The Accessibility Compliance Series
Your Website Is Broken.
Here's Exactly How.
The deepest guide to web accessibility failures in Indian financial services — by platform type, by regulated entity, by failure category.
A NOTE BEFORE WE BEGIN Issue #2 asked you a poll question: where are you in your compliance journey? The most common answer was C — 'Haven't started. Wasn't sure what was required.' This issue is for you. Not to scare you — to show you exactly what is broken on your website right now, why it's broken, and what fixing it actually involves. Platform by platform. Entity by entity. — Suryanshu Gupta, CPWA | EnableUser |
WHAT'S IN THIS ISSUE
Everything your compliance team, tech team, and legal advisor need to read — in one place.
01 | The Numbers — And Why They're Worse Than You Think 91.55% of Indian finance websites fail. 71.23% fail at Level A — the absolute floor. |
02 | The Five Failures on Every Financial Website Colour contrast, headings, alt text, unlabelled forms, keyboard inaccessibility. |
03 | By Platform — WordPress, Custom PHP, React, Static Sites What you're built on determines what you're broken by. |
04 | By Regulated Entity — Brokers, IAs, RAs, PMS, AIFs Your entity type determines your specific exposure — mapped precisely. |
05 | The Deadline Confusion — All Four Misreadings, Corrected The auditor appointment deadline was removed. March 31 = Annexure B only. |
06 | The Per-URL Pricing Myth Why per-URL pricing is compliance theatre — and what a real audit looks like. |
01 | The Numbers — Worse Than You Think
The most comprehensive study conducted on digital accessibility in India's financial sector evaluated 100 financial institutions. Here is what it found:
91.55%
of Indian finance websites FAIL accessibility
100 institutions evaluated · November 2024
71.23%
of errors fail at WCAG Level A — the absolute floor
Not Level AA. Not even the intermediate level. The absolute floor of accessibility.
97%
of sites have missing or incorrect headings
Screen reader users navigate by headings. On 97% of sites, that navigation is broken.
96%
of home pages have image description errors
Every logo, every banner, every chart image. Invisible to a screen reader.
And globally, the WebAIM Million 2024 report — an annual automated scan of the top 1 million websites — found that 96.3% of home pages have detectable WCAG failures. India's financial sector sits at the extreme end of an already bad global average.
⚠️ ON AUTOMATED TOOLS — READ THIS BEFORE YOU RUN A SCAN Automated accessibility scanners — detect approximately 30–40% of WCAG failures at best. The 60–70% they miss include: focus management failures, screen reader announcement logic, form field association errors, ARIA live region behaviour, heading hierarchy issues in dynamically rendered content, and PDF document structure. If you ran an automated scan and got a clean report, you have found less than half of what is actually broken |
02 | The Five Failures on Every Financial Website
These five failures appear consistently — across every type of financial services website in India. If your website has all five, you are not unusual. You are typical.
1 | Colour contrast failures — present on 81% of websites globally That grey text on a white background that looks 'modern' and 'minimal'? For a person with low vision, it is illegible. WCAG requires a 4.5:1 contrast ratio for normal text and 3:1 for large text. In Indian financial services specifically: The use of green for positive P&L and red for negative P&L — with colour as the only differentiator — is a WCAG 1.4.1 failure. A colour-blind investor cannot tell their profit from their loss. |
2 | Missing or incorrect heading hierarchy — present on 97% of Indian finance sites A heading hierarchy is how screen reader users navigate a webpage. With NVDA or JAWS, a user can press H to jump between headings — the way a sighted user would skim. On a website with no heading hierarchy, a screen reader user has no navigation landmarks. In practice: An IA website where the firm name is styled as bold text rather than an H1. The service descriptions are large text styled via CSS but not heading tags. Zero headings. A blind investor trying to navigate to 'Contact Us' must listen to the entire page sequentially. |
3 | Missing image alt text — present on 96% of Indian finance home pages Every image without alt text is silent to a screen reader — not described, completely absent. Most commonly missing: firm logo, founder/team photos, infographics, trading screenshots, decorative banners. The nuance most developers miss: Decorative images should have alt="" (empty alt, not missing alt). Informative images must have descriptive alt text. Functional images (button or link images) must have alt text describing the function. Three different treatments — most developers apply zero. |
4 | Unlabelled form fields — the most critical failure for investment firms A form field that has a visible label positioned near the input but with no programmatic association is inaccessible. The screen reader user focuses on the input and hears 'edit text' — nothing else. Why this is particularly bad for financial services: The risk profiling questionnaire, the KYC form, the callback request form, the grievance form — every critical investor interaction involves form fields. If none are labelled, a screen reader user cannot use any of them. |
5 | Keyboard inaccessibility — the failure you cannot find with a scanner Every interactive element must be operable using only a keyboard — no mouse required. This matters for motor-impaired users and screen reader users who navigate entirely by keyboard. Most common failures: hamburger menu that only opens on mouse hover, dropdown that traps keyboard focus, cookie consent banner that cannot be dismissed by keyboard, SIP calculator requiring a click-only slider, login forms where Tab skips the password field. |
03 | By Platform — What You're Built On
The platform your website is built on is not just a technology choice. It is a prediction of which accessibility failures you have and how hard they will be to fix.
