Compliance Guidelines for Digital Accessibility Circular ‘Rights of Persons with Disabilities Act, 2016 and rules made thereunder- mandatory compliance by all Regulated Entities’ dated July 31, 2025 (Circular No. SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111)

CIRCULAR SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/131 September 25, 2025 To, All Recognised Stock Exchanges All Recognised Clearing Corporations All Registered Depositories All Registered Intermediaries Association of Mutual Funds in India (AMFI) Association of Portfolio Managers in India (APMI) BSE Limited (Investment Adviser Administration and supervisory body-IAASB) BSE Limited (Research Analysts Administration and supervisory body-RAASB) Sir/Madam, Subject: Compliance Guidelines for Digital Accessibility Circular ‘Rights of Persons with Disabilities Act, 2016 and rules made thereunder- mandatory compliance by all Regulated Entities’ dated July 31, 2025 (Circular No. SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111) 1. SEBI issued circular on ‘Rights of Persons with Disabilities Act, 2016 and rules made thereunder-mandatory compliance by all Regulated Entities’ on July 31, 2025. 2. The Compliance Guidelines are enclosed at Annexure-A of this circular. 3. This circular is being issued in exercise of powers conferred under Section 11 (1) of the Securities and Exchange of India Act, 1992, to protect the interests of investors in securities and to promote the development of, and to regulate the securities market. 4. This circular is issued with the approval of Competent Authority. Page 1 of 95. This circular is available on SEBI website at www.sebi.gov.in under the category “Legal” and drop “Circulars”. Yours faithfully, Deepankar Chatterjee Deputy General Manager Phone: 022-26449643 Email: deepankarc@sebi.gov.in Page 2 of 9Annexure-A Compliance Guidelines for Digital Accessibility (For SEBI Circular No. SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111) These compliance guidelines are applicable to all the Regulated Entities (REs) that are required to directly submit the compliance of the said circular to SEBI Part A: Summary of Compliance Requirements Table A S/N Compliance required Date of submission of compliance 1 REs shall submit a list of digital platforms provided Sept 30, 2025 by them for the investors (Table-C1) 2 Appointment of IAAP certified accessibility professionals Dec 14, 2025 as Auditor. (Table-C2) 3 Conduct of Accessibility Audit for the digital platforms. April 30, 2026 (Table-C3) 4 Remediation of findings from the audit and ensuring July 31, 2026 compliance with this circular. (Table-C4) 5 Annually give compliance to conducting annual *April 30, 2027 accessibility audits of all the digital platforms and submit final report of such audit to SEBI *Annual compliance is to be submitted within 30 days of each Financial Year, effective April 30, 2027 Part B: Mechanism of Submission of Compliance (latest updated as per SEBI circular no. SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/121 dated August 29, 2025) Table B S/N Regulated Entity Reporting Authority 1 Stock Brokers/ Depository Stock Participants Exchanges/Depositories 2 Investment Advisor (“IAs”) and Research BSE Ltd. Analysts (“RAs”) 3 MIIs and rest of the REs SEBI This mechanism of compliance is applicable for all REs mentioned in row 3 of the table immediately above. It may be noted that the submission to SEBI in this regards shall be through email on digital_acc@sebi.gov.in in the formats specified in Part C. For the REs having multiple Digital Platforms, the audit reports for the digital platforms shall be consolidated and submitted through email as per guidelines laid down in points 4 and 5 of Part C. Page 3 of 9Illustration: An RE has listed 5 Digital Platforms. It should submit the consolidated initial audit reports of all the digital platforms by April 30, 2026 and consolidated final audit reports by July 31, 2026. Page 4 of 9Part C: Formats for Compliance Submission REs shall submit compliance to the respective reporting authorities in the formats mentioned below: 1. Format for Information