If a SEBI-registered Research Analyst sells courses through a separate website, does that website also need to be audited?
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.
Applicability is not restricted to the primary website. It may extend to subdomains, separate websites, mobile applications and other digital platforms used for client-facing activities.
If the separate website or platform is used by the Research Analyst to provide services, information or content to clients or investors, it should be considered within the scope of the digital accessibility requirements. Digital documents and multimedia content shared with clients, such as PDFs and videos, should also meet the applicable accessibility requirements.
Because the answer turns on how the course website relates to your registered activity and your clients, it needs to be looked at individually.
Note. Whether a particular course website is in scope turns on the facts. Contact us for a detailed assessment of your setup.
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, Sections B and 2.2