Regulatory Guidance
SEBI Accessibility Audit Checklist for AIFs
A practical accessibility audit checklist for Alternative Investment Funds, covering private investor portals, fund documents, SEBI submissions, and remediation evidence.
What should a SEBI accessibility audit for an AIF cover?
A SEBI accessibility audit for an Alternative Investment Fund (AIF) should establish which investor-facing platforms and content belong in scope, test representative tasks and documents, record barriers against the chosen standards, and verify remediation. The resulting evidence should support the fund's reporting to the Securities and Exchange Board of India (SEBI).
For an AIF, the most important interactions may happen after sign-in: retrieving a fund document, completing an onboarding step, reading a notice, or asking for assistance. Start with those services and the people using them. The examples below are audit-planning recommendations; include a feature only when the fund actually offers it.
Which reporting route applies to AIFs?
SEBI's September 2025 guidelines and December 2025 clarification list AIFs among entities submitting directly to SEBI, identifying AFD as the concerned department. The direct reporting channel named in those documents is digital_acc@sebi.gov.in. Check for updated instructions before submission.
A manager's shared website can support more than one fund or registered entity. Identify the entity, registration number, relevant scheme areas, and platform owner in the engagement record. A single supplier assessment does not automatically establish coverage for every fund's configuration or content.
Build a fund-to-platform scope map
Create an inventory connecting each investor task to its platform, document, responsible team, and external provider. Include authenticated services explicitly. A sitemap can help identify public pages, but it may omit private portals, uploaded documents, and application states.
Arrange approved test accounts and representative documents with the relevant permissions. Accessibility testing can take place within existing access controls. Nothing in this checklist asks the fund to publish confidential documents or remove authentication.
- Record the fund or entity name, registration details, scheme areas, URLs, and application versions.
- Identify public pages, investor accounts, onboarding services, document libraries, and support routes actually provided.
- Map investor roles and permission differences to the tasks they can perform.
- List excluded or unavailable areas, the reason, and who will arrange any follow-up assessment.
Test the journeys behind the login
Follow a task from its entry point to its outcome. For example, an authorized investor might sign in, select a scheme, filter a document list, open a capital-call notice, and contact support about it. A barrier anywhere in that sequence can prevent completion even if individual pages appear usable.
As practical test scenarios, examine keyboard operation, focus movement, screen-reader output, zoom, validation, and session recovery. Use controlled test data and agreed environments for submissions or account changes. Document browser, assistive technology, role, and build details so another evaluator can reproduce the result.
- Navigate authentication and account-recovery steps without losing context.
- Select the correct fund, scheme, reporting period, and document using a keyboard.
- Understand form labels, required fields, upload feedback, and error recovery.
- Read transaction or submission status and reach an accessible assistance route.
Which fund documents should be sampled?
Prioritize documents that affect an investor's next action or understanding. Where provided through the fund's digital services, examples may include a private placement memorandum (PPM), subscription forms, capital-call notices, investor reports, and distribution statements. Record the edition or reporting period of each tested file.
Review semantic structure, reading sequence, headings, tables, links, and alternatives for informative charts. W3C's PDF3 technique explains how incorrect reading order can make a multi-column document confusing for assistive-technology users. A successful download establishes access to a file; its contents still need evaluation.
Keep the document template or generator in the remediation plan. Repairing one PDF without changing the publishing workflow can allow the same barrier to return in the next reporting cycle.
Which standards and testing methods should be recorded?
The July 2025 SEBI circular names Web Content Accessibility Guidelines (WCAG) 2.1 or a later version, current Guidelines for Indian Government Websites (GIGW), IS 17802, and the Rights of Persons with Disabilities (RPwD) Act and rules. Its audit direction includes usability testing by persons with disabilities. The December clarification calls for periodic audits through certified accessibility professionals.
Specify the versions, applicable requirements, evaluation methods, and any sampling in the audit plan. Combine automated discovery with manual evaluation of the selected tasks. Keep severity, test coverage, and conformance conclusions separate: a low-severity finding can still represent failure of an applicable requirement.
