Regulatory Guidance
SEBI Accessibility Audit Checklist for Mutual Funds and AMCs
A practical accessibility audit checklist for mutual funds and AMCs, covering investor journeys, documents, SEBI reporting tables, evidence, and remediation.
What should an AMC prepare for a SEBI accessibility audit?
Start with a complete inventory of investor-facing digital platforms and the content published on them. Define the audit boundary, identify the responsible teams, appoint an appropriately qualified auditor, and agree how findings will be evidenced and fixed. Then test real investor journeys and publish a traceable initial report, remediation record, and final audit evidence.
This is an operational checklist, not a legal opinion or a substitute for SEBI's circulars. The relevant source documents are the July 31, 2025 digital accessibility circular, its September 25, 2025 compliance guidelines, the March 20, 2026 Mutual Funds Master Circular, and the July 31, 2026 timeline extension.
Confirm scope and ownership before testing
The SEBI Mutual Funds Master Circular, section 15.21.1, says that AMCs and MFs shall comply with the Board's digital accessibility guidelines. The September 2025 compliance guidelines list MFs and AMCs among the entities reporting directly to SEBI, under the Investment Management Department (IMD).
Map each website, mobile app, authenticated portal, transaction journey, and investor document to an owner. Include vendor-operated journeys where they form part of the investor experience. Record URLs, release versions, access arrangements, and exclusions so that an independent reviewer can understand what was actually audited.
SEBI's original directions also call for a senior accessibility nodal officer, management review, and an accessible grievance channel. These are governance controls; a technical scan cannot replace them.
- Create a platform inventory with purpose, URL or app version, owner, and accessibility status.
- Identify the accessibility nodal officer and escalation path.
- Record the auditor's IAAP certification and the agreed scope of work.
- Document dependencies on registrars, KYC providers, payment services, and publishing teams.
Test the investor tasks that matter
Sample complete tasks rather than isolated screens: finding scheme information, opening or updating an account, completing digital or video KYC, investing, redeeming, downloading statements, and raising a complaint. Test the normal path and error, timeout, validation, and recovery states. These examples are a risk-based audit plan, not an assertion that every AMC exposes identical services.
Use automated checks to identify repeatable signals, then manual keyboard, screen-reader, magnification, and document testing to determine whether a person can finish the task. Include usability testing with persons with disabilities as required in SEBI's original directions.
- Can a keyboard user reach, understand, and activate every essential control?
- Do form labels, instructions, errors, and focus movement make recovery possible?
- Can a screen-reader user distinguish scheme choices, amounts, confirmation details, and transaction status?
- Are alternatives to inaccessible e-KYC or video KYC steps available and documented?
Include documents, media, and third-party components
SEBI's directions expressly include content published on regulated entities' digital platforms. Review sample investor PDFs and other documents for tags, headings, logical reading order, table structure, useful link text, and image alternatives. A visually polished PDF may still be unusable with assistive technology.
Check captions, descriptive information, and other media support where relevant. Separate an AMC-owned defect from a vendor-owned defect in the issue log, but keep a single accountable remediation plan for the investor journey. SEBI's procurement direction places responsibility for the accessibility of a digital platform with the regulated entity.
Use the standards named by SEBI
The July 2025 circular names WCAG 2.1 or a later version, the latest Guidelines for Indian Government Websites (GIGW), IS 17802, and the applicable Rights of Persons with Disabilities Act and Rules as baseline references. Its audit direction also calls for usability testing by persons with disabilities.
State the exact standards and versions used in the engagement, and map each finding to the relevant testable requirement. Do not label a platform compliant merely because an automated score is high; the result must reflect the stated scope, manual evidence, and unresolved barriers.
Understand the current submission timeline
SEBI's September 2025 guidelines originally set separate dates for the initial accessibility audit and remediation. Its July 31, 2026 circular extended the timeline for conducting accessibility audits of digital platforms and remediating findings to October 31, 2026; it said the other provisions remain unchanged. As of this article's publication date, confirm any subsequent SEBI notice before making a filing decision.
Treat that date as a deadline for credible audit and remediation work, not as permission to defer scoping, evidence collection, or governance. Maintain a dated decision record for any item that remains open.
Keep Table C3 and the initial audit report separate
Table C3 is SEBI's submission format for the initial accessibility audit. It captures the auditor, completion date, covered platforms, key findings, and remediation plan. The terms of reference and scope, plus the consolidated initial audit report PDF, are attachments to that submission. Table C3 itself is not an audit report.
The report should show the tested platform and version, methods, assistive technology and browser context where relevant, standard mapping, severity, reproducible steps, evidence, and recommended remediation. Use the filename convention in SEBI's guidelines when preparing the consolidated PDF attachment.
Use Table C4 for final status, with a final report attached
Table C4 is the final submission format. It asks for the auditor and completion date, covered platforms, final observations, remediation measures, compliance status, and supporting evidence. The consolidated final audit report is attached as a separate PDF, along with the scope and other support requested by the format. Do not call the table a retest report.
A defensible close-out trail links each original issue to its fix, retest outcome, residual risk, and evidence. If a blocker remains, describe it honestly rather than converting a planned fix into a completed one.
A practical pre-submission checklist
Before submission, reconcile the platform inventory with the audit scope, confirm that core journeys and high-risk documents were tested, and verify that findings have owners and retest results. Confirm the current reporting channel and attachment instructions against SEBI's latest circulars. The September 2025 guidelines specify direct submission to SEBI for MFs/AMCs and identify IMD as the concerned department.
Finally, have the nodal officer and relevant management review the evidence. A useful filing should let a reader trace a platform from inventory to initial finding, remediation, final status, and attached report without guessing.
- Platform inventory and named owners are complete.
- Audit scope, auditor details, methods, and test dates are recorded.
- High-impact investor journeys and representative documents have manual evidence.
- Initial findings map to standards and actionable remediation owners.
- C3 and C4 tables are complete, with their respective audit reports attached separately.
- Final status is backed by retest evidence and clearly disclosed open issues.
Official references and next step
SEBI original digital accessibility circular (July 31, 2025): https://www.sebi.gov.in/sebi_data/attachdocs/aug-2025/1754651443956.pdf
SEBI compliance guidelines and Tables C1-C4 (September 25, 2025): https://www.sebi.gov.in/sebi_data/attachdocs/sep-2025/1758794128066.pdf
SEBI Mutual Funds Master Circular (March 20, 2026), section 15.21.1: https://www.sebi.gov.in/sebi_data/attachdocs/mar-2026/1774024028162.pdf
SEBI timeline extension (July 31, 2026): https://www.sebi.gov.in/sebi_data/attachdocs/jul-2026/1785493077212.pdf
If your AMC needs an evidence-led audit across investor journeys, documents, and submission-ready reporting, request a scoped accessibility audit from IAAP Audit.