Date: 2025-08-29Category: Not ApplicableState: Union GovernmentCountry: India
Extension of timelines and Update of reporting authority for IAs and RAs w.r.t. SEBI Circular for Compliance to 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)
**Executive Summary:**
This SEBI circular extends the timelines for Regulated Entities (REs) to comply with the Digital Accessibility circular concerning the Rights of Persons with Disabilities Act, 2016. It grants a one to six-month extension for various compliance requirements, including submitting action reports, providing lists of digital platforms, appointing accessibility professionals, conducting accessibility audits, and remediating audit findings. Additionally, it updates the reporting authority for Investment Advisors (IAs) and Research Analysts (RAs) to BSE Ltd.
**Key Points / Main Content:**
* **Extension of Compliance Timelines:**
* Submission of compliance action reports: Extended to September 30, 2025.
* Submission of a list of digital platforms: Extended to September 30, 2025.
* Appointment of IAAP certified accessibility professionals: Extended to December 14, 2025.
* Conduct of Accessibility Audit for digital platforms: Extended to April 30, 2026.
* Remediation of audit findings: Extended to July 31, 2026.
* Annual submission of compliance to accessibility audits: Extended to April 30 of each subsequent Financial Year.
* **Updated Reporting Authority for IAs and RAs:**
* The reporting authority for IAs and RAs is changed from BASL and SEBI respectively, to BSE Ltd.
* **Compliance Reporting Authorities:**
* Stock Brokers, Depository Participants, Stock Exchanges, and Depositories report to Stock Exchanges/Depositories.
* Investment Advisors (IAs) and Research Analysts (RAs) report to BSE Ltd.
* MIIs and the rest of the REs report to SEBI.
* **Authority:**
* This circular is issued under Section 11(1) of the Securities and Exchange Board of India Act, 1992.
**Impact Analysis:**
**Regulated Entities (REs):**
* *Impact:* REs are affected by the revised compliance deadlines and the change in the reporting authority for IAs and RAs.
* *Action Required:* REs must adhere to the extended timelines for compliance and ensure that IAs and RAs report to BSE Ltd. REs must also continue to comply with the Digital Accessibility circular concerning the Rights of Persons with Disabilities Act, 2016.
**Investment Advisors (IAs) and Research Analysts (RAs):**
* *Impact:* IAs and RAs are affected by the change in reporting authority.
* *Action Required:* IAs and RAs must submit compliance reports to BSE Ltd. instead of BASL or SEBI.
**BSE Ltd.:**
* *Impact:* BSE Ltd. is now the reporting authority for IAs and RAs regarding the Digital Accessibility circular.
* *Action Required:* BSE Ltd. must establish processes to receive and review compliance reports from IAs and RAs.
Key Entities Referenced
Securities and Exchange Board of India SEBI: The regulatory body issuing the circular.
Rights of Persons with Disabilities Act, 2016: The legislation mandating compliance for Regulated Entities regarding digital accessibility.
BSE Limited: The updated reporting authority for Investment Advisors (IAs) and Research Analysts (RAs) regarding compliance with the Digital Accessibility circular.
Investment Advisers IAs: Regulated entities that provide investment advice.
Research Analysts RAs: Regulated entities that conduct research and analysis of securities.
Digital Accessibility Circular: SEBI's circular concerning compliance with digital accessibility standards.
Association of Mutual Funds in India AMFI: An association of mutual funds in India
Association of Portfolio Managers in India APMI: An association of portfolio managers in India
CIRCULAR
SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/121 August 29, 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: Extension of timelines and Update of reporting authority for IAs and
RAs w.r.t. SEBI Circular for Compliance to 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. SEBI has received representations from Regulated Entities (REs) requesting
an extension of timeline to submit their compliance against the provisions of the
circular.
3. Based on the representations received, the following extensions are granted:
Page 1 of 3Table 1 : Compliance Requirements and Extension of Timelines
S/N Compliance Timeline Current Extension New
required Date Granted Date
1 REs shall submit a Within 30 Aug 30, 1 month Sept 30,
compliance/ action days 2025 2025
taken report
pertaining to the
clauses of this circular
2 REs shall submit a Within 30 Aug 30, 1 month Sept 30,
list of digital days 2025 2025
platforms provided by
them for the investors
3 Appointment of IAAP Within 45 Sept 14, 3 months Dec 14,
certified accessibility days 2025 2025
professionals as
Auditor.
4 Conduct of Within 3 Oct 31, 6 months April 30,
Accessibility Audit for months 2025 2026
the digital platforms.
5 Remediation of Within 6 Jan 31, 6 months July 31,
findings from the audit months 2025 2026
and ensuring
compliance with
this circular.
6 Annually give Within 30 April 30, To next April 30,
compliance to days of 2026 Financial 2027
conducting annual each year
accessibility audits of Financial
all the digital Year
platforms and submit
final report of such
audit to SEBI
4. The reporting authority for IAs and RAs shall be modified from BASL and SEBI
respectively to BSE Ltd. for both IAs and RAs. The updated reporting authorities
for the compliance with Digital Accessibility circular shall be as follows:
Table 2: Compliance Reporting Authorities
S/N Regulated Entity Reporting Authority
1 Stock Brokers/ Depository Stock Exchanges /
Participants Depositories
2 Investment Advisor (“IAs”) and Research BSE Ltd.
Analysts (“RAs”)
3 MIIs and rest of the REs SEBI
Page 2 of 35. 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.
6. This circular is issued with the approval of Competent Authority.
7. 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 3 of 3