This Is Readiness Week and we are here to help you make the best out of it.

The Accessibility Compliance Series 

This Is Readiness Week. 

And most of you are preparing for the wrong thing.  

Thank you for reading us. 

Over the past three issues, we have received more responses than we expected. Compliance heads forwarding these to their boards. CTOs sharing with technology teams. Legal advisors asking for circular references. IAs writing back to say this was the first time anyone explained what March 31 actually requires. 

We write professional articles that are deep, clear, and honest. We do not overcomplicate. We do not bloat. We do not use technical jargon where plain language works. The feedback tells us we are getting it right — and we intend to keep it that way. 

The thing that surprises is Most people coming and literally saying us why they have partnered with us is because they felt good after talking to us, we have been told after talking with us - they felt most clear on all the aspects.

Why it stand outs is they are buying a tech product but they have not looked at tech but the people who they are partnering with & we feel good to be those folks.

Several of you asked who is behind these newsletters. Whether we are a law firm, a consulting house, or a media company. Let us introduce ourselves. 

 Who We Are 

EnableUser is a compliance firm for SEBI-regulated entities. 

 We solve digital accessibility compliance — and broader compliance infrastructure including cybersecurity — for India's financial services sector. This is our entire focus. Not a side offering inside an IT firm. Not an add-on from a CA practice. 

 What we do: 

▸ PDF remediation — instant, template-level, at scale. Fix the template once, every future document is born accessible. 

▸ AI-powered accessibility agents - our own tools, built in-house. Deeper coverage, faster reporting. 

▸ Web platform remediation — fixing what the audit finds, not just finding it. 

▸ IAAP-certified manual audits — WCAG 2.1 AA, GIGW, IS 17802, RPwD Act. PwD usability testing included. 

▸ Readiness and gap analysis — automated baseline scan delivered in hours, referenced in your Annexure B. 

▸ Cybersecurity compliance — because accessibility is one layer of the compliance infrastructure we build. 

Let us know if you want our company profile.

 What Readiness Week Actually Means 

This is the hottest topic in every boardroom, every CTO's office, every compliance team's inbox right now. And we are here to give you exact clarity — without the confusion. 

Our phones start ringing at 8 in the morning. The same questions. Over the past few months, across conversations with regulated entities of every type and size, we keep hearing the same confusions, the same panic, the same misconceptions. We are starting to sound like a broken record — and we are fine with that, because the clarity needs to reach everyone. 

So here it is. One more time. For everyone: 

March 31 does not require an auditor appointment. 

The original December 14 deadline for auditor appointment was removed by the December 8 circular. Removed — not moved. There is no mandatory date to report proof of an appointed auditor. If someone told you March 31 is the auditor appointment deadline, they read the circular incorrectly. 

March 31 does not require an audit report. 

The audit deadline is April 30 (Table C3). The remediation deadline is July 31 (Table C4). March 31 requires only Annexure B — a self-declaration of where you currently stand. 

March 31 does not require compliant platforms. 

SEBI knows your platforms are not WCAG AA compliant. That is the expected answer. Filing No with a credible plan is compliance. Not filing at all is the failure. 

So if readiness is not about auditor appointment, not about an audit, and not about compliant platforms — what is it? 

Readiness is about meaningful understanding. Do you actually know what accessibility is? Do you know which of your platforms are in scope? Do you know that your PDFs count? That your vendor's portal is your responsibility? That an automated scan covers 30-40% of what WCAG requires? 

Readiness is the distance between confusion and clarity. This week, we close that distance for you. 

What People Are Still Confused About 

Over the past few months, we have been in the trenches — calls, emails, board presentations, WhatsApp messages. The same confusions keep surfacing. They fall into four categories. 

1. Applicability — Does this even apply to me? 

This is the first question nearly everyone asks. And for a surprising number of entities, the answer they assume is wrong. Here are the confusions we are hearing — by entity type: 

 ▸ Small IAs and RAs (under 50 clients): 'We are too small. This cannot apply to us. We have 20 clients.' 

▸ Educational-only IAs: 'My blog is educational content. It does not require an IA license. My SEBI registration is for advisory — the blog is separate.' 

▸ IAs with books and courses: 'My books and case studies are marketing materials, not investment advice. They should be out of scope.' 

▸ IAs with calculators: 'Our SIP calculator is just an HTML widget. It does not give advice.' 

▸ RAs delivering via WhatsApp/Telegram: 'Our website is just a landing page. Research is delivered on WhatsApp. The website is not our platform.' 

▸ Proprietary trading firms: 'We have no external investors. We trade our own capital. There is no investor to protect.' 

▸ Algo and quant firms: 'Our platform is API-only. There is no website to make accessible. Our users are developers.' 

▸ PMS firms: 'Our clients are HNIs with ₹50 lakh+ portfolios. They have personal relationship managers. They do not use screen readers.' 

▸ AIFs (Category I/II/III): 'Our LPs are institutional investors — pension funds, family offices, sovereign wealth funds. Disabled retail investors do not invest ₹1 crore.' 