WordPress
Most common for: IAs, RAs, smaller financial firms. Estimated 60–70% of IA and RA websites in India run on WordPress.
WordPress core is reasonably accessible. The ecosystem around it is not. Elementor and WPBakery generate semantically incorrect HTML:
▸ Heading elements used for visual sizing, not document structure — 6 H2s with no H1
▸ Icon-only buttons (social links, menu toggles) that announce only as 'link' with no destination
▸ Contact Form 7 and WPForms — both widely used, both have label association issues in default installs
▸ Auto-advancing carousels with no pause control — a WCAG 2.2.2 violation on most IA/RA home pages
▸ PDF download links labelled 'Click here' — which tells a screen reader user nothing
Fix Complexity: Medium. Most issues fixable without rebuilding. Heading hierarchy corrected in CMS. Form labels via plugin settings. Hardest part is the theme — visual builders may require custom CSS/JS overrides.
Custom PHP
Most common for: Traditional full-service brokers, older exchange portals, legacy PMS firm sites. Sites built in the 2010s.
▸ Table-based layouts — data tables used for visual layout confuse screen readers
▸ Image-heavy navigation — menus and section headers as images, every one a missing alt text failure
▸ Session timeout modals — 'Your session expires in 60 seconds' that trap keyboard focus
▸ JavaScript-driven animations and hover-only interactions — completely keyboard-inaccessible
Fix Complexity: High. Table-based layouts require HTML restructuring. Most pragmatic path: fix critical investor-facing flows first, then address structure in a planned rebuild.
React / Single Page Applications
Most common for: Zerodha's Kite, Groww, Upstox, Dhan, Angel One, AMC direct portals, platforms rebuilt after 2019.
▸ Route changes with no announcement — screen reader doesn't know navigation occurred
▸ Live market data without ARIA live regions — watchlist updates are silent to screen readers
▸ Custom components without accessibility — order type selectors built as styled divs, no keyboard access
▸ Order confirmation modal — focus stays behind the modal. Confirm and Cancel are unreachable.
▸ Dynamic error messages — 'Insufficient margin' shown in red but not announced
Fix Complexity: High — but scalable at component level. Fix the modal once, every modal is fixed. Fix the data table once, watchlist + positions + order book all fixed. That window is closing fast.
Static HTML / Wix / Webflow
Most common for: Smallest IAs and RAs — individual practitioners, boutique research operations.
Wix and Webflow have made significant accessibility investments. The content layer is the owner's responsibility: headings, alt text, link labels, captions, PDF accessibility.
Fix Complexity: Low. Primarily a content audit. No code changes. An afternoon's work with guidance.
04 | By Regulated Entity — Your Specific Exposure
The five common failures apply to everyone. But the specific profile varies dramatically by entity type.
Stockbrokers — The Widest Scope, The Most Complex Failures
A stockbroker has more investor-facing digital surface area than any other RE except an exchange.
