2
SEBI specifies three standards and frameworks. WCAG 2.1 or its latest version, IS 17802, and the latest version of the Guidelines for Indian Government Websites (GIGW).
SEBI Circular No. 2025/111, Annexure I, Section B
Yes. SEBI requires regulated entities to appoint IAAP-certified accessibility professionals to conduct accessibility audits. This is a specific requirement under the SEBI regulatory framework.
SEBI Circular No. 2025/111, Annexure I, Section 5.1 and Section 5.4
No. The auditor is not required to be a person with a disability. However, SEBI specifically requires usability testing involving persons with disabilities as part of the accessibility audit.
SEBI Circular No. 2025/111, Annexure I, Section 5.1
No. Automated testing alone cannot identify all accessibility barriers. Manual testing is also necessary, and the circular requires usability testing involving persons with disabilities.
SEBI Circular No. 2025/111, Annexure I, Section 5.1
Yes. They can be assessed under the same audit engagement, but each platform needs to be evaluated separately.
SEBI Circular No. 2025/111, Annexure I, Sections B and 5.1
Every year. SEBI requires annual accessibility audits of digital platforms through IAAP-certified accessibility professionals.
SEBI Circular No. 2025/111, Annexure I, Section 5.4
No. An accessibility audit report documents the accessibility status of the specific digital platforms assessed, against the applicable standards, as of the assessment date. It does not establish compliance with every regulatory requirement applicable to the entity.
SEBI Circular No. 2025/111, Annexure I, Section 5
31 January 2027. SEBI's circular dated 30 October 2026 extends the deadline for appointing an IAAP auditor, conducting accessibility audits and completing remediation of audit findings to that date.
SEBI Circular dated 30 October 2026
One mandate, one set of compliance guidelines and three extensions so far. Read the originals before relying on any summary, including this one.
The original mandate. Sets out which regulated entities and digital platforms are covered, the accessibility standards to follow, and the audit requirement in Annexure I.
SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111
Extends the first set of timelines and makes BSE Ltd. the reporting authority for Investment Advisers and Research Analysts.
SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/121
Compliance guidelines and reporting formats, including the designated reporting authority for each category of regulated entity and the annual reporting requirement.
SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/131
A further extension of the compliance timelines.
Extends the deadline for appointing an IAAP auditor, conducting the accessibility audit and remediating its findings to 31 January 2027. All other provisions remain unchanged.
HO/53/12/13(2)2026-ITD5-M2IPC/I/24856/2026 . Link opens on NoticeBlue.
PB Shruti audits your website and apps against WCAG, IS 17802 and GIGW, with manual testing and usability testing by persons with disabilities.
Contact the auditor at pbshruti.comLightSpeedDevs builds a new website to the standard from the first line, or fixes the findings in your audit report on the site you already have.
Contact the developer at lightspeeddevs.comNo referral commissions change hands between us. The auditor is paid for the audit and the developer is paid for the build, and you can hire either one without the other.
Last checked against the circulars on . This site explains SEBI's circulars in plain language. It is not legal advice and it is not published by SEBI.