Last updated: October 2026.
The accessibility standards Indian banks must follow are the Ministry of Finance's "Accessibility Standards and Guidelines for Banking Sector", issued on February 2, 2024, and since January 1, 2026, RBI's Digital Banking Channels Authorisation Directions have required banks to adhere to them continuously in their digital banking operations. The standards say ICT changes, including to ATMs, websites and mobile apps, should comply with IS 17802, and that the Web Content Accessibility Guidelines 2.1 "should be followed", without naming a conformance level. IS 17802 is India's ICT accessibility standard, and its web clause treats WCAG 2.1 Level AA as equivalent conformance for web content. Vervali tests banks' websites, mobile apps, statements and documents, and onboarding and KYC journeys with screen readers on real devices.
Part of Vervali's accessibility cluster: this is the India banking spoke under the WCAG 3.0 accessibility compliance hub, alongside the accessibility testing services guide. For the testing engagement itself, see Vervali's accessibility testing service.
RBI's own accessibility texts, from the Responsible Business Conduct Directions to the KYC Directions, do not mention WCAG or IS 17802. Both reach a bank's website and apps through the Ministry of Finance standards, which name WCAG 2.1 without a conformance level; Level AA comes in through the web clause of IS 17802.
What You'll Learn
- What the Ministry of Finance banking standards cover, section by section, and where IS 17802 and WCAG 2.1 come in
- How the April 2025 Supreme Court ruling and RBI's 2026 Directions change compliance obligations
- WCAG 2.1 vs WCAG 2.2 differences that directly affect banking login, OTP, and authentication flows
- Which accessibility testing tools work best for RBI compliance — and why automated tools alone are not enough
- Short answers to the exam-style questions: the touchpoints, the digital banking interface document, the benchmark standard and the statute
- A phased 90-day roadmap to reach conformance before your next accessibility audit
| Fact | Value | Source |
|---|---|---|
| Banking accessibility standards issued | February 2, 2024 (F.No. 7/32/2022-BOA-I) | Ministry of Finance, DFS |
| Added to the RPwD Rules | July 2, 2024, as Rule 15(1)(p) (G.S.R. 361(E)) | Gazette of India |
| RBI adherence requirement in force | January 1, 2026 | RBI Digital Banking Channels Authorisation Directions, 2025 |
| WCAG wording in the banking standards | WCAG 2.1 guidelines "should be followed"; no level named | Ministry of Finance, para 2.1 |
| IS 17802 web clause | WCAG 2.1 Level AA treated as equivalent | BIS IS 17802 (Part 1), clause 9.0(b) |
| Supreme Court judgment (Pragya Prasun) | April 30, 2025: 20 directions, none with a deadline | Judgment text |
| SEBI audit and remediation deadline | October 31, 2026 | SEBI circular, July 31, 2026 |
| SEBI first annual audit compliance | April 30, 2027 | SEBI circular, August 29, 2025 |
What Do the Accessibility Standards and Guidelines for Banking Sector Cover?
The Department of Financial Services in the Ministry of Finance issued the "Accessibility Standards and Guidelines for Banking Sector" on February 2, 2024 (F.No. 7/32/2022-BOA-I), and on July 2, 2024 the Ministry of Social Justice and Empowerment added them to the Rights of Persons with Disabilities Rules as Rule 15(1)(p). RBI points banks to them twice. Its payment systems circular of October 11, 2024 (RBI/2024-25/83) says they "may also be adhered to, as applicable, by all PSPs", meaning banks and authorized non-bank payment system providers. Its Digital Banking Channels Authorisation Directions, 2025 (RBI/DOR/2025-26/380, issued November 28, 2025, effective January 1, 2026) go further and require banks to ensure "continuous adherence" to them in digital banking operations. The standards themselves state no compliance date.
Section 1.1 covers branch premises: information and service counters, tactile guidance paths, external ramps, handrails and grab bars, and access to the branch itself, with the Harmonised Guidelines 2021 of the Ministry of Housing and Urban Affairs as the benchmark for buildings.
Section 1.2 covers ATMs and other self-service machines: bulk note acceptors, cheque and cash deposit machines, passbook printers, coin vending machines and kiosks, with ATM access and ATM features set out separately and POS machines in 1.2.3. RBI's Responsible Business Conduct Directions add a rule of their own: "A bank shall ensure that all its ATMs are talking ATMs equipped with Braille keypads."
Section 2.1 covers websites and mobile apps. They "should be designed user friendly and developed in such a way that, they are accessible by all people including visually impaired", every ICT change "should comply with IS 17802", and "the guidelines issued under Web Content Accessibility Guidelines 2.1 should be followed". The section lists 13 website features, from skip-to-content links, alt text and keyboard support to text resizing, contrast schemes and ARIA support with reference to GIGW. This is the most testing-intensive section and the primary area where accessibility testing services deliver measurable compliance outcomes.
