SEBI's extension of the digital accessibility audit deadline to October 31, 2026, is not a reprieve. It's a planning window. If you're treating this as extra time to delay, you're setting up your regulated entity for a last-minute scramble that produces documentation without substance.
This template provides a structured audit checklist you can deploy immediately. It's built around the reality that SEBI hasn't changed the underlying accessibility requirements. The extension only shifts when you must complete the audit and remediation cycle.
Purpose of This Template
This checklist structures your SEBI accessibility audit process from initial scoping through validation. It's designed for compliance officers and GRC teams who need to coordinate technical audits, remediation sprints, and conformance documentation across multiple digital platforms.
You'll use this to:
- Define which digital properties fall under SEBI's accessibility requirements
- Track audit findings against WCAG conformance levels
- Prioritize remediation based on regulatory risk and user impact
- Document evidence for your Accessibility Conformance Report
- Validate fixes before the October 31, 2026, deadline
This isn't a technical testing guide. It's a compliance coordination framework that sits above your technical audit work.
Prerequisites
Before you deploy this template, confirm you have:
Regulatory clarity: You've reviewed SEBI's digital accessibility circulars and understand which platforms require audits (web portals, mobile apps, investor-facing tools).
Technical resources: You have access to either internal accessibility testers or external audit partners who can execute WCAG 2.1 Level AA conformance testing.
Stakeholder alignment: Your development teams, legal counsel, and executive sponsors understand that the deadline extension doesn't change what you must achieve.
Documentation systems: You can track findings, assign remediation tasks, and maintain an audit trail. A spreadsheet works. A GRC platform works better.
The Template
Phase 1: Audit Scoping (Week 1-2)
Platform Inventory
- List all customer-facing digital platforms (web, mobile, investor portals)
- Identify platforms under SEBI jurisdiction vs. out-of-scope properties
- Document current WCAG conformance claims (if any exist)
- Note third-party components or vendors embedded in platforms
- Flag platforms with planned redesigns or migrations before October 2026
Audit Partner Selection (if using external auditors)
- Confirm auditor uses WCAG 2.1 Level AA as baseline
- Verify they provide detailed remediation guidance, not just issue lists
- Request sample deliverables (audit reports, conformance documentation)
- Establish turnaround time for audit completion and re-testing
Phase 2: Audit Execution (Week 3-8)
Conformance Testing
- Execute automated scans (axe DevTools, WAVE, or equivalent) on all in-scope pages
- Conduct manual keyboard navigation testing on interactive components
- Perform screen reader testing (NVDA on Windows, VoiceOver on macOS/iOS)
- Test forms, error handling, and dynamic content updates
- Review color contrast ratios using contrast analyzers
- Validate focus indicators and skip navigation links
- Test multimedia content for captions and audio descriptions
Documentation Requirements
- Log each WCAG success criterion failure with specific page/component reference
- Assign severity ratings: Critical (blocks core functions), High (significant barriers), Medium (usability issues), Low (minor violations)
- Capture screenshots or screen recordings demonstrating each issue
- Note whether issue affects web, mobile, or both platforms
- Record which assistive technologies are impacted
Phase 3: Remediation Planning (Week 9-10)
Prioritization Framework
- Separate issues by platform (web vs. mobile requires different fix approaches)
- Identify quick wins: issues fixable with HTML/CSS changes in under 2 hours
- Flag structural issues requiring design or architecture changes
- Estimate development effort for each remediation item
- Create sprint-based remediation roadmap through September 2026
Risk Assessment
- Mark issues that expose you to investor complaints or regulatory scrutiny
- Identify failures in authentication flows, transaction processes, or disclosure documents
- Note any patterns suggesting systemic problems (missing alt text across all pages, consistent color contrast failures)
- Document temporary accommodations if full remediation requires platform rebuild
Phase 4: Remediation Execution (Week 11-28)
Fix Implementation
- Assign remediation tasks to development teams with clear acceptance criteria
- Require developers to test fixes with keyboard and screen reader before marking complete
- Implement code review checkpoints for accessibility-specific changes
- Update component libraries or design systems to prevent regression
- Document what Web Accessibility Specialist changed and why for each remediation item
Ongoing Validation
- Re-test each fixed component using the same method that identified the original issue
- Verify fixes don't introduce new accessibility barriers
- Confirm fixes work across different browsers and assistive technologies
- Update your issue log with validation results and closure dates
Phase 5: Conformance Documentation (Week 29-32)
Accessibility Conformance Report Preparation
- Compile evidence of WCAG 2.1 Level AA conformance for each platform
- Document known issues that remain unresolved with remediation timelines
- Prepare partial conformance claims if full conformance isn't achieved
- Include testing methodology and tools used
- Note any third-party content or components not under your control
Final Validation
- Conduct end-to-end user flows with assistive technology
- Test critical investor functions (account access, document retrieval, transaction submission)
- Verify all documentation accurately reflects current platform state
- Confirm remediation evidence is traceable to specific WCAG success criteria
Customizing the Template
If you're auditing multiple brands or subsidiaries: Add a column to track which entity owns each platform. SEBI's requirements apply entity-by-entity, so you need clear ownership assignment.
If you're using agile development: Break Phase 4 into two-week sprints. Assign a fixed number of remediation items per sprint based on team capacity. Don't plan more than six weeks out because priorities shift.
If you have limited internal accessibility expertise: Add a knowledge transfer requirement to your audit partner contract. Require them to train your developers on common WCAG failures during the remediation phase.
If you're managing vendor platforms: Insert a vendor assessment step in Phase 1. Request Accessibility Conformance Reports from third-party providers. If they can't provide conformance documentation, that's a procurement risk you need to escalate.
Validation Steps
Before you consider this checklist complete:
Audit coverage: Confirm you've tested representative samples of each platform type. You don't need to test every page, but you must test every template and interaction pattern.
Evidence quality: Review your documentation. Can you demonstrate to SEBI auditors exactly what you tested, what you found, and what you fixed? Vague claims don't satisfy regulatory scrutiny.
Stakeholder sign-off: Your legal and compliance teams should review your conformance claims before you finalize documentation. Overclaiming conformance creates liability.
Regression prevention: Verify you've updated your development standards, component libraries, or design systems to prevent reintroducing the same issues in future releases.
The October 31, 2026, deadline hasn't eliminated your accessibility obligations. It's given you time to build evidence that you're managing those obligations systematically. This template structures that evidence collection. What you do with the time between now and October determines whether you're demonstrating compliance or just documenting panic.
