Tomorrow. Four Sessions. Every Readiness Question Answered.

ENABLEUSER  ·  READINESS WEEK  ·  MARCH 2026

Tomorrow. Four Sessions.

Every Question Answered.

All your readiness confusion ends in one day.

THE SINGLE MOST IMPORTANT THING TO UNDERSTAND THIS WEEK

March 31 is not an audit appointment date. It is not an audit report date. It is not a compliance deadline.  March 31 is the date to file Annexure B — a self-declaration listing your digital platforms and their current accessibility status. One table. One email. Filed to the right authority.  The original December 14 auditor appointment deadline was removed by the December 8 circular. Removed — not moved. If someone told you March 31 is the auditor appointment deadline, they read the circular wrong.  Readiness means: do you understand what accessibility is, which platforms are in scope, and what to file? That understanding is what we give you tomorrow.

10:00 AM  ·  Tuesday March 25

PMS, AIFs & Mutual Funds

PMS firms · AIF Cat I/II/III · AMCs · Fund managers

Fund managers and AMC compliance teams — this is the session where we dismantle the single most common belief in your space: 'Our investors are institutions. Accessibility does not apply to us.'

If these are your questions — this is your session:

→  Our LPs are pension funds, family offices, sovereign wealth. No disabled retail investor puts in ₹1 crore. Why does this apply?

→  We are a corporate entity — a fund management company. Not an NGO. Not a retail-facing business. Disabled persons do not come to us.

→  Our AIF trust is the SEBI-registered entity. The operating company is a separate legal entity. Which one files?

→  We have an LP portal managed by a third-party fund admin . Is that in our scope?

→  Our PPMs are private documents shared with committed investors. Not published publicly. Are they in scope?

→  We publish factsheets on our website. But they are PDFs. Does every factsheet need to be accessible?

→  An AMC publishes 480+ scheme documents per year — SID, SAI, KIM, factsheets. Do ALL of them need fixing? That is impossible.

→  We have three AIF schemes. Do we file three Annexure Bs or one?

→  We file to SEBI IMD or AFD via email. What is the exact email subject line format? Which department for which entity?

→  Can we request a phased approach — website first, then portal, then documents?

→  We don't even have a proper website. Just a one-page landing page. What do we list?

→  What does a good Annexure B look like for a PMS firm.

Register Now. (https://live.zoho.in/jvmb-mux-odp)

12:00 PM  ·  Tuesday March 25

Investment Advisers & Research Analysts

IAs (INA series) · RAs (INH series) · Dual-registered IA+RA entities

IAs and RAs —

If these are your questions — this is your session:

→  We are a small IA with 15 clients. One person firm. We cannot be expected to do this.

→  My blog is educational content — anyone can write about personal finance without a license. Why is my blog in scope?

→  What about my books, case studies, whitepapers? Those are marketing materials, not advice.

→  My SIP calculator is just an HTML widget. It does not give investment advice. In scope?

→  We moved the blog to a subdomain — blog.example.com. Now only the main domain needs audit, right?

→  The one person who ran our website moved our SEBI registration number to a separate page. Does that help?

→  I publish 3 research reports a week. That is 150+ PDFs a year. Do ALL of them need to be accessible?

→  Our financial plans are private client documents — sent by email, not published. Are those in scope?

→  Our website is 5 pages on WordPress, built by a local agency. That is our entire scope. Right?

→  Our risk profiling questionnaire is a Google Form. Is Google's form our compliance problem?

→  We have educational videos on YouTube. Do those need captions and ISL?

→  IAs submit to BSE IAASB. RAs submit to BSE RAASB. But we hold both registrations. Do we file twice? To two different portals?

→  What is the educational content argument — and why does everyone say it fails?

→  Can we create a separate accessible version of our website for disabled users instead of fixing the main one?

→  Can we just add a text-only version and call it accessible?

→  Our website is completely static. No login, no transactions. Just information. What could be wrong with it?

→  We installed an accessibility widget last week. Our vendor said we are now compliant. Are we?

→  Do we need to add voiceover narration to the website? Like audio reading of every page?

We will cover: Every platform an IA/RA operates — mapped and named. The educational content argument and why it fails at three layers (legal, commercial, and regulatory optics). The subdomain strategy and why it does not work. Template-level PDF fix — fix the Word/InDesign template once, and 150 future reports are born accessible. BSE IAASB and RAASB submission. Dual-registration filing.

Register Now (https://live.zoho.in/lhqb-mtr-pkf)

2:00 PM  ·  Tuesday March 25

All Other Entities + Open Q&A

CRAs · KRAs · RTAs · Custodians · Exchanges · Banks · ESG · Merchant Bankers · Debenture Trustees · MFDs · Anyone

This session is for entity types that do not fit neatly into the other three — and for anyone from the morning sessions who still has questions. The first 30 minutes cover entity-specific issues. The remaining 60 minutes are pure open Q&A.

If these are your questions — this is your session:

→  We are a custodian. We serve institutions, not retail investors. Our clients are fund managers, not individuals. Does this apply?

→  We are a KRA. Our portal is used by every broker and RA in India. Is the entire KRA portal in scope? That is systemic infrastructure.

→  We are an RTA. We serve listed companies AND their shareholders. Individual shareholders access our portal for transfers and dividends. Which side is in scope?

→  We are a bank with SCSB + BTI + DP registrations. Do we file three separate Annexure Bs to three different SEBI departments?

→  We are a stock exchange. We are both a regulated entity AND a reporting authority. What is our own compliance obligation?

