Digital KYC accessibility

A standard eKYC process often asks an applicant to blink, to prove they are a live person and not a photograph. That test works for most people, but not for someone who is blind and cannot perform it.

Following a Supreme Court judgment, SEBI now requires intermediaries to build alternatives into digital KYC, so that a disability does not become a barrier to opening an account or accessing derivatives markets at all.

The Supreme Court of India, in a judgment dated 30 April 2025, emphasised the need for easy access to financial services for persons with disabilities. Following this, SEBI's circular of 23 May 2025 requires intermediaries dealing in derivatives to ensure the digital KYC process is accessible to persons with disabilities.

Specifically, intermediaries must ensure: an account can be opened with the signature of a guardian; eKYC is available for persons with disabilities; and where the standard eKYC "proof of liveliness" test — asking the applicant to blink — cannot be performed, as with a blind applicant, the intermediary must not deny eKYC benefits on that basis. Instead, alternate parameters may be used, such as facial expressions, nodding of the head, the client visibly showing an OTP on screen, real-time video recording, or displaying copies of documents on screen.

A visually impaired investor wants to open a commodity trading account through an intermediary's digital KYC process. The standard liveliness test asks her to blink on camera — something she cannot reliably perform in the way the system expects.

Under the May 2025 requirement, the intermediary cannot simply reject her application or force her into a purely offline process. It must instead offer an alternate verification method — for instance, having her nod her head on camera, read out a visible OTP while her face and the screen are both recorded, or display her documents to the camera in real time — so that her disability does not become a reason she is denied access to eKYC-based account opening.

Chapter 10, in the KYC section following the general KYC-for-existing-clients discussion, introduces this requirement with the Supreme Court judgment date and the SEBI circular reference. Expect a question naming the specific alternate verification methods listed, and one testing that eKYC benefits must not be denied to a person who cannot perform the standard liveliness test.

• The requirement does not exempt disabled applicants from KYC — it requires an accessible alternative, not a waiver of KYC itself.
• A guardian's signature is one accepted route for account opening, but eKYC accessibility through alternate liveliness parameters is a separate, additional requirement, not a substitute for it.
• This is a 2025 development, tied specifically to a Supreme Court judgment on disability access to financial services — do not confuse it with the general, older KYC Registration Agency (KRA) framework covered elsewhere in the chapter.