We'll share the results in Issue #3. If you answered C, D, or E — keep reading. This issue was written for you.

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Your Website Is Not a Brochure. It Is a Regulated Platform.

Every IA and RA must maintain a SEBI-compliant website. That website carries mandatory legal disclosures — and under the accessibility circular, every element must meet WCAG 2.1 AA. Here is what that means, element by element.

✅  Mandatory legal content — update before March 31, at zero cost

1  ·  The Investor Charter

SEBI mandates every IA and RA publish an Investor Charter. The December 8, 2025 circular adds a new requirement: the Charter must now explicitly include "Investors' Right to Digital Accessibility."

✅  ZERO-COST ACTION — DO THIS THIS WEEK Add this line to your Investor Charter 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 accessible to persons with disabilities, in compliance with SEBI's Digital Accessibility Circular (No. 2025/111 and subsequent circulars)." 10 minutes. Zero cost. Do it before March 31.

2  ·  SEBI Registration Certificate & Disclosure Page

The most common failure: the certificate is published as a scanned image. A screen reader cannot read an image of text — it reads "image" and moves on.

• Convert certificate scans to tagged PDFs or accessible HTML text
• Registration number must be live text on the page — not embedded in an image

3  ·  Conflict of Interest Disclosure

Mandatory for IAs. If this is a PDF, it must be a tagged, accessible PDF — not a scanned image, not an untagged print-to-PDF. Specifically:

• Logical reading order defined in tag structure
• Heading hierarchy — H1 title, H2 sections, H3 sub-sections
• No security settings that disable accessibility APIs
• Language declared in PDF metadata

4  ·  Fee Structure and Disclosure Document

Fee tables rendered as images are inaccessible. Must be live HTML tables with proper header markup, or tagged PDF tables with header rows defined. A screen reader user must be able to read across a fee table and understand which column they are in.

5  ·  Risk Profiling Questionnaire (if web-based)

The most complex form on an IA's website — and the most commonly inaccessible. WCAG 2.1 AA requires:

• Every field has a programmatic label — not just visual positioning near the input
• Dropdowns keyboard-navigable — no mouse required
• Error messages announced by screen readers — not just shown in red
• If CAPTCHA exists — audio alternative mandatory
• Entire form completable using keyboard only

6  ·  Grievance Page and SCORES Pathway

If the only path to raising a complaint is a phone number — that is a gap for a Deaf investor. Email address, online form, or text-based pathway must exist and be accessible. The SCORES complaint pathway must be clearly labelled and reachable by keyboard navigation.

7  ·  Video Content

• Closed captions on every video — accurate, time-synced, reviewed (not raw auto-generated)
• Audio descriptions for information conveyed visually without narration
• Text transcript available for Deaf-blind users

8  ·  Calculators and Interactive Tools

SIP calculators, goal planners, return projectors. Every slider and input must have a keyboard equivalent. 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 — even as a link to a PDF on your website — are in scope. A 40-page client agreement published as an untagged PDF is inaccessible to a screen reader user. The fix: regenerate from a structured Word document with proper heading styles applied before PDF conversion.

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Your Documents Are Your Core Product. Right Now, They're Inaccessible.

Every document delivered digitally to an investor must meet WCAG 2.1 accessible PDF standards. Here is what that means for each document type.

💡  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 or InDesign — and every document produced from that template going forward is automatically accessible. This transforms hundreds of remediation tasks into one.

Research Reports — What a Screen Reader Actually Encounters

What the PDF Contains	What the Screen Reader Experiences
Company name and target price in styled header	"Image" or nothing — if inside a graphic banner
DCF model — 8 columns × 20 rows	160 numbers in a row, no column or row context
Price target chart showing 52-week range	"Image" — the entire performance narrative is gone
Risk factors section with sub-headings	Flat unstructured text — no navigation possible
Rating history table	Unstructured data stream — no column relationships

Financial Plans and Advisory Reports (IA)

Every visual element that conveys information must have a text equivalent:

• Asset allocation pie chart → alt text: "Equity 65%, Debt 25%, Gold 10%"
• Goal progress bar → alt text describing current corpus vs. target
• Risk profiling gauge → must be text, not an image of a needle on a dial
• Projected return chart → data table alternative required

