Choose an Accessibility Audit Partner

Suppose a screen-reader user can browse a mutual fund's scheme page but cannot tell whether an investment form has accepted an amount. The problem is not captured by a homepage score. It appears only when the team tests a real transaction and its feedback states.

For AMCs, accessibility testing should be organized around systems and journeys rather than a list of URLs. SEBI's Mutual Funds Master Circular points AMCs and MFs to its digital accessibility guidelines, and the original circular requires audits of digital platforms and annual follow-up.

Model the platform boundary

Build an inventory that includes the public website, investor portal, mobile application, and content published through them. For each surface record its owner, deployment version, authentication requirements, and third-party dependencies. A vendor-hosted KYC step should not disappear from the scope just because it has a different domain.

Choose a representative sample of high-impact journeys: onboarding, e-KYC or video KYC, investment, redemption, statement retrieval, and complaint submission. Map the expected success path and the recovery path for each. Capture the exact build and test account used, without putting personal data in the evidence package.

Combine tools with human verification

Run automated accessibility checks early to find repeatable issues such as missing names or detectable contrast failures. Then use the keyboard, a screen reader, zoom or magnification, and manual inspection to test actual operability and comprehension. SEBI's July 2025 directions call for usability testing by persons with disabilities; it is not interchangeable with automation.

Use WCAG 2.1 or a later version as specified by the circular, alongside the other named references: current GIGW guidance, IS 17802, and the applicable RPwD framework. State the specific versions and methods in the report rather than treating “WCAG checked” as a complete methodology.

Documents are part of the build

Test a risk-based sample of published PDFs. Visual layout is not enough: inspect tagging, heading hierarchy, reading order, tables, link names, and alternatives for informative images. The same issue-log discipline applies to PDFs as to app screens: location, observed behavior, impact, fix, owner, and retest result.

Structure the submission data correctly

SEBI's September 2025 guideline defines Table C3 for the initial audit submission and Table C4 for the final submission. Each is a format containing details about the auditor, platforms, and findings. The consolidated audit report is an attachment, not the table itself. C4 adds remediation measures, compliance status, and supporting evidence.

For engineering teams, that means every final claim should point back to an issue, a code or content change, and a retest. If a barrier remains, state its status accurately. Do not mark a defect closed because a ticket moved to “done.”

SEBI extended the audit and remediation timeline to October 31, 2026 in its July 2026 circular; confirm the latest notice before using any date in a filing.

Primary references: original direction, C3/C4 formats, MF Master Circular, timeline update.

Read the original guide on IAAP Audit: https://iaapaudit.com/blog/sebi-accessibility-audit-checklist-mutual-funds-amcs