SEBI Reports
SEBI Table C3: How to Submit the Initial Accessibility Audit Report
A practical guide explaining SEBI Table C3 as a submission table for initial accessibility audit details, with the consolidated audit report attached.
What SEBI Table C3 actually is
SEBI Table C3 should be understood as a submission table for the initial accessibility audit stage. It is not the full audit report by itself. The table captures key details about the audit and points to the consolidated audit report that must be attached.
This distinction matters because teams should not prepare only a small table and assume the audit evidence is complete. The table is the structured submission layer. The attached report is where scope, findings, observations, evidence, standards mapping, and remediation guidance should be documented.
What Table C3 asks teams to fill
SEBI's September 25, 2025 compliance guidelines describe Table C3 as the format for submission of the initial accessibility audit report for digital platforms. Teams should still verify the latest circulars and reporting authority instructions before submitting externally.
The table should make the submission details easy to review and should clearly connect to the attached consolidated report.
- Name of the IAAP Certified Accessibility Professional or firm.
- Date of completion of the accessibility audit.
- Digital platforms covered, such as websites, mobile apps, portals, PDFs, or other investor-facing platforms.
- Terms of reference and scope of audit as an attachment.
- Key findings and observations through a consolidated PDF copy of the report.
- Action plan and timelines for remediation.
What the attached audit report should contain
The attached audit report should provide the substance behind the Table C3 submission. It should be detailed enough for compliance teams to understand risk and for delivery teams to plan remediation.
A weak attachment will usually create rework. A strong attachment explains what was tested, what failed, why it matters, and what should happen next.
- Audit scope, terms of reference, and exclusions.
- Platform inventory covered by the audit.
- Testing methodology, including automated and manual review context.
- Key findings and observations with user impact.
- Evidence such as screenshots, URLs, steps, document pages, or assistive technology notes.
- WCAG or other applicable standards mapping.
- Remediation direction, priority, and timelines.
Platform scope should match the inventory
Table C3 asks for digital platforms covered. The attached audit report should make this scope specific. If an entity has multiple investor-facing platforms, the coverage should not be hidden behind a generic line item.
Scope should connect to the earlier platform inventory and should identify what was included, what was excluded, and what constraints affected testing.
- Public websites and important templates.
- Investor portals, dashboards, forms, and authenticated journeys.
- Mobile apps where applicable.
- PDFs, disclosures, statements, notices, and other documents.
- Third-party tools or vendor-controlled journeys where relevant.
- Known exclusions, inaccessible test accounts, pending releases, or other constraints.
Findings should be suitable for remediation
The key findings and observations referenced in Table C3 should be backed by report-level detail. The report should not only say that issues exist. It should help the team understand the barrier, reproduce it, prioritize it, and fix it.
For accessibility audits, findings usually need user impact, evidence, severity, and standards mapping. This allows remediation teams to convert the report into delivery work.
- Affected page, screen, component, journey, or document.
- Observed behavior and expected accessible behavior.
- Relevant WCAG success criterion or applicable standard reference.
- User impact and severity.
- Screenshot, URL, selector, test step, or document evidence where useful.
- Issue owner or responsible function where known.
- Recommended remediation direction.
- Target timeline or remediation phase.
Table C3 should prepare the C4 stage
Table C3 belongs to the initial audit stage. It should create a clear baseline for the remediation and final-status stage that follows later.
If the attached audit report provides traceable findings, practical timelines, and expected remediation outcomes, the later C4 process becomes easier because teams can show what changed and what evidence supports closure.
Common Table C3 preparation mistakes
The biggest mistake is calling Table C3 the audit report. It is more accurate to treat it as the submission table that must be supported by the attached initial accessibility audit report.
Teams should prepare both parts carefully: the table fields and the attached report evidence.
- Preparing only the table without a useful consolidated audit report.
- No clear connection between platform inventory and audit scope.
- No terms of reference or scope attachment.
- Only automated scanner output without manual testing context.
- Findings without severity, user impact, or standard mapping.
- No practical remediation plan or timelines.
- Using wording that implies complete compliance when the audit scope does not support that claim.