📋  ACCESSIBLE PDF CHECKLIST — 10 CRITERIA ☐  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 body 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. Here is what SEBI requires of every KYC and client registration flow:

✓	Every form field has a programmatic label — not just visual positioning near the input
✓	OTP fields accessible — no auto-submit on 6th digit, countdown timer announced, paste supported
✓	Disability status field is mandatory — with specific assistance options
✓	Human-reviewed alternative — no PwD application auto-rejected without human review
✓	Video KYC has audio-guided mode — instructions via audio, not visual prompts only

⚠️  IF YOU USE SIGNZY, DIGIO, IDfy OR ANOTHER KYC VENDOR Ask your vendor: "Have you conducted an IAAP-certified accessibility audit? Can you provide a conformance certificate?" If the answer is no — their platform's gaps are in your audit scope.

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If You Hold Both IA and RA Registrations

For Your IA Registration	For Your RA Registration
Reporting Authority: BSE Ltd. (IAASB) Portal: BSE IAASB portal Subject: [IA Reg No.]-[Firm Name]-Investment Adviser-Submission of status of readiness and compliance to the accessibility requirements for digital platforms	Reporting Authority: BSE Ltd. (RAASB) Portal: BSE RAASB portal Subject: [RA Reg No.]-[Firm Name]-Research Analyst-Submission of status of readiness and compliance to the accessibility requirements for digital platforms

💡  ONE AUDIT. TWO FILINGS. A single IAAP-certified audit covers both registrations in one engagement. But the 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 — Complete Platform Checklist

One row per platform. URL or name, Yes/No on WCAG AA (honest — for most of you: No), and a brief remark on your planned audit and remediation timeline.

📧  COPY THIS SUBJECT LINE [Reg No.]-[Firm Name]-[Investment Adviser / Research Analyst]-Submission of status of readiness and compliance to the accessibility requirements for digital platforms

No.	Platform / URL	WCAG AA?	Remarks
1	Main website — www.yourfirm.com	No	Audit scoping in progress. Compliance target: July 31.
2	Research report / financial plan template (PDF)	No	Template remediation in audit scope.
3	KYC / onboarding flow	No	Vendor conformance certificate being requested.
4	Mobile app — iOS	No	In audit scope.
5	Mobile app — Android	No	In audit scope.
6	Client login portal	No	In audit scope.
7	Email newsletter / research distribution	No	HTML email template accessibility under review.
8	YouTube / video content	No	Captions and transcripts to be added.
9	Investor Charter page	In progress	Right to Digital Accessibility being added. Target: March 31.
10	All mandatory disclosure PDFs	No	COI, fee, T&C templates — remediation in scope.

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How EnableUser Can Help You Right Now

🆓  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. →  Email [email protected] — subject: Free Readiness Assessment

📋  Request a Quote — Full Audit Engagement IAAP-certified audit with PwD usability testing. Limited slots before April 30. Covers your complete platform scope. Produces Table C3 and C4 reports ready for BSE submission. Handles both IA and RA filing tracks in one engagement. Tell us: registration type (IA / RA / both), number of platforms, report volume per year. We will send a scoped quote within 48 hours. →  Email [email protected] — subject: Audit Quote Request

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Coming Up in the Next Issues

Issue #3	Myth: "We have 500 pages — we need to cut content to reduce audit cost." Decoding the per-URL pricing scam.
Issue #4	Myth: "We installed an accessibility widget. We are compliant." Why overlays don't work and what SEBI's auditor will find.
Issue #5	How IAAP audits are structured — WCAG-EM, Success Criteria, PwD testing. What a professional audit actually involves.

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EnableUser — Digital Accessibility for India's Financial Services

[email protected]  ·  +91 9990397978  ·  calendar.app.google/H3offAViUNeAAHe2A

Please forward this issue to your compliance head, legal advisor, or management team.

Circulars: 2025/111 (Jul 31) · 2025/121 (Aug 29) · 2025/131 (Sep 25) · I/187/2025 (Dec 8)  ·  sebi.gov.in