What evidence makes an AIF audit useful?
A useful finding lets the fund, platform provider, and auditor discuss the same observable failure. Assign an issue identifier and record the affected fund area, URL or document version, user role, reproduction steps, expected behavior, observed result, user impact, and relevant requirement.
Screenshots can show location, while a short recording or test narrative may be needed to explain a focus or announcement failure. Redact investor identifiers and confidential financial information from shared evidence. Keep enough context for remediation without distributing live account data.
- Identify the tested release and content version.
- Assign a remediation owner and target date.
- Link the implemented change to the original finding.
- Record the retest method, date, outcome, and any remaining limitation.
How do Tables C3 and C4 fit into the submission?
Under SEBI's September guidelines, Table C3 contains initial-audit submission details; Table C4 records final observations, remediation, status, and evidence. Each is a submission table supported by a separately attached consolidated audit report and scope. Neither table is the audit report itself.
Use a document register to connect the submitted table, report filename, version, and supporting evidence. Reconcile platform names across the inventory and report. The guidelines use a department-based filename convention; AIFs are listed under AFD. Verify the exact convention in the official source before filing.
What timing changes should the fund know about?
The December 8, 2025 clarification replaced the earlier auditor-appointment milestone with platform-wise readiness and compliance status due by March 31, 2026. Its Annexure B includes an AA-level WCAG status question. A readiness declaration does not replace the test evidence used to support it.
SEBI's July 31, 2026 extension moved the audit and remediation timeline to October 31, 2026. This date is also confirmed in NSE circular COMP/75511, which carries the SEBI circular as an annexure. This article was prepared on October 27, 2026; check subsequent SEBI instructions when planning a submission.
How should remediation and retesting work?
Prioritize barriers that stop an investor from completing an essential task, then address recurring components and document templates. Allocate work across the fund team and providers, with a named owner for the complete journey. SEBI's original procurement direction retains responsibility for platform accessibility with the regulated entity.
Retest the original failure and neighboring states affected by the fix. For a repaired document template, inspect newly generated output. For a shared portal component, verify the relevant fund configurations. Keep unresolved findings visible in the final status instead of treating a planned release as a verified fix.
What should be ready before the final package is approved?
A fund's review should connect the declared scope to the actual testing and final evidence. The checklist below is a practical handover aid, to be used alongside the current SEBI formats.
- The correct registered entity, reporting route, and platform owners are identified.
- Authenticated journeys and important investor documents are represented in the test scope.
- The report records standards, methods, dates, environment, exclusions, and findings.
- Each remediation claim has a corresponding retest result or a clearly recorded open status.
- C3/C4 tables reference their respective attached reports, with consistent platform names and versions.
- The responsible reviewer has checked the declared status against the supporting evidence.
Official references and audit preparation
SEBI digital accessibility directions, July 31, 2025: https://www.sebi.gov.in/sebi_data/attachdocs/aug-2025/1754651443956.pdf
SEBI compliance formats and AIF reporting category, September 25, 2025: https://www.sebi.gov.in/sebi_data/attachdocs/sep-2025/1758794128066.pdf
SEBI clarification and readiness-status format, December 8, 2025: https://www.sebi.gov.in/sebi_data/attachdocs/dec-2025/1765194149704.pdf
SEBI timeline extension, July 31, 2026: https://www.sebi.gov.in/legal/circulars/jul-2026/extension-of-timelines-with-repect-to-compliance-of-digital-accessibility-circulars-_103277.html
NSE circular carrying the SEBI extension: https://nsearchives.nseindia.com/content/circulars/COMP75511.pdf
W3C WCAG 2.2 conformance requirements: https://www.w3.org/TR/WCAG22/#conformance-reqs
W3C PDF reading-order technique: https://www.w3.org/WAI/WCAG22/Techniques/pdf/PDF3
To scope an AIF accessibility audit, prepare your entity details, platform inventory, authorized test access, and representative documents. IAAP Audit can use that information to define coverage, document findings, and plan remediation verification.