If SEBI regulates you, this circular names you.
The July 2025 circular applies to regulated entities across the market — public or private, listed or not. The question inspectors ask is not whether you are covered. It is whether your evidence file exists.
Trading portals, back-office investor touchpoints, and contract notes delivered as PDFs.
Scheme pages, NAV disclosures, KIMs, SIDs, and annual report PDFs.
Investor portals and private placement documentation.
Client dashboards, disclosure documents, and periodic reports.
High-volume investor self-service flows where screen-reader failures surface fastest.
Published ratings, methodology documents, and press releases.
Four requirements. None of them are optional.
WCAG 2.1/2.2 AA conformance
Websites and mobile applications tested against the W3C success criteria — keyboard navigation, focus order, contrast, form labels, screen-reader semantics. A Lighthouse score is not conformance.
IS 17802 mapping
India's BIS ICT-accessibility standard, harmonised with WCAG. SEBI observations cite IS 17802 clauses, so your evidence must map findings to the Indian standard — not just WCAG numbers.
IAAP-certified auditors
The circular requires the audit to be conducted by professionals holding IAAP certification — CPACC or WAS. An internal QA pass or an uncertified vendor report does not satisfy this clause.
Deadline: July 31, 2026
One year from issuance. Subtract the audit (3–6 weeks), your remediation cycle, and re-verification — the practical start window is now, not Q2 of FY27.
The circular asks for certifications. Ours are the ones it names.
AccessSure audits are run by the ITQCR team — Ornate Software Solutions' GOI-authorised, STQC SAB SETL-1 empanelled testing laboratory. The auditors hold IAAP CPACC and WAS certifications. This is the same lab that certifies Indian government websites under GIGW 3.0, applying the same evidence discipline to SEBI work.
Every audit ships with the evidence file an inspector asks for:
- Criterion-level findings — each issue cited to the exact WCAG success criterion and IS 17802 clause
- Annotated screenshots — the failing element outlined in its real page context
- NVDA screen-reader evidence — recorded navigation showing what an investor actually hears
- Developer remediation list — failing selector, fix pattern, and priority, ready for your sprint board
- PDF document remediation — annual reports and disclosures fixed to a WCAG 2.2 AA target, implemented per PDF/UA-1 and verified by veraPDF
- Re-verification pass — post-remediation re-test so the file you keep reflects the site you actually run
A workable timeline — if it starts now.
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Week 0
Scope call
You share the investor-facing properties — web, app, and the document set. We return a fixed scope, timeline, and fee. No system access needed at any stage.
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Weeks 1–6
IAAP-certified audit
Automated scanning plus expert manual review: keyboard flows, NVDA navigation, forms, documents. Findings mapped to WCAG 2.1/2.2 AA and IS 17802.
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Your window
Remediation
Your developers work from our ticket-ready fix list. Annual report and disclosure PDFs go through our remediation engine in parallel — minutes per document, not days.
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Before the deadline
Re-verification & evidence file
We re-test, close the loop on every finding, and hand over the final evidence pack — the document your compliance officer files and your next inspection cites.
Asked in every scope call. Answered here.
We already passed an accessibility scan. Doesn't that count?
Automated scanners surface roughly 30–40% of real barriers and produce no IAAP-certified evidence. The circular's requirement is an audit by certified professionals — the scanner output can feed the audit, but it cannot replace it.
Does this apply to us if we're a private company?
Yes. The mandate follows SEBI registration, not listing status. A private AIF or portfolio manager is covered exactly as a listed AMC is.
Our website is fine — it's the PDFs we're worried about.
Reasonable worry. Investor-facing PDFs — annual reports, scheme documents, KIMs — are among the most-cited gaps in inspections, and manual PDF remediation runs 4–8 hours per document. Our engine remediates to a WCAG 2.2 AA target, implemented per PDF/UA-1 and verified by veraPDF, in minutes per document, including documents in 13 Indian languages.
What does it cost?
Scoped per property. An investor-facing website audit with evidence pack starts at ₹50,000; PDF remediation from ₹5 a page with volume rates for annual-report batches. The scope call is free and commits you to nothing.
Is there really time before July 31, 2026?
Starting in June: yes, tightly. The audit lands by mid-July, your developers get a compressed remediation window, and we re-verify against the deadline. Every week of delay removes slack from your side of the timeline, not ours.
Thirteen months became seven weeks.
The circular gave entities a year. Most of it is gone. A scope call this week puts the audit on the calendar with room left for remediation.