Section 1.3 covers credit and debit cards for visually impaired customers, and RBI's Responsible Business Conduct Directions require that all banking facilities, including ATM and internet banking facilities and credit cards, are "invariably offered to the visually impaired without any discrimination".
Section 2.3 of the standards covers digital documents: banks are "to follow specific provisions under IS 17802 for authoring digital documents" and to provide "bank e-statements in accessible PDF format or in alternative accessible formats such as Braille, ePUB, etc."
Section 2.2 covers accessible communication, and sections 3 and 4 cover the people and governance around every channel. Section 3 says "A mandatory on-line training needs to be completed as part of the induction process." Section 4 asks for a board policy, nodal officers at branch and head office, grievance handling with a member with a disability on the Customer Service Committee, an advisory committee, flagging of customers with disabilities in the core banking system, and disclosure in the annual report. A Department of Financial Services advisory, reported in March 2026, also asks public sector banks, insurers and other financial institutions to communicate with persons with hearing and speech impairments in Indian Sign Language.
Key Finding: The banking standards set no compliance date of their own. The date that matters is January 1, 2026, when RBI's Digital Banking Channels Authorisation Directions took effect and required banks to ensure "continuous adherence" to the standards in their digital banking operations.
Banks that test only their website or mobile app cover one section of the standards. The document runs from the branch entrance and the ATM to the e-statement, staff training and grievance handling, and a bank's accessibility work has to follow it that far.
Which Document Outlines Accessibility in the Digital Banking Interface?
The answer is a Ministry of Finance document, and four other instruments decide who must follow it and how conformance is measured.
The primary document is the "Accessibility Standards and Guidelines for Banking Sector" issued by the Department of Financial Services, Ministry of Finance, Government of India, on February 2, 2024 (F.No. 7/32/2022-BOA-I). Its section 2 covers the digital banking interface: websites and apps (2.1), accessible communication (2.2) and digital documents (2.3). The full text now sits in a "2026-01" upload folder on the Ministry's website after a site move; the document itself is dated February 2, 2024.
The RBI Digital Banking Channels Authorisation Directions, 2025 (RBI/DOR/2025-26/380, issued November 28, 2025, effective January 1, 2026) are how RBI applies it. Paragraph 9 requires banks to "ensure continuous adherence" in their digital banking operations to instructions on banking facilities for persons with disabilities, including the standards "as notified by the Ministry of Finance, Government of India on February 02, 2024". The versions for small finance banks (RBI/DOR/2025-26/381) and payments banks (RBI/DOR/2025-26/382) carry the same clause.
IS 17802 ("Accessibility for the ICT Products and Services") is the Bureau of Indian Standards' ICT accessibility standard, in two parts: Part 1, Requirements (2021), and Part 2, Determination of Conformance (2022). It is a technical adoption of the European standard EN 301 549 v3.2.1, so it reaches documents, software, hardware and two-way voice and video as well as the web, and its clause 9.0(b) says conformance with WCAG 2.1 Level AA "is equivalent to conforming with all of 9.1 to 9.4 and the conformance requirements of 9.6 of this standard". Rule 15(1)(c)(iii) of the RPwD Rules, inserted in May 2023, says websites and apps "shall comply" with IS 17802. RBI's own texts name neither IS 17802 nor WCAG; both reach banks through the Ministry of Finance standards.
GIGW 3.0 (Guidelines for Indian Government Websites and Apps) is written for government organizations, and its current version "ensures conformity with Level AA of WCAG 2.1". It binds a private entity only where another instrument adopts it: SEBI's circular does for SEBI-regulated entities, the Ministry of Finance insurance standards do for insurers, and the banking standards cite GIGW for ARIA and assistive technology support. RBI's own texts do not mention GIGW.
The Rights of Persons with Disabilities (RPwD) Act, 2016 provides the overarching legal framework. Section 46 requires service providers, "whether Government or private", to provide services in accordance with the accessibility rules made under section 40, and since July 2, 2024 those rules have listed the banking standards as Rule 15(1)(p). In November 2024, in Rajive Raturi v. Union of India, the Supreme Court held Rule 15(1) ultra vires for being recommendatory, directed the government to frame mandatory rules, and said progressive compliance with the existing standards "must continue unabated". As of October 2026 the mandatory rules for ICT were still in draft. For an overview of how these laws intersect, see our guide on digital accessibility laws in India.
The RPwD Act carries the fines for non-compliance.
What are the touchpoints for accessibility standards in banking?
