Digital Accessibility Compliance for Alternative Investment Funds (AIFs) in India: A Practical Guide

Digital accessibility is becoming a crucial mandate for organisations across sectors in India. For Alternative Investment Funds (AIFs), understanding and implementing digital accessibility compliance is more than a legal obligation, it is a meaningful step toward inclusion and equal opportunity for persons with disabilities (PwDs)

This blog explains digital accessibility compliance requirements in India, specifically for AIFs. It also highlights recent regulations, the role of the Department of Empowerment of Persons with Disabilities (DEPwD) and practical steps AIFs can take to comply.

What is Digital Accessibility?

Digital accessibility means designing websites, apps and digital documents so everyone, including people with disabilities, can use them easily. Disabilities can be visual (blindness, low vision), hearing, movement-related or cognitive. 

Digital accessibility removes obstacles, ensuring PwDs can navigate, read, hear and interact with digital content.

For AIFs, digital accessibility means making investor portals, fund documents, communication materials and websites usable by all. When digital content is accessible, investors with disabilities have the same access to fund information and services as others.

Why Must AIFs Care About Digital Accessibility?

India has over 26 million PwDs who are potential investors or stakeholders in financial markets. The Rights of Persons with Disabilities (RPwD) Act, 2016 which protects the rights of PwDs, mandates accessibility in all public-facing and private digital platforms to enable equality and non-discrimination.

In 2025, SEBI issued guidelines specifically requiring regulated entities, including AIFs, to comply with digital accessibility standards. Non-compliance risks legal penalties and harms reputation. More importantly, accessible digital platforms demonstrate social responsibility and expand the investor base by including persons with disabilities.

AIFs operate in a heavily regulated environment and digital accessibility compliance fits into this by ensuring clear, accessible communication and a fair investment process for all potential investors.​

Rights of Persons with Disabilities Act 2016

The RPwD Act is the foundation of accessibility laws in India. It mandates reasonable accommodations and non-discrimination in all areas including digital communication. The Act has been strengthened recently to emphasize digital inclusion and specify penalties for violations.​

SEBI’s Digital Accessibility Circular 2025

SEBI’s circular issued in July 2025 requires all regulated entities, including AIFs, to:

• Ensure websites and investor interfaces are accessible
• Conduct audits by certified accessibility experts
• Address all accessibility issues found
• Appoint officers responsible for accessibility compliance
• Report compliance status annually to SEBI

SEBI recognizes IS 17802 (India’s digital accessibility standard) and international standards like WCAG 2.1 as benchmarks.​

Role of DEPwD

DEPwD works closely with SEBI to ensure government policies on accessibility are implemented effectively. It provides detailed guidelines and public awareness campaigns for sectors including finance.​

What Does Accessibility Look Like for AIFs?

For an AIF, digital accessibility means:

• Investor portals and websites that work for users with screen readers, keyboard navigation and other assistive tools
• Fund documents (PDFs, presentations) available in accessible formats (tagged PDFs, readable fonts)
• Videos with captions or sign language interpretation
• Clear, simple language and consistent navigation
• Accessible online forms and transaction interfaces

Basically, any digital content that investors use to access fund information or perform transactions must be usable by all.

How Can AIFs Become Compliant?

Step 1: Identify Digital Assets

List all websites, mobile apps, investor portals, transaction systems and documents that you provide to investors digitally.

Step 2: Conduct an Accessibility Audit

Hire IAAP-certified experts to test these digital assets. They will check how well your platforms work with assistive technologies and conform to standards like WCAG 2.1 and IS 17802.

Step 3: Fix Accessibility Issues

Based on audit reports, implement changes such as:

• Adding accurate alt text to images
• Ensuring keyboard-only navigation works
• Improving color contrasts for readability
• Tagging PDFs correctly for screen readers
• Adding captions to videos

Step 4: Appoint Compliance Officers

Designate personnel responsible for monitoring accessibility issues and responding to investor feedback.

Step 5: Train Staff and Vendors

Educate developers, marketers and customer service teams about accessibility requirements.

Step 6: Submit Compliance Reports

Report accessibility status to SEBI annually and keep up with any new regulations.

Benefits Beyond Legal Compliance

Beyond avoiding penalties, digital accessibility offers real benefits:

• Expands your investor base by including PwDs
• Enhances overall user experience for all investors
• Demonstrates corporate social responsibility and goodwill
• Reduces legal and reputational risks
• Future-proofs digital platforms against emerging standards

Challenges and How to Overcome Them

Some common challenges for AIFs include:

• Lack of awareness about accessibility standards
• Limited technical expertise
• Budget concerns for audits and redesigns
• Ongoing maintenance to keep compliant with new updates

Solutions:

• Engage expert consultants early to guide the process
• Plan accessibility into new designs from the start
• Use affordable tools that automate some accessibility checks
• Train in-house teams for continual improvement

Inclusion is the Way Forward

Digital accessibility compliance is a key regulatory requirement and a strong signal of inclusion for AIFs. By aligning with laws like the RPwD Act and SEBI’s 2025 guidelines, AIFs can ensure seamless access for all investors, foster trust and contribute to a more inclusive financial ecosystem in India.

Taking proactive steps today will help AIFs comply with the law and become leaders in responsible investing by adopting accessibility.