Platform / Asset | Most Likely Failure |
Marketing website | WordPress or Custom PHP. Heading chaos, missing alt text, unlabelled forms. |
Trading terminal (web) | React or custom JS. Live data with no ARIA. Order entry unlabelled. Modal focus broken. Colour-only P&L. |
Mobile app (iOS/Android) | VoiceOver/TalkBack testing almost never done. Chart data invisible. |
Client portal | Back-office vendor (Apex, ODIN). Tables without headers. Download buttons with no context. |
Contract notes (PDF) | Untagged PDFs from back-office. No structure, no reading order. |
KYC / onboarding | No disability status field. No audio-guided Video KYC. Auto-rejection without human review. |
Investment Advisers — The Document Problem Is Enormous
An IA's primary output is documents — financial plans, advisory reports, risk profiling results, fee disclosures. Most are PDFs. None are accessible.
Asset | Specific Failure |
WordPress website | Elementor-built. Zero heading hierarchy. Logo has no alt text. Contact form labels not associated. |
Investor Charter (PDF) | Often a scanned image or Word print-to-PDF. No tags. Rights section invisible. |
Financial plan (PDF) | Pie chart = image with no alt text. Goal table = unstructured data. Risk gauge = image of a needle. |
Risk profile form | Radio buttons with visual labels but no fieldset/legend. Scale inputs with no keyboard alternative. |
Fee disclosure | Fee table published as an image. Screen reader reads values with no column context. |
Research Analysts — 150+ PDFs a Year, Every One Inaccessible
An RA publishing 3 reports per week generates 150 PDFs a year. Fix the template once, every future report inherits the fix.
WHAT A SCREEN READER ENCOUNTERS IN A TYPICAL RA REPORT Cover page: 'image' (logo) … 'image' (graphic) … unstructured text with no heading. DCF model table (8 columns × 20 rows): 160 numbers read sequentially. Revenue. 45231. 52890. 61034. EBITDA. 8942. No column context. Price target chart: 'image.' The entire 52-week range, current price, and target are gone. Risk factors: Flat text. No navigation landmarks. No heading hierarchy. |
Portfolio Management Services — The Statement Problem
A PMS firm's primary output is the portfolio statement — monthly PDFs showing holdings, performance, sector allocation. Most are generated by WealthSpectrum. The PDF engine produces untagged documents. One platform fix covers the entire PMS industry.
AIFs — The Institutional Exemption Assumption
The most common AIF belief: 'Our LPs are institutions. Accessibility doesn't apply to us.' Three problems:
▸ No exemption exists — SEBI makes no distinction by LP type, AUM, or investor sophistication
▸ Your LP base includes individuals — family offices, HNIs, NRIs with age-related impairments. One SCORES complaint is enough.
▸ Your website is public — your PPM download page, strategy page, and grievance mechanism are accessible to anyone. Anyone can file.
05 | The Deadline Confusion — All Four Misreadings
We are hearing four very different beliefs about what March 31 requires. Most are wrong.
1 | "March 31 is the last date to be fully compliant — audit done, fixes done, everything." This comes from reading the December 8 circular as a full reset. It is not. March 31 is one specific submission. The audit is April 30. The fixes are July 31. |
2 | "March 31 is the deadline to appoint an IAAP-certified auditor." The original December 14 auditor appointment deadline was not moved to March 31. It was removed entirely by the December 8 circular. There is no mandatory auditor appointment filing date anymore. |
3 | "Our platforms must be WCAG AA compliant by March 31." No. Annexure B is a self-declaration of where you currently stand. For virtually every RE, the honest answer is No. That is the expected answer. Filing honestly with No and a credible timeline is compliance. Not filing is the failure. |
4 | "This doesn't apply to us — we're small / HNI clients / no investor login." The circular contains no size exemption, no investor-type carve-out, no threshold. If you hold a SEBI registration, you are in scope. Full stop. |
🔑 WHAT THE DECEMBER 8 CIRCULAR ACTUALLY SAYS — VERBATIM "Instead of meeting the compliance requirement for appointment of accessibility auditor by December 14, 2025, REs shall submit a status of their readiness and compliance to the accessibility requirements for each of their digital platforms, latest by March 31, 2026." Three words carry everything: "Instead of." SEBI did not add Annexure B on top of the auditor appointment. It replaced that requirement. March 31 = Annexure B. Nothing else. |
Deadline | What IS Required | What Is NOT Required |
Mar 31, 2026 | Annexure B — readiness status per platform. One per registration. | Audit report. Auditor proof. Fixed platforms. Table C2. |
Apr 30, 2026 | Table C3 — initial audit report. IAAP auditor. PwD usability testing mandatory. | Fully remediated platforms. |
Jul 31, 2026 | Table C4 — final report with remediation evidence. |
|
Dec 14, 2025 | REMOVED — Auditor appointment removed by December 8 circular. | No longer a standalone filing requirement. |
06 | The Per-URL Pricing Myth
Some vendors are charging per URL or per page — and telling clients to remove pages to reduce cost. Both are wrong.
