ENABLEUSER Digital Accessibility for India's Financial Services Issue #2 · March 2026 · For Investment Advisers & Research Analysts
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What Your Website, Reports, and Legal Disclosures Actually Need to Be Accessible A complete, platform-by-platform guide for IAs and RAs — with the Annexure B checklist, the document template fix, and the two things you can do before March 31 at zero cost.
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✍️ | A note before we begin We have been getting one question more than any other this month: "I'm an IA / RA — what do I actually need to do, and when?" This issue is our complete answer. We have gone platform by platform, document by document, disclosure by disclosure. If you forward only one issue to your compliance team this year, make it this one. — Suryanshu Gupta, CPWA | EnableUser |
First — The Deadline Confusion, Settled
Most IAs and RAs we speak to are in one of two positions: they have over-panicked and believe they need a completed audit by March 31, or they have under-prepared and believe March 31 is just about appointing an auditor. Both are wrong.
Deadline | What Is Required | What Is NOT Required |
Mar 31, 2026 | Annexure B — readiness status per platform. One filing per registration. That is all. | Audit report. Auditor appointment proof. Fixed platforms. Table C2. |
Apr 30, 2026 | Initial audit report — Table C3. IAAP-certified auditor required. PwD usability testing mandatory. | Fully fixed platforms. Complete remediation. |
Jul 31, 2026 | Remediation complete. Final audit report — Table C4 with evidence. |
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🔑 The one thing to remember about March 31 The auditor appointment deadline (originally December 14, 2025) was not moved to March 31. It was removed entirely by the December 8 circular. March 31 requires only Annexure B — your honest, platform-by-platform readiness status. Answering 'No' to WCAG AA compliant is expected. Filing nothing is the compliance failure.
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📊 Quick Poll — Where Are You Right Now?
Before we go deeper — we want to understand where IAs and RAs across India actually stand. Reply to this newsletter with the letter that matches your situation, or click your answer if you're reading this online.
Where are you in your SEBI accessibility compliance journey?
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A | I have already appointed an IAAP-certified auditor and am ready to go. |
📊 Quick Poll — Where Are You Right Now?
- I have already appointed an IAAP-certified auditor and am ready to go.
- I am in the process of evaluating auditors but haven't appointed one yet.
- I haven't started yet — I wasn't sure what was actually required.
- I didn't know this circular applied to me as an IA / RA.
- I think we're compliant already — our website passed an automated scan.
Your Website Is Not a Brochure. It Is a Regulated Platform.
Every IA and RA is required by SEBI to maintain a compliant website. That website carries mandatory legal disclosures. Under the accessibility circular, every element of it — every page, every PDF, every form, every video — must meet WCAG 2.1 AA. Here is exactly what that means, element by element.
MANDATORY LEGAL CONTENT — UPDATE BEFORE MARCH 31, AT ZERO COST |
1. The Investor Charter
SEBI mandates that every IA and RA publish an Investor Charter on their website. The December 8, 2025 circular adds a new requirement: the Investor Charter must now explicitly include "Investors' Right to Digital Accessibility" as a stated investor right.
✅ Zero-cost action you can take this week Open your Investor Charter. Add a line under investor rights: "Right to Digital Accessibility — Investors have the right to access all digital platforms, documents, and services of this firm in a manner that is accessible to persons with disabilities, in compliance with SEBI's Digital Accessibility Circular (No. 2025/111 and subsequent circulars)." This takes 10 minutes. If your Investor Charter does not have this, it is non-compliant right now — independent of any audit.
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2. SEBI Registration Certificate and Disclosure Page
Your SEBI registration number, certificate, and regulatory disclosures must be on your website in accessible format. The most common failure here: the certificate is published as a scanned image of the physical document.
→ A screen reader cannot read an image of text. It reads 'image' and moves on.
→ The registration certificate must be a tagged PDF or accessible HTML text — not a JPG or a scanned PDF.
→ The registration number and category must be in readable text on the page, not embedded in an image.
3. Conflict of Interest Disclosure
Mandatory for IAs. If this is a PDF on your website — and it almost certainly is — here is what accessible means for that document:
→ Logical reading order — screen readers follow the tag structure, not the visual layout
→ Heading hierarchy — H1 for document title, H2 for sections, H3 for sub-sections
→ No password protection or security settings that disable accessibility features
→ Language of document declared in metadata
→ No scanned pages — the entire document must be live text, not images
4. Fee Structure and Disclosure Document
Your fee model, billing schedule, and service scope. If this is a table on a webpage — are the table headers marked up correctly? If it is a PDF — is it tagged? A fee table rendered as an image, or a PDF with no heading structure, is inaccessible.