The standards have no list called touchpoints. The areas they cover are branch premises (1.1), ATMs and other self-service machines (1.2), POS machines (1.2.3), cards for visually impaired customers (1.3), websites and apps (2.1), accessible communication (2.2), digital documents (2.3), staff training (3) and governance steps such as nodal officers (4). The table maps the channels a customer actually uses to those sections; for testing, the boundary is any channel a customer must operate to get a banking service.
| Touchpoint | Where the banking standards cover it | What testing checks |
|---|---|---|
| Public website and net banking | 2.1: IS 17802, the WCAG 2.1 guidelines and 13 listed website features | WCAG 2.1 Level AA, which IS 17802 treats as equivalent for web content; testing to WCAG 2.2 Level AA covers it too |
| Mobile banking apps, iOS and Android | 2.1: websites and apps | The same success criteria, applied through each platform's native accessibility APIs |
| ATMs and self-service kiosks | 1.2: ATMs, deposit machines, passbook printers and kiosks; RBI also requires talking ATMs with Braille keypads | Hardware and interface together: reach, tactile keys, audio jack output, screen-reader mode, timeout behaviour |
| IVR and phone banking | 2.2: accessible communication; no IVR-specific clause | Menu depth, timeout tolerance, and a route to a human that does not require completing the tree |
| Statements, notices and PDF documents | 2.3: IS 17802 for authoring; e-statements in accessible PDF, Braille or ePUB | A tagged reading order and real text. A PDF must have a tagged reading order and real text |
| Branch-hosted digital signage and tablets | 1.1 and 1.2, where a customer operates them | Anything a customer must operate to complete a transaction |
| Third-party and white-labelled journeys | Not named in the standards | Your obligation does not transfer to a vendor. Contract for it and test what they ship |
| Internal staff tools | Not covered; section 3 covers staff training | Employment law may still apply, but that is a separate route |
The two that consistently fail an audit are documents and third-party flows. Statements are generated by a system nobody in the digital team owns, so they leave as untagged images of text. Third-party journeys, typically a payment gateway or an onboarding vendor, are assumed to be somebody else's conformance problem and are usually not tested at all. Documents are named in section 2.3, and third-party flows reach the customer under the bank's name.
Where the requirement comes from. The Reserve Bank of India issues the sectoral direction through its directions and circulars. RBI's Digital Banking Channels Authorisation Directions point at the Ministry of Finance standards, and those standards point at IS 17802 and WCAG, maintained by the W3C Web Accessibility Initiative. RBI requires banks to adhere to the Ministry of Finance standards, which use WCAG 2.1 to define conformance.
How Does WCAG 2.2 Change Accessibility Requirements for Indian Banks?
WCAG 2.2 is the current W3C Recommendation, while the banking standards still name WCAG 2.1. SEBI asks its regulated entities for "WCAG 2.1 or latest version", and its readiness format asks whether each platform meets "AA level as per latest WCAG guidelines"; RBI's texts name neither version. Content that meets WCAG 2.2 Level AA also meets WCAG 2.1 Level AA, so a bank loses nothing by moving its test baseline to 2.2.
WCAG 2.2 adds 9 new success criteria to the 78 in WCAG 2.1 and removes one, 4.1.1 Parsing, which leaves 86 across Levels A, AA and AAA. The new standard is backward-compatible: meeting WCAG 2.2 automatically satisfies WCAG 2.1 requirements. According to the W3C, the 9 new criteria are 2 at Level A, 4 at Level AA and 3 at Level AAA.
For banking applications, two new criteria stand out as particularly impactful.
Criterion 3.3.8 — Accessible Authentication (Minimum, Level AA) prohibits cognitive function tests as the sole authentication method. In banking terms, memory-based puzzles and pattern-recognition challenges used during login or OTP verification must offer an alternative or a mechanism that helps. Object-recognition CAPTCHAs are an exception at Level AA, though an image CAPTCHA still needs a non-visual alternative under criterion 1.1.1. Banks must allow password managers, biometric login, or copy-paste OTP entry as alternatives to cognitive-test-based authentication.
Criterion 2.5.8 — Target Size (Minimum, Level AA) requires interactive elements to be at least 24x24 CSS pixels with adequate spacing. For mobile banking apps — where UPI payment buttons, fund transfer confirmation buttons, and navigation elements are frequently undersized — this criterion demands significant UI remediation.
