Key Takeaways from SEBI’s 2025 Digital Accessibility Clarifications

4. Formal audits and qualified professionals are expected

Another key clarification is around who should be assessing accessibility. SEBI goes beyond saying “test your platforms” and strongly indicates that formal audits should be carried out by qualified accessibility professionals—for example, those holding recognised certifications, with demonstrable expertise in auditing complex digital systems.

This doesn’t mean your internal QA or UX teams are irrelevant; on the contrary, they play a crucial role in ongoing testing. But for regulatory purposes, SEBI signals that there must be independent, expert-level review at defined intervals. Many entities interpret this as engaging IAAP‑certified accessibility auditors or specialist firms who can:

• Perform structured audits

• Provide detailed, traceable issue reports

• Stand behind their findings if questions arise from regulators or internal stakeholders

The clarifications also encourage entities to avoid “check the box” audits that generate a generic pass/fail certificate without meaningful detail.

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5. Prioritisation and remediation planning are part of compliance

SEBI’s clarifications don’t expect entities to achieve perfection overnight, especially if they have large legacy systems. Instead, the focus is on structured prioritisation and credible remediation planning.

Key ideas include:

• Classifying issues by severity and impact on users with disabilities

• Fixing blocking barriers in critical journeys (login, onboarding, trading, payments, statements) before cosmetic issues

• Documenting decisions: what will be fixed now, what will be deferred, and why

• Ensuring accessibility requirements are integrated into upcoming redesigns and projects

The takeaway is that a clear, documented remediation roadmap is better than chaotic ad‑hoc fixes. Regulators will often be more comfortable with an honest, prioritised plan than with superficial claims of full compliance.

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6. Re‑testing and validation are not optional

A subtle but important point in the clarifications is the emphasis on re‑testing after remediation. Fixing code is only half the story; you need to confirm that:

• the specific issues flagged in the audit are actually resolved

• the fixes have not introduced new accessibility barriers elsewhere

• the overall user experience for people with disabilities has improved in practice

SEBI’s guidance points towards a lifecycle approach: audit → remediation → re‑testing → updated status. Entities are encouraged to maintain “before and after” evidence, including screenshots, code references and test results. For larger platforms, this re‑testing may be done by a mix of the original auditors, internal teams and additional tools.

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7. Documentation and evidence are central

From a compliance perspective, documentation is as important as the work itself. The clarifications emphasise the need for entities to maintain:

• Audit reports and issue logs

• Remediation plans and status trackers

• Records of fixes implemented (for example, change tickets, code merges)

• Re‑test results or validation reports

• Platform‑wise summaries of accessibility readiness

This documentation is crucial for internal audit, board oversight, and any regulatory queries. It allows you to demonstrate not just that you care about accessibility, but that you have a structured, traceable process. Without records, even good work can appear invisible.

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8. Governance: accessibility must be owned, not just assigned

The 2025 clarifications also touch on governance. While they avoid prescriptive structures, they signal that entities should:

• Assign clear ownership for digital accessibility (for example, a function or committee)

• Integrate accessibility into broader SEBI compliance frameworks

• Ensure cross‑functional participation from compliance, IT, product, design, content and operations

• Build accessibility into policies, procedures and training

The key idea is that accessibility should not be an informal side project. It should have sponsors, roles, responsibilities and escalation paths, like any other material compliance area.

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9. Vendor and third‑party considerations

Many regulated entities rely on vendors for their websites, apps, portals or document production. SEBI’s clarifications implicitly highlight that outsourcing does not outsources accountability. You remain responsible for the accessibility of investor‑facing systems, even if they are built or hosted by third parties.

Practically, this means:

• Including accessibility requirements and standards in RFPs and contracts

• Asking vendors for evidence of accessibility testing and remediation

• Coordinating audits that include third‑party components

• Avoiding “black box” solutions where you cannot influence accessibility fixes

Accessibility has to become a standard negotiation and due‑diligence point with vendors.

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10. What should regulated entities do now?

Taken together, the 2025 clarifications paint a clear picture of where SEBI expects the industry to go. For most organisations, a realistic action plan looks like this:

1. Inventory platforms and journeys – list websites, apps, portals, key processes and document types that are investor‑facing.

2. Engage qualified auditors – plan a scoped accessibility audit for your most critical assets first.

3. Create a remediation roadmap – prioritise issues, align with release cycles, and secure budgets.

4. Embed accessibility into workflows – update design guidelines, dev standards, QA checklists and vendor requirements.

5. Set up governance and reporting – define owners, cadence of reviews, and documentation formats.

6. Plan periodic re‑testing – treat accessibility like security: something you revisit regularly, not once.