✗ What per-URL pricing gives you
A scan of individual URLs. Automated tool output formatted as a report. What it misses: keyboard navigation testing, screen reader testing, focus management, ARIA errors, PDF accessibility, video captions, onboarding flow testing — the 60–70% that automated tools don't find.
This will not satisfy SEBI's requirement for an IAAP-certified audit with PwD usability testing. It is a surface scan with a price tag.
✓ What a real SEBI-compliant audit looks like
Scoped by unique page templates and user journeys — not URL count. A website with 200 blog posts and 15 unique templates is scoped as 15 templates.
Includes: automated scan, manual screen reader testing, keyboard-only navigation, PwD usability testing, PDF review, and developer-actionable remediation guidance.
Produces Table C3 and Table C4 reports ready for SEBI submission. Signed by an IAAP-certified professional.
⚠️ ON REMOVING PAGES TO REDUCE AUDIT COST If a vendor told you to remove pages to reduce scope — that vendor does not understand WCAG-EM or SEBI's requirements. Audit scope is by unique templates, not page count. Removing blog posts does not reduce scope. It does remove investor-accessible content — which may itself be a compliance issue. |
What to Do With All of This
This issue has been dense. Here is the short version:
WordPress (IA/RA): Update Investor Charter (10 min), list all platforms and PDFs for Annexure B. Start document template audit immediately.
Custom PHP (Broker/PMS): List every investor-facing flow for Annexure B. Request the back-office vendor conformance certificate immediately.
React SPA (New broker/portal): Scope audit by component type. Start auditor procurement now — React audits are longer. If still building, add accessibility to your design system this week.
Wix/Webflow (Small IA/RA): Content audit: headings, alt text, link labels, captions. Fix disclosures. Update Investor Charter. Most remediation is an afternoon's work.
🆓 FREE READINESS ASSESSMENT We run an automated scan of your website and key platforms, give you a structured readiness report, and format it into Annexure B — ready to submit to your reporting authority. No cost. No obligation. No commitment beyond the assessment. → Email [email protected] — subject: Free Readiness Assessment |
📋 REQUEST A QUOTE — FULL AUDIT ENGAGEMENT IAAP-certified audit scoped by your platform type and entity category. Covers website, documents, onboarding, and mobile. Table C3 and C4 formatted. Limited slots before April 30. Tell us: registration type (IA / RA / Broker / PMS / AIF / other), number of platforms, and report volume per year. → Email [email protected] — subject: Audit Quote Request |
COMING IN ISSUE #4
Myth: "We installed an accessibility widget. We are now compliant." We test an overlay widget on a live financial services website with NVDA and show you exactly what a screen reader user experiences. The result will surprise you.
EnableUser — Digital Accessibility for India's Financial Services
[email protected] | +91 9990397978 | calendar.app.google/H3offAViUNeAAHe2A
Please forward this issue to your compliance head, technology team, and legal advisor.
SEBI Circulars: 2025/111 (Jul 31) · 2025/121 (Aug 29) · 2025/131 (Sep 25) · I/187/2025 (Dec 8)