| Aspect | WCAG 2.1 | WCAG 2.2 |
|---|---|---|
| Named in Indian texts | Banking standards (no level), IS 17802 web clause (Level AA), GIGW 3.0 (Level AA), Supreme Court directions of April 2025, SEBI ("2.1 or latest version") | Not named; reached only through SEBI's "or latest version" |
| Total Success Criteria | 78 | 86 (9 added, 4.1.1 Parsing removed) |
| RBI's own texts | Not named | Not named |
| Authentication Rules | No specific criterion | 3.3.8 Accessible Authentication - no cognitive tests without alternatives |
| Target Size Rules | No minimum size criterion | 2.5.8 Target Size - 24x24 CSS pixels minimum |
| Dragging Movements | Not addressed | 2.5.7 - single-pointer alternatives required for drag-based actions |
| Focus Visibility | Basic requirements | 2.4.11 Focus Not Obscured - sticky headers cannot hide focus indicators |
| Redundant Entry | Not addressed | 3.3.7 - multi-step forms must not re-ask for previously entered data |
| Help Consistency | Not addressed | 3.2.6 Consistent Help - help mechanisms in same relative location |
Pro Tip: Start your WCAG 2.2 transition with the two highest-impact banking criteria: 3.3.8 Accessible Authentication and 2.5.8 Target Size. Audit every login flow, OTP screen, CAPTCHA, and payment confirmation button on your mobile banking app and net banking portal.
What Did the 2025 Supreme Court Ruling Mean for Banking Accessibility?
On April 30, 2025, the Supreme Court of India delivered a landmark judgment in Pragya Prasun & Ors. v. Union of India, heard with Amar Jain v. Union of India (2025 INSC 599). The bench of Justice JB Pardiwala and Justice R Mahadevan declared that digital access is an integral part of the fundamental right to life under Article 21 of the Indian Constitution and issued 20 directions to regulators and regulated entities. One of them reads: "The respondent authorities are directed to ensure that all websites, mobile applications and digital platforms comply with the Web Content Accessibility Guidelines (WCAG) 2.1 and other relevant national standards, such as the Guidelines for Indian Government Websites (GIGW)."
The directions cover accessibility standards for all regulated entities, nodal officers, periodic audits by certified accessibility professionals with persons with blindness involved in user acceptance testing, alternatives to liveness checks, the BIS ICT standard in procurement, WCAG 2.1 and GIGW for websites and apps, and grievance handling with human review of rejected KYC applications. None of the 20 directions carries a deadline.
RBI acted on the judgment on August 14, 2025 with two circulars. RBI/2025-26/74 tells all regulated entities to comply, in one operative sentence: "All regulated entities shall undertake appropriate measures to ensure compliance with the above Supreme Court Order, as applicable." It sets no deadline, reporting requirement or penalty.
RBI/2025-26/75, issued the same day with immediate effect, is the KYC (Second Amendment) Directions, 2025. It names persons with disabilities in customer acceptance, says "No application for onboarding or periodic updation of KYC shall be rejected without application of mind", and adds that "The liveness check shall not result in exclusion of person with special needs." The consolidated KYC Directions for commercial banks carry the rule in paragraph 27(1)(v): facial gestures such as blinking or smiling are "not mandatory for liveness check", and "The bank shall take due cognizance of special needs, if any, of the customer during liveness check." For a testing team, that puts video KYC and liveness steps in scope: they must work for a customer who cannot see the prompt or make the gesture the software asks for.
Watch Out: Neither the judgment nor RBI/2025-26/74 sets a date, so the obligation applies now. Since January 1, 2026, RBI's Digital Banking Channels Authorisation Directions have required banks to adhere continuously to the Ministry of Finance standards in their digital banking operations, and the Supreme Court has directed periodic accessibility audits by certified accessibility professionals.
SEBI runs a parallel regime. Its circular of July 31, 2025 (SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111) made digital accessibility mandatory for every SEBI-regulated entity, from stock exchanges, depositories and brokers to mutual funds, and it reaches banks in their SEBI-registered roles: SEBI's clarification of December 8, 2025 lists Bankers to an Issue and Self Certified Syndicate Banks among the entities that report to SEBI directly. After two extensions, SEBI's circular of July 31, 2026 set October 31, 2026 for both the accessibility audit and the remediation of its findings. The first annual audit compliance is due by April 30, 2027, and periodic audits must be done "through certified accessibility professionals".
Insurers have standards of their own. The Ministry of Finance's Accessibility Standards and Guidelines for infrastructure and services in Insurance Sector (F. No. 16017/6/2022-Ins.I, August 20, 2024) say websites, apps and ICT services "shall comply" with IS 17802 Parts 1 and 2, that the GIGW website standard "shall be followed", and that documents should be in ePUB or OCR PDF format. Like the banking standards, they state no compliance date.
How Are Indian Banks Implementing Accessibility Testing in 2025-2026?
