Making Markets Accessible: SEBI’s Disruption of Investor Rights

[Vishvajeet is a student at Chanakya National Law University.]

On 31 July 2025, the Securities and Exchange Board of India (SEBI) issued a circular mandating digital accessibility across all regulated entities. For the first time, accessibility is treated not as voluntary good practice but as a compliance requirement. SEBI draws authority from the Rights of Persons with Disabilities Act 2016 (RPwD Act) and directs every market participant, from stock exchanges to small brokers, to ensure that their websites, mobile apps, disclosures, and KYC processes are accessible to persons with disabilities.

This move reframes investor protection itself. Accessibility is not charity; it is the gateway to meaningful participation in financial markets. Yet, while the circular is laudable in intent, it raises difficult questions about feasibility, proportionality, and the risk of formal compliance without substantive inclusion.

The Core of the Circular

The circular introduces a multi-pronged framework. Investor-facing platforms must comply with the Web Content Accessibility Guidelines (WCAG 2.1 or higher), Guidelines for Indian Government Websites, and IS 17802 standards. Annual audits are required, and they must be conducted by certified professionals. Investor documents such as circulars and PDFs must be issued in accessible formats. KYC processes must be adaptable, offering human-assisted alternatives to biometric or automated verification.

Each regulated entity must also appoint a senior nodal officer responsible for accessibility and publish grievance channels in accessible formats. The obligation extends to third-party vendors, as contracts with fintech providers and SaaS platforms must now carry accessibility clauses.

Although SEBI originally set a 6-month compliance window, an August 2025 follow-up circular extended key deadlines, recognizing industry concerns. Inventories must now be submitted by September 2025, audits completed by April 2026, and full remediation achieved by July 2026.

Global Context: How India Stands Apart

In comparative perspective, SEBI’s framework is unusually direct. In the United States, digital accessibility in financial services is largely enforced through litigation under the Americans with Disabilities Act or procurement obligations under Section 508 of the Rehabilitation Act. The European Union’s Accessibility Act imposes obligations on banking and digital services, but enforcement lies across multiple sectoral regulators. Singapore prefers a guideline-based approach, encouraging accessibility without strict statutory deadlines.

SEBI has made accessibility part of securities regulation itself. By requiring audits, management sign-off, and contractual clauses, India has placed itself at the front line of regulatory enforcement in this space. The circular therefore has a symbolic significance: it signals that access to the securities market is not an optional courtesy but a regulated right.

Spillover Effects and Unintended Consequences

SEBI’s move is bold, but it is not without real-world friction. Turning good intent into practical outcomes will come with trade-offs.

First, the cost burden would not fall equally. Big firms will likely manage just fine. They have the money and in-house teams to handle audits, consultants, and tech upgrades. Smaller brokers and solo advisers? Not so much. Imagine a one-person advisory firm in a Tier 2 town now needing to shell out lakhs to revamp their website and get an annual accessibility audit. What was meant to bring more people into the market could end up forcing smaller players out of it.

Second, vendor issues will get messy. A lot of intermediaries rely on international fintech platforms or SaaS tools they don’t control. SEBI wants accessibility clauses baked into those contracts, but good luck convincing a US-based software provider to tweak its terms for one small Indian client. Without that leverage, firms may resort to ticking the boxes without actually making their platforms better for disabled users.

Third, there is a serious shortage of accessibility auditors. With thousands of firms now needing certified professionals, demand will quickly outpace supply. Delays are almost guaranteed, and prices will rise. Smaller entities might end up waiting months or paying a premium just to get their audit done on time.

Fourth, overlapping enforcement could confuse everyone. SEBI has its rules, but the RPwD Act also applies. That means firms could face penalties from two separate authorities for the same issue. It creates legal uncertainty and opens the door to mixed signals on what compliance actually looks like.

Fifth, grievance redressal might fall short. The circular requires a senior nodal officer to handle accessibility issues, but in small firms, that could just be someone wearing five other hats already. Without training or dedicated resources, it risks becoming a check-the-box requirement that doesn’t help real users.

Even with all this, the upside is huge, if it is done right. Think about a visually impaired investor who has never been able to open a demat account or read offer documents without help. With accessible platforms and human-assisted KYC, they could finally invest on their own terms. That kind of autonomy changes lives. The key is making sure the system includes everyone, not just those who can afford to comply.

Towards a Balanced Framework

To reconcile inclusion with feasibility, SEBI should consider calibrating its approach. Tiered obligations could relieve smaller intermediaries of the cost of annual audits, requiring instead self-declarations with periodic external certification. Industry associations might pool resources to empanel auditors and negotiate uniform audit fees.

Capacity building is equally vital. Expanding the pool of certified auditors through collaboration with accessibility organizations will reduce bottlenecks. Centralized helpdesks hosted by stock exchanges or depositories could serve as focal points for accessibility grievances, easing the burden on smaller firms.

Finally, clearer coordination with the Department of Empowerment of Persons with Disabilities would reduce overlapping enforcement and ensure predictable processes.

Conclusion: A High Bar, A Clear Message

SEBI’s accessibility mandate is both progressive and disruptive. It extends the idea of investor protection beyond disclosure and governance to the very ability of investors to participate. By embedding accessibility into compliance, India has positioned itself as a leader in inclusive financial regulation.

Yet, the circular also sets a high bar. Without proportional safeguards, it risks overburdening smaller intermediaries and encouraging hollow compliance. The challenge for SEBI is to ensure that accessibility remains a lived reality for investors, not just a regulatory checkbox.

If implemented thoughtfully, this circular can become a global benchmark: a demonstration that financial regulation can advance not just efficiency and integrity, but inclusion itself.