For years, digital accessibility in India has been discussed in policy circles but rarely enforced. That changed when the Securities and Exchange Board of India (SEBI) issued a circular mandating that all regulated financial entities make their digital platforms accessible to persons with disabilities, in compliance with WCAG 2.1 Level AA standards.
This is not a recommendation. It's a mandate. And based on what I've seen across the Indian financial sector, most organisations are not ready.
What the Circular Actually Requires
Let me cut through the legal language and tell you what this means in practical terms:
- WCAG 2.1 Level AA conformance for all public-facing websites and mobile applications
- Accessible digital documents — including PDFs for KYC forms, account opening documents, and disclosures
- Keyboard operability for all functionality
- Compatibility with assistive technologies — screen readers, magnification software, and voice input
- An accessibility statement published on the website
- A feedback mechanism for users with disabilities to report barriers
Who Does This Apply To?
The scope is broad. If SEBI regulates you, this applies to you:
| Category | Examples |
|---|---|
| Market Infrastructure Institutions | NSE, BSE, CDSL, NSDL, clearing corporations |
| Stockbrokers & Trading Platforms | Zerodha, Angel One, ICICI Direct, and others |
| Mutual Fund Houses (AMCs) | SBI MF, HDFC AMC, Nippon India, and others |
| Other Intermediaries | Portfolio managers, investment advisers, research analysts, depository participants |
The Legal Foundation
This mandate does not exist in isolation. It stands on two pillars:
1. The Rights of Persons with Disabilities (RPwD) Act, 2016
India's RPwD Act is one of the most comprehensive disability rights laws in the world. It covers 21 categories of disabilities and has specific provisions for digital inclusion:
- Section 40 requires government and establishments to ensure that their ICT (Information and Communication Technology) is accessible
- Section 42 addresses access to electronic media specifically
- Section 46 mandates accessibility in all public services
- Sections 89–92 lay out penalties for non-compliance
SEBI's mandate is essentially an enforcement mechanism for what the RPwD Act already requires in the financial sector.
2. GIGW 3.0 (Guidelines for Indian Government Websites)
The Guidelines for Indian Government Websites, version 3.0, published by MeitY and NIC, incorporate WCAG 2.1 Level AA as the baseline standard. While GIGW primarily applies to government websites, SEBI has referenced it as the benchmark — effectively extending government-grade accessibility standards to the private financial sector.
The Reality on the Ground
I work with organisations in the financial sector. Here's what I see consistently:
- Trading platforms are among the least accessible applications I've tested. Real-time data tables, interactive charts, and order placement flows are almost entirely inaccessible to screen reader users.
- KYC and account opening processes rely on inaccessible PDFs, CAPTCHA that doesn't work with assistive technology, and OTP flows that time out before a screen reader user can complete them.
- Mobile applications from most brokers and mutual fund platforms have unlabelled buttons, missing headings, and touch targets that are too small.
- Customer support portals often use chat widgets that are completely inaccessible — I can't even open them with a keyboard.
This isn't a matter of fixing a few alt texts. For most organisations in this sector, achieving WCAG 2.1 AA conformance requires a significant, sustained effort.
What Happens If You Don't Comply?
There are multiple layers of risk:
- SEBI enforcement action under SEBI regulations, including potential penalties under the SEBI Act, 1992
- RPwD Act penalties under Sections 89–92, which can include fines and, in cases of persistent violation, imprisonment
- Legal action from users — persons with disabilities can file complaints with the Chief Commissioner for Persons with Disabilities or approach the courts directly
- Reputational risk — as awareness grows, organisations seen as excluding persons with disabilities face increasing public scrutiny
What You Should Do Now
If this mandate applies to your organisation, here is the practical path forward:
- Conduct a comprehensive accessibility audit. Not just an automated scan. You need manual testing with screen readers and keyboard-only navigation, covering your website, mobile apps, and key documents. I've written about why automated tools alone are not enough.
- Prioritise by user impact. Start with the flows that matter most: account opening, login, transactions, and customer support. These are the paths that persons with disabilities need to complete independently.
- Remediate systematically. Work with your development teams to fix issues in priority order. Build accessibility into your design system so that new features are accessible from the start.
- Prepare your documentation. Create a VPAT (Voluntary Product Accessibility Template) or ACR (Accessibility Conformance Report) that documents your current conformance level. Publish an accessibility statement on your website.
- Train your teams. Developers, designers, QA engineers, and content authors all need to understand accessibility. A one-time workshop is not enough — accessibility needs to become part of how your teams work.
- Establish ongoing monitoring. Accessibility is not a one-time project. Build it into your release cycle with automated checks, manual testing, and regular audits.
- Set up a feedback channel. Give users with disabilities a clear, accessible way to report barriers. And actually respond to that feedback.
Why This Matters Beyond Compliance
I'm a screen reader user. I also invest. I trade. I use banking apps and mutual fund platforms. And I can tell you from daily experience: most of these platforms make it unnecessarily difficult for me to manage my own money.
This mandate isn't just about avoiding penalties. It's about giving millions of Indians with disabilities the ability to participate in the financial system independently. According to the 2011 Census, India has over 26 million persons with disabilities. The actual number, accounting for under-reporting, is likely much higher.
These are your customers. They want to use your platforms. They just need your platforms to work with the tools they depend on.
I follow this space closely and understand the regulation well. If you want to discuss what the mandate means in practical terms, feel free to reach out or connect with me on LinkedIn.