IAAP Auditor for SEBI Accessibility: RA and IA Guide
SEBI's accessibility circulars end in one practical step: an IAAP-certified accessibility professional audits your website and any other digital platform your clients use. Here is what SEBI asks for, the dates, what you send BSE, and what to ask before you appoint an auditor.
Not legal advice. Aktai is software, not a Research Analyst or Investment Adviser. You remain the registered entity and are responsible for your compliance, including the accessibility audit and your reports to BSE. Check each point against the SEBI circular before you act.
What SEBI asks for
Circular SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111 of 31 July 2025 makes the Rights of Persons with Disabilities Act 2016 binding on every SEBI regulated entity's digital platforms. Annexure I, section 5.1 says the audit of your websites, apps and portals is done through the International Association of Accessibility Professionals (IAAP), follows WCAG, GIGW and the RPwD Act, and includes usability testing by persons with disabilities.
Section 5.4 makes it annual. The audit is not the only duty. The same annexure asks you to name a nodal officer for accessibility, run an accessibility grievance channel with escalation, and publish accessible documents. Those are in our accessibility statement template.
The dates
| Date | What | Circular |
|---|---|---|
| 31 January 2027 | IAAP auditor appointed, accessibility audit done, findings fixed | HO/53/12/13(2)2026-ITD5-M2IPC/I/24856/2026, 30 October 2026 |
| 30 April 2027, then yearly | Annual accessibility audit of all digital platforms, reported within 30 days of the financial year end | SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/131, 25 September 2025, Table A |
The deadline to fix the findings has moved three times. The July 2025 circular gave six months from its issue. The circular of 29 August 2025 moved it to 31 July 2026, a circular of 31 July 2026 to 31 October 2026, and the circular of 30 October 2026 to 31 January 2027, together with the auditor and the audit. Plan for the date, not for another extension.
Who you report to
Research Analysts and Investment Advisers report to BSE Ltd. Circular SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/121 of 29 August 2025 moved both from their earlier authorities to BSE. Stock brokers report to the exchanges. Most other entities report to SEBI directly.
What the submissions contain
Circular SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/131 sets four formats. Have the facts for each ready before your auditor starts.
| Format | What it asks for |
|---|---|
| C1, your digital platforms | Each platform's name, URL, purpose and current accessibility status |
| C2, the auditor | Name, IAAP ID or certificate number, date of appointment, scope of the audit, whether the auditor was told about the SEBI circular, contact details |
| C3, initial audit report | Auditor, date the audit finished, platforms covered with the terms of reference, key findings as one consolidated PDF, the plan and timeline for fixes |
| C4, final audit report | Date of the final audit, findings, fixes made, status (fully complied, partially complied or pending), and evidence such as screenshots, URLs and reports |
What to ask an auditor before you appoint one
- Their IAAP ID or certificate number. Format C2 asks for it, so get it in writing and check it with IAAP before you sign.
- Scope. Every platform your clients use: your website, client portal, app, and the PDFs you publish, such as the investor charter. Section 5.1 names websites, mobile apps and portals.
- Usability testing by persons with disabilities. Section 5.1 requires it. An automated scan alone is not the audit SEBI describes.
- Standards. WCAG 2.1 or later, GIGW and IS 17802 (section B of Annexure I). The December 2025 clarification sets WCAG AA as the minimum level.
- Report shape. A consolidated PDF of findings and a fix plan for C3, then a re-test and a final report with status and evidence for C4.
- Timeline. Audit, your fixes, then the re-test, all before 31 January 2027. Ask how long their re-test takes.
- The SEBI circular. Send it to them. C2 asks you to confirm you did.
Cut the findings before the auditor arrives
An audit lists what is wrong. The fixes are still yours, against a fixed date. Most RA and IA websites fail on the same things: images without alt text, low-contrast text, menus a keyboard cannot reach, untagged PDFs and forms without labels. Our GIGW and IS 17802 checklist lists them page by page.
If you would rather hand it over, our accessibility check and fixes tests every page of your existing website and fixes up to 8 pages for โน4,999 once, excl. GST, with a report you can give your IAAP-certified auditor. The audit itself stays with the auditor you appoint.
If your clients use a vendor's portal, list it in C1 too. Section 6.1 of Annexure I expects software vendors to audit their own product against WCAG 2.1, and keeps the responsibility with you. Ask each vendor for its accessibility report.
FAQ
Does a one-person Research Analyst or Investment Adviser need an IAAP auditor?
Yes. SEBI circular SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111 applies to all regulated entities from 31 July 2025, and Research Analysts and Investment Advisers report their accessibility compliance to BSE Ltd. The circular does not exempt small practices.
What is the deadline for the IAAP audit?
SEBI circular HO/53/12/13(2)2026-ITD5-M2IPC/I/24856/2026 of 30 October 2026 gives regulated entities until 31 January 2027 to appoint the IAAP auditor, finish the accessibility audit and fix what it finds. After that, the audit is annual, reported within 30 days of each financial year end from 30 April 2027.
Can my web developer do the audit?
Only if they are an IAAP-certified accessibility professional, and the audit includes usability testing by persons with disabilities (Annexure I, section 5.1 of the July 2025 circular). A developer can fix the site before the audit, which usually means fewer findings.
What happens if an investor reports an accessibility problem?
SEBI circular HO/13/19/13(2)2025-ITD-1_VIAP/I/187/2025 of 8 December 2025 says investors can file accessibility complaints on SCORES under an "Accessibility" category, and the firm has to fix the issue to close the complaint.