SEBI Digital Accessibility Circular 2024: Complete Compliance Guide for Listed Companies

In 2024, the Securities and Exchange Board of India (SEBI) issued a landmark circular mandating digital accessibility for all regulated entities. This means listed companies, stock brokers, depository participants, mutual fund AMCs, registrar and transfer agents (RTAs), and other SEBI-regulated intermediaries must now ensure their websites, trading platforms, and mobile applications are accessible to persons with disabilities (PwD).

This guide breaks down exactly what the circular requires, who is covered, and the step-by-step process to achieve and maintain compliance.

What the SEBI 2024 Circular Requires

The circular references the Web Content Accessibility Guidelines (WCAG) 2.2 at the AA conformance level as the technical standard. All digital platforms operated by regulated entities must meet this standard. Key requirements include:

All public-facing web pages must conform to WCAG 2.2 Level AA
Mobile applications must meet equivalent accessibility standards
Trading platforms and investor portals are explicitly in scope
Entities must conduct accessibility audits by qualified professionals
Compliance documentation must be maintained and available for review
Ongoing monitoring is expected — accessibility is not a one-time activity

Who Must Comply?

The scope of the SEBI circular covers a broad range of regulated entities across India's financial ecosystem:

Companies listed on NSE and BSE
Stock brokers and sub-brokers
Depository participants (CDSL and NSDL)
Mutual fund asset management companies (AMCs)
Registrar and transfer agents (RTAs)
Investment advisers and portfolio managers
Credit rating agencies
Other SEBI-registered intermediaries

WCAG 2.2 AA: What It Means in Practice

WCAG 2.2 AA is the global gold standard for web accessibility. For a typical trading platform or corporate investor portal, compliance means:

Perceivable: All content (charts, tables, notifications) must have text alternatives. Videos need captions. Colour alone cannot convey information.
Operable: Every feature must work with a keyboard alone. No timed interactions without alternatives. Navigation must be consistent and predictable.
Understandable: Forms must have clear labels and error messages. Language of the page must be programmatically set. Content must be readable and predictable.
Robust: Code must be valid and compatible with assistive technologies such as screen readers (JAWS, NVDA, VoiceOver).

Step-by-Step Compliance Checklist

Follow this process to move from awareness to full SEBI accessibility compliance:

Conduct a preliminary audit— Identify the current state of accessibility across all digital properties. A free preliminary check from an IAAP-certified auditor can give you a baseline.
Commission a full WCAG 2.2 AA audit— Engage certified professionals to perform automated scanning, manual testing, and assistive technology testing (screen readers, keyboard, switch devices).
Prioritise and remediate issues— Start with critical and high-severity issues. Developer-ready code fixes accelerate the process significantly.
Conduct PwD user testing— Test with real persons with disabilities to validate usability beyond technical compliance.
Generate compliance documentation— Produce a detailed conformance report structured for SEBI submission.
Establish ongoing monitoring— Set up monthly or quarterly re-audits to maintain compliance as your platforms evolve.

Timelines and Deadlines

While the SEBI circular took effect in 2024, enforcement is expected to intensify throughout 2025 and 2026. Entities that have not yet begun compliance efforts face growing risk of regulatory scrutiny. The practical reality is that accessibility audits and remediation take 4 to 6 weeks on average — waiting increases exposure to both regulatory action and reputational risk.

Consequences of Non-Compliance

Failure to comply with the SEBI accessibility mandate can result in:

Regulatory penalties and fines under SEBI regulations
Mandatory remediation orders with fixed deadlines
Reputational damage and public disclosure of non-compliance
Liability under the RPwD Act 2016 for discrimination against PwD
Loss of trust from investors and stakeholders who value ESG and inclusion

How We Help

Our IAAP-certified team specialises in SEBI accessibility compliance. We offer full WCAG 2.2 AA audits, developer remediation workshops, PwD user testing, and SEBI-formatted compliance documentation — all priced competitively for the Indian market. Every engagement starts with a free preliminary accessibility check so you know exactly where you stand.