Download SEBI's Accessibility Mandate Whitepaper for Indian Financial Institutions

The Regulatory Framework: RPwD Act 2016, RBI, and SEBI Mandates

Digital accessibility in India’s financial sector is not a single rule but a layered framework of statutory law, sector regulators, and technical standards. For BFSI (Banking, Financial Services, and Insurance) organizations, understanding how these mandates connect is the first step toward defensible compliance.

Rights of Persons with Disabilities (RPwD) Act, 2016

The Rights of Persons with Disabilities (RPwD) Act, 2016 is the legal foundation for digital accessibility in India. Section 40 empowers the government to prescribe accessibility standards for information and communication technology (ICT), while Section 46 sets timelines for service providers to make their offerings accessible. A 2025 Supreme Court judgment reinforced these provisions, directing regulators to ensure that essential digital services — including Know Your Customer (KYC) journeys — are usable by persons with disabilities.

RBI and DFS: Accessible Digital Banking

The Reserve Bank of India (RBI) extends these obligations to banking. RBI guidelines require banks to make their digital channels — net banking, mobile apps, ATMs, and payment interfaces — accessible to customers with visual, auditory, motor, and cognitive disabilities. The Department of Financial Services (DFS) has likewise issued accessibility guidelines directing banks and financial institutions to align their platforms with recognized accessibility standards.

SEBI’s July 31, 2025 Circular

Building on this foundation, SEBI’s circular dated July 31, 2025 mandates that all regulated entities — including stockbrokers, mutual funds, asset management companies, depositories, and other intermediaries — implement digital accessibility in line with the Supreme Court’s directives. Regulated entities are expected to conduct accessibility audits, remediate their web and mobile platforms, and demonstrate conformance with WCAG 2.1 Level AA, IS 17802, and GIGW within the stipulated timeline.

Technical Compliance Standards: WCAG 2.1 AA, IS 17802, and GIGW 3.0

Compliance is measured against three specific technical standards. Together they define what an accessible banking portal, trading app, or insurance self-service journey must actually deliver.

WCAG 2.1 Level AA

Web Content Accessibility Guidelines (WCAG) 2.1 Level AA is the international benchmark published by the W3C. It is organized around four principles — content must be Perceivable, Operable, Understandable, and Robust. For transactional BFSI journeys, Level AA criteria cover requirements such as minimum color contrast (4.5:1 for normal text), full keyboard operability, visible focus indicators, descriptive labels for form fields, clear error identification and suggestions, and text resizing up to 200% without loss of function.

IS 17802

IS 17802 is the Indian Standard for accessibility of ICT products and services, published by the Bureau of Indian Standards. Released in two parts, it adapts WCAG-aligned requirements to the Indian context and covers both web content and non-web software such as native mobile applications. Indian regulators increasingly reference IS 17802 as the domestic yardstick for accessible digital services.

GIGW 3.0

The Guidelines for Indian Government Websites (GIGW) 3.0 define accessibility, usability, and quality requirements for public-facing digital services. Version 3.0 is harmonized with WCAG 2.1 and IS 17802, and its checklists are widely adopted as a practical compliance reference for regulated financial platforms.

Step-by-Step Accessibility Audit and Implementation Roadmap for BFSI

Meeting the mandate within a six-month window requires a structured, repeatable program rather than a one-time fix. The following phased roadmap reflects how leading BFSI teams approach an accessibility audit and remediation.

Phase 1: Automated Testing

Begin with automated scanning to catch the large share of issues that machines can reliably detect — missing alternative text, insufficient contrast, empty links and buttons, and invalid ARIA. Engines such as Axe-core, which powers many accessibility DevTools, can be embedded directly into Selenium, Cypress, and Playwright pipelines so every build is checked. Automated testing typically surfaces roughly 30–40% of WCAG issues and is the fastest way to establish a baseline.

Phase 2: Manual Testing With Assistive Technology

Automation alone cannot confirm a usable experience. Manual testing with real assistive technologies is essential: NVDA and JAWS for desktop screen readers, VoiceOver for iOS and macOS, and TalkBack for Android. Testers navigate critical journeys — account opening, fund transfers, KYC, and trade execution — using only a keyboard and screen reader to validate reading order, focus management, meaningful labels, and error handling.

Phase 3: Independent Third-Party Audit

An independent audit provides an objective conformance assessment and, where required, an accessibility conformance report. Specialist Indian firms such as BarrierBreak, along with resources like DigitalA11Y, are commonly engaged to benchmark platforms against WCAG 2.1 AA, IS 17802, and GIGW and to guide remediation.

Phase 4: Continuous Regression Testing

Accessibility is not a one-time certification. Because AI-assisted development ships UI changes faster than ever, teams must guard against regressions by scheduling recurring automated scans and adding accessibility checks to CI/CD. Self-healing tests adapt to UI changes to reduce maintenance, while continuous monitoring keeps new features compliant long after the initial audit.