FINANCIAL INCLUSION · RBI MANDATE 2025
Digital Accessibility for NBFCs
Help make Non-Banking Financial Company digital services accessible to all customers — loan journeys, KYC, mobile apps and websites — with WCAG 2.1, WCAG 2.2, IS 17802 and the RBI's digital accessibility mandate in mind.
Digital Accessibility Is Now a Compliance Requirement for NBFCs
The Supreme Court of India (April 30, 2025) held that digital access is part of the right to life under Article 21, and the Reserve Bank of India followed with a compliance circular on August 14, 2025 (RBI/2025-26/75) addressed to all regulated entities — including NBFCs — asking for immediate action. The RBI also amended its KYC rulebook so that customer verification journeys are inclusive of persons with disabilities.
Why Digital Accessibility Matters for NBFCs
NBFCs provide digital lending, asset finance, wealth services and consumer credit through websites, mobile apps and loan management portals. When those interfaces are inaccessible, customers with visual, hearing, motor or cognitive disabilities are excluded from credit and financial services they are entitled to use independently.
Following the RBI mandate, accessibility is no longer optional for NBFCs. Beyond compliance, accessible design widens your customer base — India has over 26 million persons with disabilities — reduces discrimination risk, and improves the experience for every user of your platform.
What Falls in Scope for an NBFC
If a customer interacts with your organisation through any of the following, the RBI mandate applies to you:
Websites & Web Apps
Loan application portals, EMI calculators, document upload flows and account dashboards.
Mobile Apps
Consumer lending apps, repayment apps and any customer-facing mobile interface.
KYC / e-KYC / Video KYC
Verification journeys must work for persons with disabilities — including liveness checks that do not rely on eye-blinking.
Digital Documents & e-Forms
Sanction letters, loan agreements, statements and e-sign flows must be readable by assistive technology.
Key Requirements for NBFCs
IS 17802:2022
The Bureau of Indian Standards ICT accessibility standard is the RBI's core technical benchmark — covering websites, apps, KYC modules, documents and ATMs.
WCAG 2.1 & 2.2
Global W3C guidelines covering contrast, keyboard navigation and screen reader compatibility — the accessibility baseline.
Inclusive KYC & Liveness
No mandatory blinking in video KYC — offer gesture-, facial-movement- or audio-based alternatives. Accept Aadhaar Face Authentication and thumb impressions.
Human Review of Rejections
No auto-rejecting applications from persons with disabilities. Rejections need human review, documented reasons and a designated officer who can override automated decisions.
Certified Accessibility Audits
Periodic audits by certified professionals (IAAP-certified), with usability testing by persons with disabilities — not internal self-assessments.
Accessible Customer Support
Dedicated PwD helplines, staff sensitisation, sign-language interpreter support over video, and doorstep or assisted authentication options.
A Practical Compliance Roadmap for NBFCs
The RBI expects "immediate compliance," but the work is best done in stages. Here's a phased path:
Phase 1Assess & Set Policy
Inventory every customer-facing platform, document barriers, and update your KYC policy and SOPs with disability-inclusive protocols and accessible paper-based options.
Phase 2Fix the Technical Foundation
Add alternative liveness detection, accept Aadhaar Face Authentication and thumb impressions, meet IS 17802:2022 across platforms, and integrate assistive technology support.
Phase 3Add Human Support
Set up a PwD helpline, train branch and call-centre staff, allow nominated guardians to assist, and provide sign-language interpreters over video.
Phase 4Test & Validate
Test full customer journeys with people across disability types, engage an IAAP-certified auditor, and security-test alternative authentication methods.
Phase 5Train & Sustain
Build training modules for staff, Business Correspondents, agents and vendors — and keep a regular audit and reporting schedule to the RBI.
How A11yGo Helps NBFCs
A11yGo supports the full accessibility improvement lifecycle for NBFC organizations:
From a free assessment to remediation guidance and assistive technology for your customers, A11yGo helps you turn a compliance obligation into a verifiable, defensible position.
NBFC Assessment
Evaluate your NBFC website, app or KYC journey for accessibility barriers aligned with IS 17802, WCAG and the RBI mandate.
Get Free AssessmentRBI Compliance Guide
Everything NBFCs and banks need to know about the Supreme Court judgment, RBI circular RBI/2025-26/75 and the KYC (2nd Amendment) Directions, 2025.
Read the RBI Guide