→  What about SmartODR? It is a dispute resolution platform. Who is responsible for its accessibility — the exchange or SEBI?

→  We are a credit rating agency. We publish thousands of rating rationale PDFs every year. All in scope?

→  Our CRA website has a rating search portal. Institutional analysts use it. Is that investor-facing?

→  We are an ESG rating provider. We are not directly investor-facing. We rate companies. How does this apply?

→  We are a Mutual Fund Distributor with only an ARN number. No IA, no RA, no broker registration. Are we even covered?

→  We are a debenture trustee. Our digital presence is minimal. What do we list?

→  We are a merchant banker. Our website is for corporate clients, not retail investors.

→  Our website has multiple verticals — some financial, some not. Can we exclude the non-financial sections?

→  Can we request SEBI to apply this in phases — first for websites, then for trading portals, then for documents?

We will cover: Quick walkthrough: CRAs (rating PDFs, search portal — SEBI DDHS). KRAs/RTAs (systemic gatekeeper, investor portal — SEBI MIRSD). Custodians (institutional ≠ exempt — SEBI AFD). Exchanges (dual obligation — SEBI MRD). Banks with multiple registrations (3 filings to 3 authorities). ESG providers. MFDs. Then 60 minutes open Q&A — any entity, any question, any confusion. 

Register Now (https://live.zoho.in/yoqn-xjw-slr)

4:00 PM  ·  Tuesday March 25

Stockbrokers & Depository Participants

Stockbrokers (INZ series) · Depository Participants · Sub-brokers

You operate the most complex digital ecosystem of any SEBI-regulated entity. Your marketing website is the simplest part. Behind it: a trading terminal, mobile apps on two platforms, a client portal powered by a vendor you did not build, a KYC flow run by a third party, contract notes generated by a system you cannot access, and a grievance mechanism that may or may not work with a keyboard. Every single one of these goes into your Annexure B.

If these are your questions — this is your session:

→  Our trading terminal - how do we make this accessible?

→  Our back office is very old., is this also covered.

→  Is the mobile app covered? On both iOS and Android separately? We thought this circular was about websites.

→  Our ReKYC portal is a one-time regulatory process. Not a regular platform. Covered?

→  Contract notes are auto-generated PDFs from the back-office system. We have zero control over the PDF template. We cannot make them accessible.

→  We generate margin statements, holding statements, and ledger reports as PDFs. - how about these ?

→  Can we just do the homepage and the account opening page? Not the trading terminal?

→  Can we make only the critical investor-facing sections accessible and skip internal operations tools?

→  Our website has 200 pages but only 10 are investor-facing. Do we audit all 200?

→  52 pages of the same template — do all 52 get audited separately, or just the template once?

→  Is 100% accessibility required? Or can we do phases — website first, then trading platform, then mobile, then documents?

→  Can we create a separate accessible version of our website for disabled investors instead of fixing the main one?

→  We have an API platform for algo traders — Kite Connect, Vortex. Is API documentation in scope? Developers don't have disabilities... do they?

→  Our helpdesk runs on Freshdesk. That is a third-party SaaS product. Is it our grievance mechanism? Is it in scope?

→  Our blog and educational content — market analysis, stock tips, videos. In scope?

→  We file through the exchange member portal. NSE or BSE? What is the exact submission process?

→  We are also a DP. Do we file a separate Annexure B to the depository?

We will cover: Every platform a broker operates mapped and named (8-15 rows). Complete 10-row Annexure B for a mid-size broker — walked through row by row. What accessibility means & how to prepare your Roadmap.

REGISTER — https://live.zoho.in/mutg-ceo-vkr

What You Can Report — Better Than 'Appointed an Auditor'

We are an auditing firm. We want your contract. But there is something much better you can file right now. Here is what meaningful progress looks like — each is a signal SEBI reads:

Internal discussion completed — board is aware

Self-assessment conducted — gaps identified across all platforms

Full scope mapped — all digital platforms listed

Investor Charter updated — 'Right to Digital Accessibility' added

Grievance mechanism updated — email + web form, not phone-only

Nodal officer designated — documented in board note

Accessibility statement published on website

Vendor conformance certificates requested from all third-party providers

Widget installed — fashion statement, not compliance, but shows intent

Disability status field added to KYC/onboarding

Auditor engagement in progress — IAAP-certified professional being identified

Phased timeline proposed — website first, then terminal, then docs, then mobile

A filing with eight of these tells SEBI infinitely more than 'Appointed an auditor. Waiting for them to start.' The first shows understanding. The second shows delegation without understanding.

 WHAT IS EXPECTED IS NOT COMPLIANCE — IT IS SELF-ASSESSMENT

Filing No across every platform with a credible timeline and evidence of action is the correct filing for 99% of entities right now. Not filing at all is the failure. Filing Yes without proof is worse.

 Why This Matters — Beyond Compliance - You want to get an accessibility audit done.

 We hear one question more than any other: 'Does my normal user need this?'

When you sit in the webinar tomorrow and hear what a screen reader user actually hears on your website — the silence where navigation should be, 'image, image, image' where charts should be, 'edit text, edit text' where form labels should be — you will understand this differently.

Every day this week is a Super Bowl. We are here to make sure you win it.

Take it and conquer.

— Suryanshu Gupta, CPWA

EnableUser — Enterprise Accessibility Infrastructure

[email protected]  |  +91 9990397978

SEBI Circulars: 2025/111 · 2025/121 · 2025/131 · I/187/2025