5. Risk Profiling Questionnaire (if web-based)
This is the most complex web form on an IA's website — and the most commonly inaccessible one. Here is what WCAG 2.1 AA requires of every field:
→ Every field has a programmatic label — not just visual positioning near the input
→ Dropdowns are keyboard-navigable — no mouse required
→ Error messages are announced by screen readers — not just shown in red
→ The submit button has an accessible name — not just an icon with no text
→ If CAPTCHA exists — an audio alternative must be provided
→ The form must be completable using keyboard only — no mouse traps
6. Grievance Page and SCORES Pathway
Your grievance mechanism must be accessible — and it must be operable by a person with a disability. If the only path to raising a complaint is a phone number — that is an accessibility gap for a Deaf investor. Email address, online form, or text-based pathway must exist and be accessible.
7. Video Content
If your website has market commentary videos, onboarding explainers, or educational content — every video must have:
→ Closed captions — accurate, time-synced, not auto-generated without review
→ Audio descriptions for any information conveyed visually without narration
→ A transcript available as accessible text for Deaf-blind users
8. Calculators and Interactive Tools
SIP calculators, goal planners, return projectors. Every interactive element must be keyboard-operable. Slider inputs must have keyboard equivalents. If the output is a visual chart — a text alternative showing the same data must be available.
⚠️ The one that surprises most IAs and RAs Terms and Conditions and Client Agreement documents — if published on your website, even as a link to a PDF — are in scope. A 40-page client agreement published as an untagged PDF is inaccessible to a screen reader user.
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Your Documents Are Your Core Product. Right Now, They're Inaccessible.
For a Research Analyst, the research report is what you produce. For an Investment Adviser, the financial plan is your deliverable. Under SEBI's circular, every document delivered digitally to an investor must meet WCAG 2.1 accessible PDF standards. Here is what that means for each document type — and the single most important thing to understand about fixing it.
💡 The Template Insight — Read This First The fix for document accessibility is never report-by-report or plan-by-plan. It is template-level. Fix the template in Word, InDesign, or whatever tool generates your documents — and every document produced from that template going forward is automatically accessible. This transforms what feels like hundreds of remediation tasks into one.
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Research Reports — Initiations, Result Updates, Sector Notes, Thematic Reports
These are dense, financially complex PDFs. Here is what a screen reader encounters when reading a typical Indian research report today:
What the PDF Contains | What the Screen Reader Experiences |
Company name and target price in a styled header | "Image" or nothing — if in a graphic banner |
DCF model table with 8 columns and 20 rows | A stream of 160 numbers with no context of which column or row |
Price target chart showing 52-week range | "Image" — the entire performance narrative is invisible |
Risk factors section with sub-headings | Flat unstructured text — no navigation possible |
Rating history table | Unstructured data stream — no column relationships |
The fix: tag the InDesign or Word template. Define heading styles. Mark tables with proper header rows. Add alt text to every chart. Set reading order. This is a one-time fix per template that covers every report produced from it — whether you publish 5 reports a year or 250.
Financial Plans and Advisory Reports (IA)
Goal analysis, asset allocation, risk assessment, projected returns, rebalancing schedules. These documents combine narrative text with visual charts, tables, and graphical risk indicators. Every visual element that conveys information must have a text equivalent.
→ Asset allocation pie chart → alt text: "Asset allocation: Equity 65%, Debt 25%, Gold 10%"
→ Goal progress bar → alt text: "Goal: Child's education. Current corpus: ₹8.2L. Target: ₹25L. Progress: 33%"
→ Risk profiling result graphic → must be text, not an image of a gauge
→ Projected return chart → data table alternative required
Quarterly Client Review Reports
Performance summaries, portfolio drift, benchmark comparison. If generated from a template — Word, Excel, or a reporting tool — the template is the fix point. Excel-to-PDF conversions require specific settings to produce tagged output. Most do not have these settings configured.
Disclosure Documents Delivered at Onboarding
Conflict of interest disclosure, fee disclosure, terms of engagement — delivered to the client as PDFs when they sign on. If sent digitally (email, WhatsApp, client portal), they are in scope. The fix: regenerate from structured Word source with proper heading styles.