Union Bank of India launched its "Union Access" initiative on May 19, 2022 (Global Accessibility Awareness Day) and has since built one of India's most comprehensive banking accessibility programs. According to Inclusion.in (2025), the bank's corporate website and internet banking portal comply with WCAG 2.1 Level AA and IS 17802. The initiative includes Union Sparsh Braille Cards, Talking ATMs, an accessible Digital Rupee (CBDC) app, UVConn WhatsApp banking in 7 languages, and voice-operable banking. Union Bank's digital platforms are compatible with NVDA, JAWS and VoiceOver screen readers. The bank won the 16th NCPEDP Mphasis Universal Design Award 2025 in the Role Model Organizations category, and notably employs IAAP-certified professionals, including persons with visual impairment, in development roles.
Union Bank's program rests on a board-level Accessibility Committee, IAAP-certified team members and a formal digital accessibility policy. Section 4 of the banking standards asks every bank for the same kind of structure: a board policy, nodal officers at branch and head office, an advisory committee and disclosure in the annual report.
For mobile banking apps, mobile application testing services matter as much as web testing. Test TalkBack on Android and VoiceOver on iOS on real devices, because each platform exposes an app to its screen reader through its own accessibility API.
Which Accessibility Testing Tools Should Banks Use for RBI Compliance?
Automated tools cannot test screen reader compatibility or keyboard navigation. Automated scanners check what a machine can decide, such as missing alternative text, missing form labels and low color contrast, and they cannot tell whether a screen reader user can finish a fund transfer. The Supreme Court's directions ask all regulated entities to "involve persons with blindness in user acceptance testing phase while designing any app or website or in case of any new feature being launched", and SEBI's circular says its accessibility audit "shall include usability testing by persons with disabilities".
Banks that rely only on automated tools leave screen reader compatibility, keyboard navigation flow and cognitive accessibility untested, and each of those needs a person at the keyboard.
| Tool | Type | Cost | WCAG Coverage | Best For | CI/CD Integration |
|---|---|---|---|---|---|
| axe DevTools | Automated scanner | Free tier available; paid plans for enterprise | WCAG 2.0, 2.1, 2.2 - A, AA, AAA | Developers in CI/CD pipelines | Yes - axe-core npm package |
| WAVE | Visual overlay tool | Free for web; paid API | WCAG 2.1 - A, AA | Non-technical content editors; visual feedback | Limited - API only |
| Lighthouse | Automated audit | Free - built into Chrome DevTools | ~30 accessibility checks only | Quick audits; better for performance/SEO | Yes - Lighthouse CI |
| JAWS | Screen reader | Paid license | Manual screen reader testing | Enterprise banking accessibility testing | No - manual testing |
| NVDA | Screen reader | Free and open-source | Manual screen reader testing | Cost-effective screen reader testing | No - manual testing |
| Pa11y | Automated scanner | Free and open-source | WCAG 2.1 - A, AA | CI/CD automation; scheduled monitoring | Yes - CLI and npm |
For RBI compliance, the recommended approach combines automated and manual testing. Automated tools (axe DevTools integrated into CI/CD pipelines) catch regressions during development. Manual screen reader testing with JAWS and NVDA validates the real-world experience of users with disabilities on net banking portals. For mobile banking apps, VoiceOver (iOS) and TalkBack (Android) testing is essential. For a comprehensive comparison of testing tools, see our guide on top accessibility testing tools.
Integrating axe-core into your CI/CD pipeline through test automation services enables continuous accessibility monitoring — catching regressions before they reach production. This is critical for banks that release frequent updates to mobile apps and net banking portals.
Quick Answers to Exam-Style Questions on Banking Accessibility Standards
Each answer below comes from the document it names.
Which document outlines accessibility in the digital banking interface?
The Ministry of Finance's "Accessibility Standards and Guidelines for Banking Sector" (Department of Financial Services, F.No. 7/32/2022-BOA-I, February 2, 2024). Its section 2 covers websites and apps, accessible communication and digital documents. Since January 1, 2026, RBI's Digital Banking Channels Authorisation Directions have required banks to adhere to it in their digital banking operations.
Which of the following are the touchpoints for accessibility standards in banking?
The standards have no list called touchpoints. The areas they cover are branch premises, ATMs and other self-service machines, POS machines, credit and debit cards for visually impaired customers, websites and apps, accessible communication, digital documents, staff training, and governance steps such as nodal officers and a board policy. An option that names one of these matches the document.
Which Indian accessibility standard serves as a benchmark for the banking sector?
IS 17802, the Bureau of Indian Standards' "Accessibility for the ICT Products and Services" (Part 1, 2021; Part 2, 2022). The banking standards say all ICT changes, including ATMs, websites and mobile apps, "should comply with IS 17802". For buildings they point to the Harmonised Guidelines 2021.
What do the banking standards say about WCAG?
That "the guidelines issued under Web Content Accessibility Guidelines 2.1 should be followed". They name no conformance level; Level AA comes through IS 17802, whose web clause treats WCAG 2.1 Level AA as equivalent.
Which statutory framework mandates Indian banks to implement employment reservation and accessibility for persons with disabilities?
