Compliance Guidelines for Digital Accessibility Circular ‘Rights of Persons with Disabilities Act, 2016 and rules made there under mandatory compliance by all Regulated Entities

Multi Commodity Exchange of India Limited (MCX), vide Circular No. MCX/MEM/414/2026 dated July 16, 2026, has announced an important update regarding Compliance Guidelines for Digital Accessibility Circular – ‘Rights of Persons with Disabilities Act, 2016 and Rules made thereunder – Mandatory Compliance by all Regulated Entities’.

Key Details of the Update –

• Applicability: The circular is applicable to all Trading Members (TMs) of the Multi Commodity Exchange of India Limited.

• All digital platforms of Trading Members shall be subject to an Accessibility Audit conducted by an IAAP-certified accessibility professional in accordance with the applicable SEBI Circulars.

• For standard digital platforms/applications (such as front-office CTCL solutions, client back-office access, e-KYC products, mobile/internet trading applications, etc.) used by multiple Trading Members without accessibility-impacting customization, Trading Members may obtain an accessibility audit report/certificate from the respective software vendor.

• The vendor-provided accessibility audit report, together with the closure/non-closure status of audit observations, may be submitted for compliance. Vendors must also provide a covering letter specifying platform details (including version, where applicable), details of the IAAP-certified auditor, and the audit report issued in the vendor's name.

• A validation checkpoint will be incorporated into the Standardised Terms of Reference (TOR) of System Audit (where applicable) to enable the System Auditor to confirm that the vendor-issued IAAP Audit Certificate relates to the standard version of the application and that no relevant customization has been undertaken. For Trading Members not required to submit a System Audit Report, an alternative submission mechanism will be notified separately.

• For customized or unique digital platforms, including websites, mobile/web applications, back-office/KYC applications and other in-house systems, Trading Members must continue to conduct an independent accessibility audit through an IAAP-certified accessibility professional.

• The circular clarifies that vendors are under no regulatory obligation to obtain or provide Accessibility Audit Reports. Such arrangements remain contractual between vendors and Trading Members, and Trading Members may choose to engage their own IAAP-certified accessibility professional.

• Responsibility for complying with the Digital Accessibility Circulars, implementing remediation measures and adhering to prescribed accessibility standards continues to rest solely with the concerned Trading Members.

• Effective Date: The circular is effective from July 16, 2026, with the prescribed submission timeline applicable for compliance.

• Key Changes: The circular clarifies the implementation framework by permitting reliance on vendor-issued accessibility audit reports for standard, non-customized applications, while reaffirming independent audit requirements for customized platforms and clarifying that compliance responsibility remains with Trading Members.

Actions if Any –

• Conduct accessibility audits through IAAP-certified accessibility professionals for applicable digital platforms.

• Obtain vendor accessibility audit reports and supporting covering letters where relying on vendor-certified standard applications.

• Ensure System Auditor validation of vendor-provided certificates wherever the System Audit requirement applies.

• Continue independent accessibility audits for customized or in-house digital platforms.

• Submit the Final Accessibility Audit Report for digital platforms to the Exchange through the prescribed mechanism once notified.

Compliance Deadline –

• Trading Members shall submit the Final Accessibility Audit Report for Digital Platforms to the Exchange by July 31, 2026.