📋 Checklist: What makes a PDF accessible ✓ Document title set in PDF metadata ✓ Language declared (English / Hindi as applicable) ✓ Heading hierarchy applied (H1 → H2 → H3) ✓ All tables have header rows defined ✓ All images and charts have descriptive alt text ✓ Reading order matches visual layout ✓ No security settings that disable accessibility APIs ✓ Bookmarks/table of contents for documents over 10 pages ✓ Colour is not the only means of conveying information (e.g. red = loss) ✓ Minimum 4.5:1 colour contrast ratio for all text
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Your Onboarding Flow — The Gate Every New Client Passes Through
If a person with a disability cannot complete your digital onboarding, they cannot become your client. That is not a hypothetical — it is the current state of virtually every IA and RA digital onboarding flow in India. Here is what SEBI's circular requires:
✓ | Every form field has a programmatic label Not just visually positioned near the input — the label is in the HTML/code |
✓ | Document upload is operable without sight Camera trigger announced, capture confirmed via audio, file accepted message announced |
✓ | OTP fields are accessible No auto-submit on 6th digit, countdown timer announced, paste supported |
✓ | Disability status field is mandatory With specific assistance options — screen reader, motor assistance, sign language interpretation |
✓ | Human-reviewed alternative exists No PwD application can be auto-rejected without a human reviewing it first |
✓ | Video KYC has audio-guided mode Instructions delivered via audio, not visual prompts only |
If You Hold Both IA and RA Registrations — Read This Carefully
For Your IA Registration | For Your RA Registration |
Reporting Authority BSE Ltd. (IAASB) Submission Portal BSE IAASB portal Email Subject Line [IA Reg No.]-[Firm Name]-Investment Adviser-Submission of status of readiness... | Reporting Authority BSE Ltd. (RAASB) Submission Portal BSE RAASB portal Email Subject Line [RA Reg No.]-[Firm Name]-Research Analyst-Submission of status of readiness... |
💡 One audit. Two filings. A single IAAP-certified audit can cover both your IA and RA obligations in one engagement — the same auditor tests your website, your financial plans, your research reports, and your onboarding flow together. But the compliance submissions are two separate filings: one to BSE IAASB with your IA registration number, one to BSE RAASB with your RA registration number. Most dual-registration entities discover this mid-submission. You now know before you start.
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Your Annexure B — The Complete Platform Inventory
Here is exactly what to include in your Annexure B submission. One row per platform. For each: URL or name, Yes/No on WCAG AA compliance (honest answer — for most of you, No), and a brief remark on your audit and remediation timeline.
📧 Copy this subject line exactly For IAs: [IA Registration No.]-[Firm Name]-Investment Adviser-Submission of status of readiness and compliance to the accessibility requirements for digital platforms For RAs: [RA Registration No.]-[Firm Name]-Research Analyst-Submission of status of readiness and compliance to the accessibility requirements for digital platforms
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No. | Platform / URL | WCAG AA? | Remarks |
1 | Main website — www.yourfirm.com | No | Audit being scoped. Auditor procurement in progress. Audit to commence [Month]. Compliance target: July 31, 2026. |
2 | Research report template (PDF) | No | Template accessibility remediation to be conducted as part of audit. All future reports to be produced from accessible template. |
3 | Financial plan template (PDF) | No | Template remediation in scope. See above. |
4 | Client onboarding / KYC flow | No | Third-party KYC vendor engaged. Vendor conformance certificate being sought. Fallback: include in audit scope. |
5 | Mobile app — iOS (if applicable) | No | Included in audit scope. |
6 | Mobile app — Android (if applicable) | No | Included in audit scope. |
7 | Client login portal (if any) | No | Included in audit scope. |
8 | Email newsletter / research distribution | No | HTML email template accessibility to be reviewed. |
9 | YouTube / video content channel | No | Captions to be added to all videos. Transcripts to be published. |
10 | Investor Charter page | No / In progress | Right to Digital Accessibility being added. Target: March 31, 2026. |
11 | Grievance / SCORES pathway page | No | Accessible text-based complaint path being established. |
12 | All mandatory disclosure PDFs | No | Conflict of interest, fee, T&C — template remediation in scope. |
How EnableUser Can Help You Right Now
We work specifically with IAs and RAs on exactly this scope. We are IAAP-certified. We conduct mandatory PwD usability testing. We produce SEBI-format audit reports and handle both IA and RA filing tracks in one engagement. Here are two ways to start:
🆓 Free Readiness Assessment Get your Annexure B ready before March 31 — at no cost. We run an automated WCAG scan of your website and key platforms, give you a structured readiness report, and format it into Annexure B — ready to submit to BSE IAASB or RAASB. No obligation, no commitment beyond the assessment. → [email protected] with subject: Free Readiness Assessment
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📋 Request a Quote — Full Audit Engagement IAAP-certified audit with PwD usability testing. Limited slots before April 30. Covers your complete platform scope — website, document templates, onboarding flow, mobile app, disclosure PDFs. Produces Table C3 and C4 formatted reports ready for BSE IAASB and RAASB submission. Remediation support included. Tell us: your registration type (IA / RA / both), number of platforms, and report volume per year. We will send you a scoped quote within 48 hours. → [email protected] with subject: Audit Quote Request
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Coming Up in the Next Issues
Issue #3 | Myth: "Our website has 500 pages — we need to cut content to reduce audit cost." Decoding the per-URL pricing scam and what audit scope actually means. |
Issue #4 | Myth: "We installed an accessibility widget. We are now compliant." Why overlay widgets don't work, what SEBI's auditor will find, and what actually does. |
Issue #5 | How IAAP audits are structured — WCAG-EM, Success Criteria, PwD testing. Demystifying what a professional accessibility audit actually involves. |
EnableUser — Digital Accessibility for India's Financial Services [email protected] | +91 9990397978 | Please forward this issue to the compliance head, legal advisor, or management team at your firm. Circular references: 2025/111 (Jul 31) · 2025/121 (Aug 29) · 2025/131 (Sep 25) · I/187/2025 (Dec 8) · sebi.gov.in |