Is an automated accessibility scan sufficient for a comprehensive audit?

Answered by PB Shruti, IAAP-certified accessibility auditor. Last checked 15 November 2026.

No. Automated testing alone cannot identify all accessibility barriers. Manual testing is also necessary, and the circular requires usability testing involving persons with disabilities.

Manual testing is needed to evaluate:

Keyboard navigation
Screen-reader compatibility
Colour contrast
Zoom
Focus management
Other relevant accessibility requirements

The circular requires a comprehensive accessibility audit, and it requires that audit to include usability testing by persons with disabilities. A report generated by a scanner on its own covers neither.

What the circular says

“comprehensive accessibility audit of their digital platforms”

Regulatory reference

Circular: Rights of Persons with Disabilities Act, 2016 and rules made thereunder – mandatory compliance by all Regulated Entities
Circular number: SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111
Dated: 31 July 2025
Where to look: Annexure I, Section 5.1

Need the audit done, or the website fixed?

Accessibility audit

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.com

Website build or remediation

LightSpeedDevs 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.com

No 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.

Who is behind these answers

Auditor: PB Shruti IAAP-certified accessibility auditor and SEBI-registered Research Analyst. Writes and reviews every answer.
Developer: LightSpeedDevs Designs, builds and maintains this website.

Last checked against the circulars on 15 November 2026. This site explains SEBI's circulars in plain language. It is not legal advice and it is not published by SEBI.