▸ AIF operating companies: 'The fund management company is a separate legal entity from the AIF trust. The operating company is not SEBI-registered.' 

▸ ESG rating providers: 'We rate companies. We are not directly investor-facing. Our clients are corporations, not individuals.' 

▸ Credit Rating Agencies: 'Our ratings are used by institutions. Individual investors use rating aggregators, not our portal directly.' 

▸ Custodians and RTAs: 'We serve institutions, not retail investors. Our clients are fund managers, not individuals with disabilities.' 

▸ Mutual Fund Distributors (ARN only): 'AMFI distributors are not directly SEBI-registered intermediaries.' 

▸ Global entities (Macquarie, Morgan Stanley, Goldman): 'This is our Australian/American parent's website. India has no control over it. Does SEBI expect us to make the entire global site accessible?' 

▸ Stockbrokers with separate sub-domains: 'Our trading platform is on trade.broker.com. The marketing site is broker.com. These are different platforms.' 

▸ Banks with multiple registrations: 'We are an SCSB, DP, and broker. Do we file three times? To three different authorities?' 

Every single one of these entities is in scope. The circular says 'all Regulated Entities.' No size exemption, no investor-type carve-out, no AUM threshold. The Supreme Court's Article 21 ruling makes digital access a fundamental right. There is no wealth-based or sophistication-based exception. 

 2. Scope — What exactly is covered? 

This is where the most dangerous under-reporting is happening. People are listing one URL and calling it done. Here are the confusions we are hearing: 

▸ 'Our website is 5 pages. That is our entire scope.' — But what about your PDFs? Your KYC form? Your Investor Charter? Your grievance mechanism? Your vendor's back-office portal? 

▸ 'The back-office system is internal. Investors don't see it.' — Investors log in to see holdings, download contract notes, check ledger balances. That is investor-facing. 

▸ 'Our blog is educational. It does not require a license.' — It is published on the SEBI-registered entity's platform, carrying your registration number. The platform is the unit of compliance, not individual pages. 

▸ 'The mobile app is a separate product.' — The circular explicitly names mobile applications as first-class targets. 

▸ 'Content behind login is private.' — SEBI explicitly includes investor portals and web portals. Authentication does not create an exemption. 

▸ 'Our trading terminal is a vendor product. We cannot modify it.' — SEBI says compliance responsibility remains with the RE, even for vendor platforms. 

▸ 'Third-party PDFs linked on our site are not our problem.' — If you direct investors to inaccessible content from your platform, that is your compliance gap. 

▸ 'Our KYC is handled by a third-party KRA.' — The Supreme Court specifically flagged inaccessible KYC processes as discriminatory. 

▸ 'ReKYC is a one-time regulatory update, not a platform.' — If a disabled investor cannot complete ReKYC, their account gets frozen. That is discrimination. 

▸ 'The support portal (Freshdesk, Zendesk) is a third-party SaaS product.' — If investors use it to file complaints, it is your grievance mechanism. SEBI requires accessible grievance redressal. 

▸ 'Our research reports are just PDFs sent via email.' — PDFs are digital documents explicitly covered by the circular, regardless of delivery method. 

▸ 'Webinars are live events, not a platform.' — Recorded webinars published on your website are multimedia content. Captions, transcripts, and ISL videos are required. 

▸ 'API documentation is for developers, not investors.' — Developers have disabilities too & the end consumer may want to read documentation.

▸ 'We moved our blog to a subdomain. Now only the main domain needs audit.' — Both domains are owned by the same SEBI-registered entity. Creating a subdomain does not create a separate legal entity. 

The circular says 'all digital platforms (e.g., websites, mobile applications, web portals, etc.) and content published on the digital platforms must comply.' The word is all. A stockbroker has 8-15 platforms in scope. An IA has 6-12. An AIF has 5-10. If your Annexure B has fewer than 5 rows, you are almost certainly under-reporting. 

3. What Accessibility Actually Is — And What It Is Not 

This is the deepest confusion. Most people believe accessibility is simpler than it is. 

Most people think accessibility means: 

▸ Installing a widget or overlay plugin 

▸ Adding alt text to images 

▸ Changing colour contrast 

▸ Running an automated scan 

It is not. Those are fragments. Here is what accessibility actually means: 

Accessibility means testing every interactive component on your platform — every button, every form field, every dropdown, every modal, every chart, every table, every navigation menu — and verifying that each one has the correct semantic value, keyboard behaviour, and screen reader announcement. 

It means verifying that a blind person using NVDA or JAWS can navigate your website by headings, understand the page structure, complete every form, read every table, receive every error message, and complete every transaction — without sighted assistance. 

It means verifying that a person who cannot use a mouse can operate every element on your platform using only a keyboard — Tab, Enter, Escape, Arrow keys — and that focus is visible, logical, and never trapped. 

It means verifying that your PDFs are not just visual images of text but are tagged, structured documents with reading order, heading hierarchy, table headers, and alt text for every chart and image. 