The Rights of Persons with Disabilities Act, 2016. On accessibility, section 46 requires service providers, government or private, to follow the rules made under section 40, and since July 2, 2024 those rules have listed the banking standards as Rule 15(1)(p). Section 89 sets the fines.
Which RBI circular told regulated entities to comply with the Supreme Court's accessibility judgment?
RBI/2025-26/74 of August 14, 2025. RBI/2025-26/75, issued the same day, is the KYC amendment that stops liveness checks from excluding persons with special needs.
What Are the Penalties for Non-Compliance with RBI Accessibility Guidelines?
Penalties and enforcement come through three routes: the RPwD Act, 2016, RBI's supervision of banks, and SEBI for capital market entities and for banks in their SEBI-registered roles.
Under the Rights of Persons with Disabilities (RPwD) Act, 2016, section 89 sets a fine of up to Rs 10,000 for a first contravention and a fine of Rs 50,000 to Rs 5,00,000 (Rs 5 lakh) for any subsequent contravention. Complaints about inaccessible digital services go to the Court of the Chief Commissioner for Persons with Disabilities, which issues recommendations. In 2026 it recommended that a stockbroker appoint "a qualified accessibility auditor (notified by the DEPWD)", remove the barriers found and report back within 30 days, and that a healthcare platform complete an audit "through an independent certified accessibility auditor" within three months.
RBI enforcement runs through its supervision of banks. The accessibility instructions themselves are short: RBI/2025-26/74 asks regulated entities to comply with the Supreme Court order "as applicable" and contains no deadline, reporting or penalty language, while the Digital Banking Channels Authorisation Directions require "continuous adherence" to the Ministry of Finance standards in digital banking operations.
SEBI enforcement applies to capital market entities (stock exchanges, mutual funds, brokers, investment advisers) and to banks acting as Bankers to an Issue or Self Certified Syndicate Banks. SEBI set October 31, 2026 for the audit and remediation in its circular of July 31, 2026, the first annual audit compliance is due by April 30, 2027, and investors can lodge accessibility complaints on SCORES, where "the RE shall remediate the accessibility related issue for the closure of the complaint".
A banking customer with a disability who is denied access to digital services can now approach the courts citing the Supreme Court's April 2025 fundamental rights ruling — transforming what was previously a regulatory matter into a constitutional rights case.
| Enforcement Channel | First Offense Penalty | Maximum Penalty | Enforcer | Active Enforcement |
|---|---|---|---|---|
| RPwD Act 2016, section 89 | Up to Rs 10,000 | Rs 5,00,000 for a subsequent contravention (minimum Rs 50,000) | Chief Commissioner for PwD hears complaints | Yes - 2026 recommendations on a broker's trading apps and a healthcare platform |
| RBI Supervisory Action | Monetary penalty + supervisory action | Case-specific | RBI | Continuous adherence required since Jan 1, 2026; no reporting cycle in RBI/2025-26/74 |
| SEBI Enforcement | Regulatory warning | SEBI enforcement action + fines | SEBI | Audit and remediation due Oct 31, 2026; first annual compliance due Apr 30, 2027 |
| Supreme Court - Article 21 | Contempt of court | Court-directed penalties | Judiciary | Active since April 30, 2025 |
How Can Banks Build a 90-Day Accessibility Compliance Roadmap?
A bank can map its platforms against the Ministry of Finance standards in 90 days.
Phase 1: Audit and Gap Analysis (Days 1-30)
Audit the net banking portal, the Android and iOS apps, the customer website, and any USSD or SMS banking interfaces against WCAG 2.1 Level AA.
Key activities during this phase include automated scanning using axe DevTools and WAVE to identify programmatic violations, followed by manual screen reader testing with NVDA (Windows), VoiceOver (iOS), and TalkBack (Android). Banks should also audit document accessibility — specifically PDF bank statements, loan agreements, and KYC forms — against tagged PDF standards.
The output of Phase 1 is a prioritized gap analysis report that maps every identified violation to the specific WCAG criterion it violates, assigns a severity level (critical, major, minor), and estimates the remediation effort required.
Phase 2: Remediation and Re-Testing (Days 31-60)
Phase 2 focuses on fixing the highest-priority violations identified in the audit. Banks should address critical violations first — keyboard traps, missing form labels, inaccessible authentication flows, and screen reader incompatibilities — before moving to major and minor issues.
During this phase, accessibility testing services provide the combination of automated scanning and manual assistive technology testing required for comprehensive remediation validation. Banks should integrate axe-core into their CI/CD pipeline during this phase to prevent new violations from being introduced during development.
Each fix should be re-tested using the same methodology (automated scan + manual screen reader validation) to confirm the violation is resolved and no new violations have been introduced. Banks should maintain a remediation log documenting each fix, which is the evidence an auditor or a supervisor will ask for.
