Compliance Guidelines for Digital Accessibility Circular ‘Rights of Persons with Disabilities Act, 2016 and rules made thereunder mandatory compliance by all Regulated Entities’ dated July 31, 2025 (Circular No. SEBI/HO/ITD1/ITD_VIAP/P/CIR/2025/111)

National Commodity & Derivatives Exchange Limited (NCDEX), vide Circular No. NCDEX/MEMBERSHIP-028/2026 dated July 17, 2026, has announced an important update regarding compliance guidelines for Digital Accessibility Circular under the Rights of Persons with Disabilities Act, 2016 and rules made thereunder for mandatory compliance by all Regulated Entities.

Key Details of the Update –

• NCDEX has issued clarifications, in consultation with SEBI, to facilitate uniform implementation of the Digital Accessibility Circulars based on representations received from Trading Members.

• 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.

• Standard Digital Platforms: Where standard applications/platforms (such as front-office CTCL solutions, back-office client access, e-KYC products, mobile/internet trading applications, etc.) are used across multiple Trading Members without any customization affecting accessibility, Trading Members may rely on the vendor's Accessibility Audit Report and certificate issued by an IAAP-certified accessibility professional. The vendor shall also provide a covering letter containing details of the digital platform (including version, where applicable) and the IAAP-certified accessibility professional who conducted the audit.

• A checkpoint shall be incorporated into the Standardised Terms of Reference (TOR) of the System Audit, wherever applicable, requiring the System Auditor to validate that the vendor's Accessibility Audit Certificate relates to the standard version of the software/application and that no customization affecting accessibility has been carried out. For Trading Members not required to submit a System Audit Report, an alternative submission mechanism will be notified separately.

• Customized/Unique Digital Platforms: Trading Members using customized or in-house digital platforms, including websites, mobile/web applications, back-office systems, KYC applications, or other proprietary systems, shall continue to undertake an independent Accessibility Audit through an IAAP-certified accessibility professional.

• The Circular clarifies that vendors are not under any regulatory obligation to obtain or provide an Accessibility Audit Report. Such arrangements shall be governed by contractual terms between the vendor and the Trading Member. Trading Members may also choose to appoint their own IAAP-certified accessibility professional instead of relying on the vendor's report.

• The responsibility for compliance with the applicable Digital Accessibility Circulars, including implementation of remediation measures and adherence to prescribed accessibility standards, shall continue to rest solely with the concerned Trading Members.

• Applicability: All Trading Members of NCDEX.

• Effective Date: July 17, 2026 (date of the Circular).

• Penalty/Consequence: Not Mentioned.

Actions if Any –

• Ensure all digital platforms undergo an Accessibility Audit by an IAAP-certified accessibility professional.

• Obtain and maintain the vendor's Accessibility Audit Report and covering letter where reliance is placed on a standard vendor-provided application.

• Conduct an independent Accessibility Audit for customized or in-house digital platforms.

• Implement remediation measures and ensure compliance with the Digital Accessibility Circulars.

• Submit the Final Accessibility Audit Report for Digital Platforms to the Exchange within the prescribed timeline.

Compliance Deadline –

• July 31, 2026 – Trading Members shall submit the Final Accessibility Audit Report for Digital Platforms to the Exchange. The submission modalities, including the designated platform/path, will be notified separately.