Download the SEBI Accessibility Pre-Audit Checklist for Finance

Understanding SEBI's Digital Accessibility Mandate

SEBI’s July 31, 2025, circular mandates digital accessibility for all regulated financial entities, requiring compliance with IS 17802:2021, GIGW 3.0, and WCAG 2.1 standards to ensure accessibility of digital content, including websites, mobile apps, and online banking services.

Non-compliance risks SEBI penalties, legal consequences, reputational damage, customer exclusion, and a negative impact on ESG scores.

Key Compliance Deadlines (SEBI Circular)

• Sept 30, 2025: Submit platform list & compliance report
• Dec 14, 2025: Appoint IAAP-certified auditor (upcoming)
• April 30, 2026: Complete accessibility audit
• July 31, 2026: Complete remediation & achieve compliance
• April 30, 2027: Annual audit & reporting (recurring yearly)

Why SEBI Accessibility Compliance Matters for Finance

India is home to over 14,500 fintech companies with a digital finance adoption at 87%, making it one of the global fintech leaders. SEBI’s new accessibility mandate requires all regulated financial entities to comply by April 30, 2026.

Non-compliance could lead to:

• Fines for failure to comply with accessibility standards.
• Legal action under the RPwD Act.
• Regulatory scrutiny, leading to additional audits and oversight.
• Negative media attention and reputational damage.
• Increased legal risks, including potential lawsuits.
• Significant drop in ESG (Environmental, Social, and Governance) scores.

With the deadline fast approaching, financial institutions need to act now and start accessibility testing.

List of 50 Essential Accessibility Compliance Checkpoints

Governance & Organizational Readiness

• Senior Nodal Officer appointed for accessibility compliance with clear responsibilities documentedCRITICAL
• Accessibility grievance redressal mechanism established (email, phone, web form) and published on websiteCRITICAL
• List of all digital platforms (websites, mobile apps, portals, trading terminals) documented and submitted to SEBICRITICAL
• Procurement policy updated to include accessibility requirements in all RFPs and vendor contractsHIGH
• Accessibility policy documented and approved by senior managementHIGH

Web Platform Accessibility

• All images have descriptive alt text (decorative images marked with empty alt="")CRITICAL
• Proper heading hierarchy (H1-H6) used throughout the website for structureCRITICAL
• All interactive elements (buttons, links, forms) are keyboard accessible (Tab, Enter, Space keys)CRITICAL
• Visible focus indicators present on all focusable elements with minimum 3:1 contrast ratioCRITICAL
• Text contrast meets WCAG AA standards (4.5:1 for normal text, 3:1 for large text)CRITICAL
• Forms have properly associated labels, instructions, and error messages announced by screen readersCRITICAL
• Error prevention: Confirmation step provided for financial transactions and data submissionsCRITICAL
• Skip navigation links provided to bypass repetitive contentHIGH
• Page titles are descriptive and unique for each pageHIGH
• Link text is descriptive (avoid "click here" or "read more" without context)HIGH
• Text can be resized up to 200% without loss of content or functionalityHIGH
• No automatic page refreshes or redirects without user controlHIGH
• Time limits can be extended or disabled (for session timeouts, tickers, etc.)HIGH
• Tables have proper header cells (th) and table captions for data tablesMEDIUM
• ARIA landmarks used appropriately (navigation, main, complementary, contentinfo)MEDIUM

Mobile App Accessibility

• Compatible with iOS VoiceOver and Android TalkBack screen readersCRITICAL
• All interactive elements have minimum touch target size of 44x44 points (iOS) or 48x48dp (Android)CRITICAL
• Proper accessibility labels provided for all UI elements (not just visible text)CRITICAL
• Biometric authentication has alternative input methods (PIN, password)CRITICAL
• Swipe gestures have alternative navigation methods (buttons or menu options)HIGH
• Text zoom/dynamic type supported up to 200% without horizontal scrollingHIGH
• Color is not the only means of conveying information (use icons, text labels, or patterns)HIGH
• Focus order is logical and follows visual layoutHIGH
• App works with external keyboards and switch controlsHIGH
• Device orientation changes supported (portrait and landscape modes)MEDIUM

Document Accessibility

• All investor-facing PDFs are tagged with proper structure (headings, lists, tables)CRITICAL
• PDFs have reading order set correctly for logical flowCRITICAL
• All images and charts in documents have alternative text descriptionsCRITICAL
• Documents available in alternative formats (audio, large print, easy-read text) upon requestHIGH
• Excel/spreadsheet documents have properly labeled columns and rows for screen readersMEDIUM

Multimedia & Video Content

• All videos have accurate closed captions (not auto-generated only)CRITICAL
• Video transcripts provided for all investor education and important announcementsHIGH
• Indian Sign Language (ISL) interpretation available for critical videosHIGH
• Video players are keyboard accessible with visible controlsHIGH
• Audio descriptions provided for videos where visual information is criticalMEDIUM

e-KYC & Customer Processes

• e-KYC process fully accessible via keyboard and screen readersCRITICAL
• Alternative KYC methods available (human-assisted, phone, in-person options)CRITICAL
• CAPTCHA has audio alternative or accessible challenge methodCRITICAL
• Trading platforms and order entry accessible to assistive technology usersCRITICAL
• Video KYC includes accommodations for deaf/hard of hearing users (text chat option)HIGH

Training, Testing & Third-Party Management

• Staff training completed on accessibility basics, assistive technology, and customer serviceCRITICAL
• Usability testing conducted with persons with disabilities (multiple disability types)CRITICAL
• Development and design teams trained on WCAG 2.1, ARIA, and accessible development practicesHIGH
• Third-party vendors/platforms assessed for accessibility; contracts include accessibility clausesHIGH
• Accessibility statement published on website with contact information and conformance detailsHIGH

Important Notes: This checklist is for preliminary self-assessment only; SEBI requires formal accessibility audits by IAAP-certified professionals