Phase 3: Validation, Documentation, and Continuous Compliance (Days 61-90)
The final phase validates the overall accessibility posture and produces the documentation a bank needs to show adherence to the Ministry of Finance standards. Banks should conduct a full re-audit to verify that all critical and major violations have been resolved, and document the remaining minor issues with planned remediation timelines.
Banks should publish an accessibility statement on their website. No RBI text requires one, but it tells customers which standard the bank works to and where to report a barrier, and section 4 of the banking standards already asks for disclosure in the annual report. The statement should declare the WCAG level targeted, the date of the most recent audit, known limitations, and contact information for accessibility-related feedback.
Appoint nodal officers at branch and head office, as section 4 of the Ministry of Finance standards asks, and put a member with a disability on the Customer Service Committee. The same section asks for a board policy and an advisory committee, which keeps accessibility running as a program after the first round of fixes.
How Does Vervali Approach Banking Accessibility Testing?
Vervali tests banking websites, mobile apps, statements and documents, and onboarding and KYC journeys against the Ministry of Finance standards, IS 17802 and WCAG 2.1 and 2.2 Level AA. Its testers combine automated scans (axe, WAVE) with manual testing in JAWS, NVDA, VoiceOver and TalkBack on real devices, then support the fixes and retest them.
Vervali's accessibility testing services follow a six-step methodology: Accessibility Audit and Scoping, Automated Scan and Manual Review for 360-degree validation, Assistive Tech Compatibility testing across real devices and screen readers, Issue Categorization and Prioritization by WCAG level and business impact, Remediation Guidance with developer-friendly references, and Re-Testing with Continuous Compliance monitoring.
In banking and financial services, Vervali built AI deepfake detection for a Mumbai financial-services firm's digital KYC, which cut manual review time by 70% at 75% detection accuracy for known and emerging deepfake variants. In accessibility, Vervali tested more than 2,000 URLs for a US HR software provider serving more than 6,000 public-sector and education organizations, remediated more than 5,000 accessibility gaps against WCAG 2.0 and Section 508, and the client achieved Section 508 certification on the first attempt.
For banks working under RBI's Digital Banking Channels Authorisation Directions, in force since January 1, 2026, Vervali runs the test, fix and retest cycle against the sections of the Ministry of Finance standards that cover websites, apps and documents, IS 17802 and WCAG 2.1 Level AA: testing before a certified audit, help with fixing its findings, and the retest that confirms them fixed.
TL;DR: Indian banking accessibility compliance in 2026 rests on five pillars: (1) the Ministry of Finance banking standards of February 2, 2024, which point to IS 17802 and WCAG 2.1, (2) RBI's Digital Banking Channels Authorisation Directions, which have required continuous adherence to them since January 1, 2026, (3) the Supreme Court's April 30, 2025 judgment and its 20 directions, (4) WCAG 2.2's 9 new criteria (especially 3.3.8 Accessible Authentication and 2.5.8 Target Size), and (5) RPwD Act fines and complaints to the Chief Commissioner. The Supreme Court asks regulated entities to involve persons with blindness in user acceptance testing, so manual screen reader testing with JAWS, NVDA, TalkBack and VoiceOver belongs in every test cycle.
Ready to Make Your Banking Platform Accessible and Compliant?
Vervali's accessibility testing team helps Indian banks and financial institutions reach WCAG 2.1 and 2.2, IS 17802 and GIGW 3.0 conformance. From automated WCAG scanning to manual JAWS, NVDA and TalkBack testing, Vervali tests your channels, supports the fixes and retests them, so your bank can show adherence to the Ministry of Finance standards. Explore our accessibility testing services or get in touch to discuss your banking accessibility compliance roadmap.