Colour contrast and alt text are part of this — but they are two criteria out of approximately 50 WCAG 2.1 AA success criteria. They are the part people understand because they are visible. The other 48 criteria — heading structure, focus management, ARIA roles, form associations, error identification, live region announcements, keyboard operability — are invisible to sighted users. That is why 60-70% of WCAG failures are missed by automated scanners. The scanners only see what sighted users see. 

This is also why accessibility is not charged per page. It is charged per effort. Your website might have 200 pages — but if 180 of them use the same template, the effort is in testing the template, not counting the pages. A 52-page site with one template has a fundamentally different effort profile than a 10-page site with 10 different interactive components. Template-based pricing is the honest way to scope this. Per-page pricing is how vendors who do not understand accessibility overcharge you. 

 4. What to Actually File — And How to File It Well 

We are releasing the deepest guide available on this — entity by entity, registration by registration, reporting authority by reporting authority, with exact format, remark templates, and worked examples. More on this below. 

But here is the summary: Annexure B is one table. One row per digital platform. Four columns: serial number, URL, WCAG AA Yes/No, Remarks. Filed to the correct reporting authority by email or portal. One filing per SEBI registration. 

The Remarks column is where it matters. A good remark has three parts: where you stand now, what you are doing about it, and when you expect to be done. 

And here is the truth from us — an auditing firm whose commercial interest is in you hiring us: the best thing you can file right now is not 'We have appointed an auditor.' It is: 'We have understood the scope, identified our digital platforms, conducted an internal self-assessment, updated our Investor Charter and grievance mechanism, and are now in the process of engaging an IAAP-certified accessibility auditor.' That filing communicates ten times more progress than 'Auditor appointed, work not started.' 

We are an auditing firm. We want your contract. But we are not a firm that wants you to panic, rush, or hate this process. We know this compliance area deeply. If we tell you the auditor appointment is not the priority this week — believe us. We gain nothing from saying that except your trust. 

10 Things You Can Do This Week — Without an Auditor 

None of these cost money. All of them improve your Annexure B. Each one is a progress signal SEBI can see: 

1. Update your Investor Charter to include 'Investors' Right to Digital Accessibility' — 10 minutes. 

2. Update your grievance mechanism — add email and web-form-based options alongside phone. 

3. Appoint a nodal officer for accessibility — internal designation, documented in a board note. 

4. Map your complete digital platform inventory — website, app(s), portals, PDFs, KYC, vendor platforms. 

5. Request accessibility conformance certificates from every third-party vendor you use. 

6. Publish an accessibility statement on your website. 

7. Add a disability status field to your KYC/onboarding process. 

8. Run a free gap analysis on your website — get a baseline you can reference in your Annexure B. 

9. Draft your Annexure B — list every platform, mark No honestly, write credible remarks with timelines. 

10. Request an extension or phased implementation timeline in your Annexure B remarks — specify that you are requesting website compliance first, followed by trading portals, documents, and mobile apps in subsequent phases. SEBI has not indicated whether phased timelines will be accepted, but filing the request is a genuine compliance signal. 

If you do all ten, you have done more than 90% of regulated entities will have done by March 31. And you will have done it without spending a single rupee on an auditor. 

 What You File → What SEBI Thinks 

Your Annexure B is a signal. Here is what different filings communicate: 

What We Are Releasing This Week 

Our team worked through the weekend. Here is everything we are putting out — written guides you can follow at your convenience, and live sessions where we answer anything. 

Written Guides 

Live Webinars — Daily This Week 

Accessibility is very new. Reading guides helps. But having someone walk you through it, answer your specific questions, and show you what a screen reader actually does on your website — that is different. 

We are inviting your Q&As beforehand and releasing the links to connect on the webinar so you can do the right things, right way within the time.

Reply to this email to be added to the invite list. 

Free Tools 

▸ Free gap analysis report — automated scan of your website, delivered in hours 

▸ Sitemap discovery tool — identify every page and template on your domain 

▸ Readiness report template — structured format for your compliance team 

 We loaded thousands of dollars in scanning credits for this week. Use them. 

Send us an email, we will give you the link. 

Everything We Have Published So Far 

The Bottom Line 

Readiness is not an auditor appointment. It is an understanding. 

If you understand what accessibility is, which platforms are in scope, what your Annexure B should contain, and what your timeline is — you are ready.  If you appointed an auditor last month but still don't know that your PDFs are in scope, that your vendor's portal is your responsibility, that your KYC flow must include a disability status field, and that a widget is not compliance — you are not ready.  Understanding is. The guides, the webinars, the tools, the answers. Use them.

The auditor comes after.

How We Can Help You — This Week 

Free — Annexure B Review 

Send us your draft. We check completeness, remark quality, correct authority, and platform coverage. Available until March 31. → [email protected] — subject: Annexure B Review 

Free — Gap Analysis Report 

Automated scan of your key platforms. Baseline accessibility report for your Annexure B remarks. → [email protected] — subject: Gap Report 

EnableUser — Enterprise Accessibility Infrastructure 

[email protected]  |  +91 9990397978  |  enableuser.in 

Forward this to your compliance head, CTO, and legal advisor. They need this before Monday.