Digital KYC still excludes people with disabilities despite new rules

However, a crucial blindspot remains around know-your-customer (KYC) infrastructure.

Take the case of Pragya Prasun, an acid attack victim who couldn’t blink for an electronic KYC video call because of her facial burns and loss of vision in her left eye. “Bank employees said I couldn’t open a bank account in my name because I couldn’t blink. It is an RBI regulation for digital KYC. I reached out to ICICI Bank through their social media channels but there was no response until I received 25,000 signatures for my online petition," said Prasun, who was ultimately able to open an account with the bank.

This was followed by a two-year battle in the Supreme Court, which issued 20 directives to financial regulators in India, such as being considerate with applications of people with disabilities and looking for alternatives to the “liveliness" check. This forced the Reserve Bank of India and the Securities and Exchange Board of India to fix parts of the digital KYC ecosystem.

Yet, significant gaps remain. Mint Money spoke to people with disabilities to understand the hurdles they continue to face.

What has changed?

The Supreme Court ruling called for barrier-free digital environments for people with disabilities. Following this, Sebi issued guidelines on accessibility & inclusiveness of digital KYC, while the RBI altered video-based identification in August 2025, saying, “The liveness check shall not result in exclusion of persons with special needs."

While this is a step in the right direction, it may not be enough. According to Sumanta Ghosh, chief technical officer at Bandhan Life, several digital gaps need urgent attention.

For example, conducting e-KYC over video calls eases the burden for those with physical disabilities, but may still pose challenges. Consider the case of Rahul Kelapure, a visually impaired Mumbai resident who was required to sign on a screen using his finger as part of his e-KYC. “While I have acquired the skill to sign on paper over the years, I have no means to ascertain if the signature is correct on a screen." In fact, of the 26.8 million registered Indians with disabilities in 2011, about 12.2 million were illiterate and thus unable to sign.

Then during the second KYC call, Kelapure had to hold his ID Card up to the screen but ended up holding it the wrong way, causing his spouse, who also has a physical disability, to step in and help. “The video KYC call was disconnected as they sensed someone else was in the room, telling me to move the card to the left. In another attempt my friend stepped in to move the card on without speaking, with no luck," Kelapure said. He, like many others, was also unable to remember and recite his PAN for verification, which is for e-KYC. In the end, it took him five attempts to complete his KYC.

Harsh Vardhan Masta, Head of Payments at Policybazaar, said, “E-KYC guidelines are rigid about the ‘no assistance allowed’ rule. But when a caregiver helps a person with a disability to read or follow instructions, it shouldn’t be considered fraud. It is offering accessibility."

Technological sensitivity

When applying for an Aadhar card, a thumb print is the usual alternative when an iris scan fails. But for people with certain disabilities, this isn’t a solution. Take the case of Pune resident Shweta Runwal’s child, who has Down’s syndrome. She struggled to register her thumb prints or keep her eyes steady for the iris scan for her Aadhar card. “It took multiple re-takes to get her card processed," said Runwal.

To resolve this biometric issue, the RBI has offered another option – face authentication based on UIDAI data. But for a friend of Runwal’s, even this isn’t a perfect solution as she hasn't been able to get an Aadhar card itself. “Those with higher levels of impairment can’t stare into devices and screens for long. Even making eye contact is sometimes difficult as they squint," Runwal said.

Masta said, “Most digital KYC systems assume that consumers can read small text on a screen, hold a phone steady, follow visual instructions, or complete facial ‘liveness’ checks. For millions of users, these assumptions simply do not hold."

Simple tasks such as entering CAPTCHA code, often the first step in KYC processes, can be nearly impossible for the visually impaired or those with cerebral palsy. Similarly, hearing impaired can't respond to yes no questions asked over video calls.

“Lack of built-in assistive technologies in most eKYC systems, such as screen readers for the visually impaired or voice-to-text tools for those who are speech or hearing impaired, makes the process inaccessible to many," Ghosh said.

“For the KYC process to be truly inclusive, the future must embrace alternative methods for liveliness detection—such as head nods, facial expressions, or other accessible prompts—that cater to people with physical abilities," Ghosh added.

Possible solutions

An alternative for CAPTCHA could be screen-reader support, visible focus, keyboard operability and audio codes, as well as 200% scalable text without content loss, suggested Krishna Kishore Chukkapalli, MD & CEO of KYC registration agency KFIN. Time-out leniency should be offered, and face-to-face KYC should be an option if digital isn’t feasible, he added. Also, when biometrics are not an option, “ensure OTP-based and document-only fallbacks," he said.

Individuals such as Kelapure should be allowed to have a trusted aide to help, without treating this as ‘prompting’, others said. “We are exploring the possibility of assisting with scanned documents instead of manually presenting them during calls and speech to text or vice-versa," Swarup Mohanty, vice chairman and CEO at Mirae Asset Investment Managers, which offers a dedicated desk for people with disabilities in every branch.

Another way to facilitate better access would be to allow certain exemptions for people with disabilities based on documents. “Entities should accept disability certificates and not insist on impossible tasks," said Chukkapalli.

A process to fast-track grievance redressal would also go a long way towards inclusivity. While people can write to the ministry of social justice and empowerment seeking legal action under the Rights of Persons with Disabilities Act, Sebi’s new rules make it easier for users to raise formal complaints or pursue litigation if digital services are inaccessible to them. Sebi has mandated publishing an accessibility statement and a grievance route, as well as appointing a nodal officer for digital accessibility compliance.

“Track and report KYC failures on account of disability and provide fast-track redressals for customers that are denied access. Inclusiveness should be assessed with the same serious lens as compliance," said Masta.

The cost of inclusivity

“Accessibility should be in the same non-negotiable vein as cybersecurity. Equal access requires clarity, not ambiguity", Masta said.

Sebi-regulated entities will have to hire an accessibility auditor before 14 December 2025, who will need to complete an accessibility audit by 30 April 2026.

Costs, therefore, are a concern, especially as vendors have hiked prices in view of the Supreme Court guidelines and audit requirements. “We are ready to offer support, which comes at a cost. Since there is an emotional angle to it, vendors who typically charge ₹10-20 lakh for a regular KYC solution, are asking for ₹1 crore for special access solution," said the chief of a financial services firm, who did not wish to be named.

A common platform could help reduce costs. “There’s a strong need for ecosystem-level investment in developing assistive digital infrastructure that works across platforms," Ghosh said.