RBI Digital Accessibility Compliance Guide for Banks & NBFCs

01 · THE HEADLINE

What is the RBI digital accessibility mandate?

Put simply: every RBI-regulated entity must now make its digital services — websites, mobile apps, KYC journeys, ATMs and more — usable by persons with disabilities, including people who are blind or have low vision, and acid attack survivors.

This is no longer a matter of good practice. A Supreme Court judgment, an RBI circular and an amended KYC rulebook have turned digital accessibility into a compliance obligation with an "immediate action" expectation.

How the mandate came together

1. 1
   April 30, 2025 — Supreme Court judgment. In Pragya Prasun & Ors. v. Union of India and Amar Jain v. Union of India, the Court held that access to digital services is part of the right to life under Article 21 of the Constitution, and issued 20 directions to regulators and regulated entities.
2. 2
   The case had a banking origin. It was sparked by real exclusion — including a petitioner who could not open a bank account because she could not perform the blinking required by a liveness check during verification.
3. 3
   August 14, 2025 — RBI circular (RBI/2025-26/75). The RBI wrote to all regulated entities asking for immediate compliance with the judgment's directions.
4. 4
   KYC (2nd Amendment) Directions, 2025. The RBI amended its KYC Master Direction to bake disability-inclusive protections into the rulebook.

02 · SCOPE

Who needs to comply?

If your organisation is an RBI-regulated entity (RE) with customer-facing digital services, the mandate applies to you. That includes:

In short: if a customer interacts with your organisation through a website, app, video KYC flow or ATM, you are in scope.

03 · COURT DIRECTIONS

What the Supreme Court told banks and NBFCs

Most of the 20 directions were addressed to regulators, but several land directly on banks and NBFCs. The key ones:

04 · RULEBOOK

What changed in the RBI's KYC rules

The KYC (2nd Amendment) Directions, 2025 folded these protections into the Master Direction on KYC. In practical terms:

• Persons with disabilities are now a specifically protected class in the KYC framework.
• No mandatory blinking for liveness in video KYC; alternative verification methods are allowed.
• Aadhaar Face Authentication and thumb impressions are accepted as biometric alternatives.
• Rejections must be justified, documented and reviewed by a human — not left to an automated checkbox.
• The CKYC Registry (CERSAI) updated its KYC template (live from September 30, 2025) to capture disability type and percentage, so this data is formally recorded.

05 · ACTION PLAN

Your phase-by-phase compliance roadmap

The RBI's expectation is "immediate compliance," but the work is best sequenced. Here is a practical roadmap shaped by the Supreme Court directions and the RBI notification.

06 · FRAMEWORK

The standards and laws behind all this

You do not have to invent your own rulebook. The framework rests on:

07 · THE BIGGER PICTURE

Why this matters beyond avoiding penalties

It is tempting to treat this as paperwork. It isn't:

• It is a constitutional obligation now. The Supreme Court tied digital access to Article 21 — this carries real legal weight.
• It expands your customer base. Accessible banking reaches millions of people with disabilities, plus older customers and anyone using assistive technology.
• It is better design for everyone. Clear navigation, flexible KYC and well-structured documents improve the experience for all customers.
• It reduces risk. Documented, human-reviewed processes protect you from discrimination claims and regulatory scrutiny.

08 · FAQ

Quick answers