Stop Panicking. Read This Instead.
The real SEBI accessibility deadlines — and the three myths sending companies into chaos.
Please forward to the concerned team at your firm - it might help them & subscribe if you want to tune into these.
Before we address other line items, the most important thing & panic that we are seeing that there is a total confusion on what is due on 31st March.
90% of people are wrongly interpreting:
Many believe that it is the last date to appoint an auditor or appoint an auditor & give an initial observation.
Some think that they need to submit the compliance confirmation and report they have done the audit & fixes.
However these conclusions are incorrect - because most people have only read the latest update on 8th dec and they are not aware of all the circulars that there are.
Or they are hearing this as a misstatement from other.
So what’s actually to be done ?
Most of that panic is based on a misreading of the circulars. And some of it is being actively encouraged by vendors who benefit from the chaos.
In this issue, we are going to slow down and give you the clarity nobody else is providing.
If you have only read the December 8th circular, you have an incomplete picture. There are four circulars. They need to be read together. Most people have not done this — and that is the root of all the confusion.
That confusion is not a reflection of the people involved. It is a reflection of how the four SEBI circulars on digital accessibility have been read, misread, forwarded, condensed, and summarised by the time they reach the person who actually has to act on them.
"March 31 hai. Kuch karna padega. But kya exactly karna hai? |
Per 8th Dec circular: 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."
The single most important thing: the auditor appointment deadline no longer exists. SEBI removed it. Entirely. It is not a deadline that was extended — it was removed. If a vendor is telling you otherwise, they are either misinformed or not being straight with you.
The table that you need to submit on 31st March is the Annexure B and not the Table C2, advising who the auditor you have appointed is. - The auditor details will go on April 30th in the audit report.
Annexure B
Format of submitting a status of readiness and compliance to the accessibility requirements for digital platforms – Applicable to all REs.
Subject: [RE Registration No.]-[RE name]-[RE category] -Submission of status of readiness and compliance to the accessibility requirements for digital platforms
Body:
Table 1: Digital platform-wise accessibility
Sl. No. | URL of digital platform | Is minimum level of accessibility at AA level as per latest WCAG guidelines (Yes / No) | Remarks on the status of readiness and compliance with the accessibility requirements |
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For the Regulated Entities, they can appoint an auditor at their free will -
The only hard external deadline you have is 30th April 2026 — the audit report submission. That is it. Everything else is internal preparedness.
Here is why this matters practically. Readiness is about your internal preparedness — understanding your platforms, scoping your audit, and identifying your vendor. It is not about having a completed audit report in hand.
So what should you actually do before 31st March?
• Understand your digital scope — what platforms, portals, and documents you have
• Evaluate vendors properly — understand their methodology, their pricing model, their audit approach
• Factor in your procurement cycle — management approvals, legal review, PO process. How long does this actually take in your organisation?
• Choose a partner you trust.
The question is not: when is the deadline to appoint an auditor? The question is: how long does my procurement cycle take, and how much time do I need to leave for the audit itself, so that I have a report by 30th April?
The whole point being, as we started seeing a lot of chaos, we wanted to help you understand the actual deadlines, stop you from panicking. And if somebody tells you that 31st March is the deadline - no, it’s not.
I would also encourage readers to read all the official 4 circulars hosted on SEBI’s website and build a roadmap for their organisation.
July 31, 2025 SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111 The "Original" Circular: Established the primary framework for mandatory compliance by all REs.
Aug 29, 2025 SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/121 Timeline Extensions: Provided updated deadlines for reporting and auditor appointments.
Sept 25, 2025 SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/131 Compliance Guidelines: Detailed operational instructions and initial reporting formats.
Dec 08, 2025 HO/13/19/13(2)2025-ITD-1_VIAP/I/187/2025 Clarification Circular: The latest update recognizes accessibility as an "Investor Right" and introduces the Annexure B status report.