1. Introduction and Applicability

This Digital Accessibility Policy (“Policy”) is adopted by KredX Platform Private Limited (“Company”) to ensure that its Video-based Customer Identification Process (VCIP) is inclusive, accessible, and non-discriminatory for persons with disabilities and specially abled persons. The Policy is framed in accordance with the Department of Regulation (DoR) Circular dated 14 August 2025, the applicable directions issued by the Reserve Bank of India (RBI), the directions of the Hon’ble Supreme Court, and other applicable laws and guidelines relating to digital accessibility and customer protection.

The objective of this Policy is to provide reasonable accommodation, alternative methods, and human assistance to ensure that persons with disabilities are able to complete the VCIP and onboarding process with dignity, autonomy, and ease, without being excluded due to technological or procedural barriers.

Applicability

This Policy shall apply to:

• KredX Platform Private Limited and all its VCIP-enabled digital platforms, applications, and systems;
• All employees, officers, and authorised representatives of the Company involved in customer onboarding, KYC, and VCIP processes;
• All third-party service providers, technology partners, VCIP vendors, and agents engaged by the Company for conducting VCIP or allied services.

The Policy shall be applicable to all existing and new customers undergoing VCIP, including persons with visual, hearing, speech, motor, cognitive, or other disabilities, and shall be read in conjunction with the Company’s KYC Policy, Grievance Redressal Policy, and other applicable internal policies.

2. Purpose

This Policy applies to:

• KredX Platform Private Limited (“Company”), and
• All VCIP-related digital interfaces, systems, service providers, agents, and employees involved in customer onboarding and KYC processes.

The Policy covers accessibility measures for persons with visual, hearing, speech, motor, cognitive, and other disabilities.

3. Regulatory Framework

This Policy is framed with reference to:

• RBI Master Directions on Know Your Customer (KYC)
• DoR Circular dated 14 August 2025 on Digital Accessibility
• Directions of the Hon’ble Supreme Court on digital inclusion and accessibility
• Rights of Persons with Disabilities Act, 2016 (to the extent applicable)

4. Guiding Principles

The Company shall adhere to the following principles:

• Equal access to digital financial services
• Non-discrimination on the ground of disability
• Reasonable accommodation and assistive support
• Human intervention and review where required
• Transparency and ease of grievance redressal

5. Accessibility Measures in VCIP

5.1 Alternative Liveness Detection

The VCIP process shall not rely solely on eye-blinking for liveness detection. Alternative liveness checks shall be enabled, including but not limited to:

• Randomised real-time questions
• Verbal or written responses during VCIP
• Other system-supported liveness indicators

5.2 Support for Visually Impaired Users

For users with visual impairment:

• VCIP agents shall provide step-by-step verbal guidance
• Users may respond to questions by writing answers on paper and displaying them during VCIP
• Adequate time shall be provided to complete the process

5.3 Support for Hearing-Impaired Users

For users with hearing impairment:

• All instructions shall be displayed on the screen in written form
• Chat-based or text-based guidance shall be enabled during VCIP
• Agents shall avoid reliance on audio-only instructions

5.4 Support for Other Disabilities

For users with speech, motor, or cognitive disabilities:

• Flexible interaction methods shall be permitted
• Additional time and human assistance shall be provided
• VCIP re-attempts shall be allowed where required

6. Human Review and Fallback Mechanism

All VCIP rejections involving specially abled persons shall be subject to human review. A fallback mechanism through trained agents shall be provided to ensure that rejections are not solely system-driven and are assessed fairly.

7. Step-by-Step Assistance

The Company shall ensure continuous, step-by-step assistance throughout the VCIP and onboarding process. Trained personnel shall guide users at each stage to facilitate completion of the process without hardship.

8. Appointment of Nodal Officer

The Company shall designate:

• A Nodal Officer for Digital Accessibility, and
• An Escalation Officer

Details of such officers shall be disclosed appropriately. The Nodal Officer shall be responsible for monitoring accessibility compliance and addressing concerns raised by persons with disabilities.

9. Grievance Redressal Mechanism

A dedicated grievance redressal mechanism shall be available for reporting accessibility-related issues. Complaints from persons with disabilities shall be:

• Acknowledged promptly
• Resolved within stipulated timelines
• Escalated where necessary

10. Training and Awareness

The Company shall ensure periodic training of employees and VCIP agents on:

• Disability sensitivity
• Accessibility obligations
• Regulatory requirements

11. Review and Updates

This Policy shall be reviewed periodically and updated as necessary to align with regulatory changes, judicial directions, and best practices.

12. Approval and Effective Date

This Policy has been approved by the Board of Directors of KredX Platform Private Limited and shall be effective from the date of approval.