about Digital Platforms of the RE. Email Subject: [RE Registration No.] Information About Digital Platforms of the RE. Email Body: Name of RE Category for which submission is made (from the list provided in Part D) Table C1 S/N Name of URL Purpose Remarks on current digital accessibility status of the platform platform (add or remove rows as applicable) Page 5 of 92. Format for Information about appointment of IAAP certified accessibility professionals as Auditor for digital platforms for REs. Email Subject: [RE Registration No.] Information about appointment of IAAP certified accessibility professionals as Auditor for digital platforms for REs. Email Body: Name of RE Category for which submission is made (from the list provided in Part D) Table C2 Sl. Particulars Details to be No. filled by RE 1 Name of IAAP Certified Accessibility Professional 2 Certification Details (IAAP ID/Certificate No.) 3 Date of Appointment 4 Scope of Audit (Websites, Mobile Apps, Portals, etc.) Note: Make sure to cover details of all digital platforms as applicable 5 Is the SEBI circular notified to the appointed auditor for compliance verification (Yes/No) 6 Contact Details of Auditor Page 6 of 93. Format for Submission of Initial Accessibility audit report for digital platforms. Email Subject: [RE Registration No.] Submission of Initial Accessibility audit report for digital platforms Email Body: Name of RE Category for which submission is made (from the list provided in Part D) Table C3 Sl. Particulars Details to be filled by No. RE 1 Name of IAAP Certified Accessibility Professional / Firm 2 Date of Completion of Audit 3 Digital Platforms Covered (Websites, Terms of Reference Mobile Apps, Portals, etc.) and Scope of audit to be attached 4 Key Findings / Observations Consolidated PDF copy of the report(s) to be attached. The consolidated audit report is to be attached under the file name [Department]_Table- C3_[SEBI Reg No.]_DDMMYYYY.pdf* 5 Action Plan / Timelines for Remediation *Here, Department will be the concerned department corresponding to the RE category in Part D. DDMMYYYY is the date of the report where DD is 2-digit date of month, MM is 2-digit month of year and YYYY is 4-digit year. Page 7 of 94. Format for submission of final accessibility audit report for digital platforms. Email Subject: [RE Registration No.] submission of final accessibility audit report for digital platforms Email Body: Name of RE Category for which submission is made (from the list provided in Part D) Table C4 Sl. Particulars Details to be filled by No. RE 1 Name of IAAP Certified Accessibility Professional / Firm 2 Date of Completion of Final Audit 3 Digital Platforms Covered (Websites, Mobile Terms of reference Apps, Portals, etc.) and Scope of audit to be attached 4 Key Findings / Observations from Final Audit Consolidated PDF copy of the report(s) to be attached. The consolidated audit report is to be attached under the file name [Department]_Table- C4_[SEBI Reg No.] _DDMMYYYY.pdf* 5 Remediation Measures Undertaken 6 Status of Compliance (Fully Complied / Partially Complied / Pending) 7 Supporting Evidence (Screenshots, URLs, Certificates, Reports) *Here, Department will be the “concerned department” corresponding to the RE category in Part D. DDMMYYYY is the date of the report where DD is 2-digit date of month, MM is 2-digit month of year and YYYY is 4-digit year. Page 8 of 9Part D: List of REs submitting compliance directly to SEBI Table D S/N REs submitting compliance directly to SEBI Concerned Departments 1 Alternative Investment Funds(AIFs) AFD 2 Bankers to an Issue (BTI) and Self Certified CFD Syndicate Banks (SCSBs) 3 Clearing Corporations MRD 4 Collective Investment Schemes(CIS) IMD 5 Credit Rating Agencies (CRAs) DDHS 6 Custodians AFD 7 Debenture Trustees (DTs) DDHS 8 Depositories MRD 9 KYC Registration Agencies (KRAs) MIRSD 10 Merchant Bankers (MBs) CFD 11 Mutual Funds (MFs)/ Asset Management IMD Companies (AMCs) 12 Portfolio Managers IMD 13 Registrar to an Issue and Share Transfer Agents MIRSD (RTAs) 14 Stock Exchanges MRD 15 Venture Capital Funds (VCFs) AFD -------x x x------- Page 9 of 9