Sources
- Department of Financial Services, Ministry of Finance (2024). "Accessibility Standards and Guidelines for Banking Sector", F.No. 7/32/2022-BOA-I, February 2, 2024. https://financialservices.gov.in/sites/default/files/reports/2026-01/Guidelines-for-Banking-Sector.pdf
- Ministry of Social Justice and Empowerment (2024). G.S.R. 361(E), July 2, 2024, inserting Rule 15(1)(p) in the Rights of Persons with Disabilities Rules, 2017. https://cdnbbsr.s3waas.gov.in/s3e58aea67b01fa747687f038dfde066f6/uploads/2024/09/202409171647156535.pdf
- Reserve Bank of India (2025). "Digital Banking Channels Authorisation Directions, 2025" for commercial banks, RBI/DOR/2025-26/380, November 28, 2025. https://www.rbi.org.in/Scripts/BS_ViewMasDirections.aspx?id=13163
- Reserve Bank of India (2025). RBI/2025-26/74, compliance with the Supreme Court order, August 14, 2025. https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=12892
- Reserve Bank of India (2025). RBI/2025-26/75, KYC (Second Amendment) Directions, 2025, August 14, 2025. https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=12893
- Reserve Bank of India (2025). "Know Your Customer Directions, 2025" for commercial banks, RBI/DOR/2025-26/169. https://www.rbi.org.in/scripts/BS_ViewMasDirections.aspx?id=13141
- Reserve Bank of India (2025). "Responsible Business Conduct Directions, 2025" for commercial banks, RBI/DOR/2025-26/170. https://www.rbi.org.in/SCRIPTs/BS_ViewMasDirections.aspx?id=13140
- Reserve Bank of India (2024). RBI/2024-25/83, "Facilitating accessibility to digital payment systems for Persons with Disabilities", October 11, 2024. https://rbi.org.in/Scripts/NotificationUser.aspx?Id=12741&Mode=0
- Supreme Court of India (2025). Pragya Prasun v. Union of India, 2025 INSC 599, judgment of April 30, 2025. https://indiankanoon.org/doc/68332080/
- Supreme Court of India (2024). Rajive Raturi v. Union of India, 2024 INSC 858, judgment of November 8, 2024. https://api.sci.gov.in/supremecourt/2005/9321/9321_2005_1_1503_56986_Judgement_08-Nov-2024.pdf
- Bureau of Indian Standards. IS 17802 (Part 1): 2021 and IS 17802 (Part 2): 2022, "Accessibility for the ICT Products and Services", in the DEPwD compilation. https://cdnbbsr.s3waas.gov.in/s3e58aea67b01fa747687f038dfde066f6/uploads/2023/11/202311291533057741.pdf
- Rights of Persons with Disabilities Act, 2016, sections 46 and 89. https://indiankanoon.org/doc/29311573/ and https://indiankanoon.org/doc/33042789/
- SEBI (2025). SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111, July 31, 2025. https://www.sebi.gov.in/legal/circulars/jul-2025/rights-of-persons-with-disabilities-act-2016-and-rules-made-thereunder-mandatory-compliance-by-all-regulated-entities_95745.html
- SEBI (2025). SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/121, extension of timelines, August 29, 2025. https://www.sebi.gov.in/legal/circulars/aug-2025/extension-of-timelines-and-update-of-reporting-authority-for-ias-and-ras-w-r-t-sebi-circular-for-compliance-to-digital-accessibility-circular-rights-of-persons-with-disabilities-act-2016-and-rules-_96353.html
- SEBI (2025). "Clarification on the Digital Accessibility circulars of SEBI", December 8, 2025. https://www.sebi.gov.in/legal/circulars/dec-2025/clarification-on-the-digital-accessibility-circulars-of-sebi_98238.html
- SEBI (2026). "Extension of timelines with respect to compliance of Digital Accessibility Circulars", July 31, 2026. https://www.sebi.gov.in/legal/circulars/jul-2026/extension-of-timelines-with-repect-to-compliance-of-digital-accessibility-circulars-_103277.html
- Department of Financial Services, Ministry of Finance (2024). "Accessibility Standards and Guidelines for infrastructure and services in Insurance Sector", F. No. 16017/6/2022-Ins.I, August 20, 2024. https://financialservices.gov.in/sites/default/files/2026-01/Accessibility-Standards-and-Guidelines-for-infrastructure-and-services-in-Insurance-Sector.pdf
- Press Information Bureau (2026). Department of Financial Services advisory on Indian Sign Language. https://www.pib.gov.in/PressReleasePage.aspx?PRID=2241272
- MeitY and NIC. Guidelines for Indian Government Websites and Apps (GIGW 3.0). https://guidelines.india.gov.in/new-features-of-gigw-3-0/
- Court of the Chief Commissioner for Persons with Disabilities (2026). Case No. 14725/1101/2023. https://cdnbbsr.s3waas.gov.in/s39fb7b048c96d44a0337f049e0a61ff06/uploads/2026/06/202606191724201993.pdf
- Court of the Chief Commissioner for Persons with Disabilities (2026). Case No. 13205/1102/2022, order of July 22, 2026. https://cdnbbsr.s3waas.gov.in/s39fb7b048c96d44a0337f049e0a61ff06/uploads/2026/08/202608091685237439.pdf
- W3C (2024). "Web Content Accessibility Guidelines (WCAG) 2.2". https://www.w3.org/TR/WCAG22/
- Inclusion.in (2025). "Union Bank of India's Union Access Initiative Redefines Inclusive Banking." https://inclusion.in/article/2025/11/no-indian-left-behindunion-bank-of-indiasunion-access-initiative-redefines-inclusive-banking/
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