2024-08-20
Added · Updated
The Securities and Exchange Board of India (SEBI) issues the Cybersecurity and Cyber Resilience Framework (CSCRF) to supersede existing cybersecurity circulars and guidelines for all SEBI Regulated Entities (REs). The framework establishes a graded classification system for REs into five categories—Market Infrastructure Institutions, Qualified REs, Mid-size REs, Small-size REs, and Self-certification REs—based on operational thresholds. It mandates the implementation of specific cybersecurity standards, the establishment of Security Operation Centres (SOCs), and periodic cyber audits, with compliance deadlines set for January 1, 2025, for certain entities and April 1, 2025, for others.
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CIRCULAR
SEBI/HO/ ITD-1/ITD_CSC_EXT/P/CIR/2024/113 August 20, 2024
To,
All Alternative Investment Funds (AIFs)
All Bankers to an Issue (BTI) and SelfCertified Syndicate Banks (SCSBs) All Clearing Corporations All Collective Investment Schemes (CIS) All Credit Rating Agencies (CRAs) All Custodians All Debenture Trustees (DTs) All Depositories All Designated Depository Participants (DDPs) All Depository Participants through Depositories All Investment Advisors (IAs) / Research Analysts (RAs) All KYC Registration Agencies (KRAs) All Merchant Bankers (MBs) All Mutual Funds (MFs)/ Asset Management Companies (AMCs) All Portfolio Managers All Registrar to an Issue and Share Transfer Agents (RTAs) All Stock Brokers through Exchanges All Stock Exchanges All Venture Capital Funds (VCFs)
CSCRF
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Dear Sir / Madam,
Subject: Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI Regulated Entities (REs)
Background:
SEBI had issued Cybersecurity and Cyber resilience framework for Market Infrastructure Institutions (MIIs) in 2015. Subsequently, SEBI had issued other Cybersecurity and Cyber resilience frameworks in line with MIIs circular of 2015 for following REs:
1.1. Stock Brokers and Depository Participants
1.2. Mutual Funds (MFs)/ Asset Management Companies (AMCs)
1.3. KYC Registration Agencies (KRAs)
1.4. Qualified Registrar to an Issue and Share Transfer Agents (QRTAs)
1.5. Portfolio Managers
Further, SEBI has also issued various advisories to REs, from time to time, on Cybersecurity best practices.
In order to strengthen the cybersecurity measures in Indian securities market, and to ensure adequate cyber resiliency against cybersecurity incidents/ attacks, Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI REs has been formulated in consultation with the stakeholders. The CSCRF aims to provide standards and guidelines for strengthening cyber resilience and maintaining robust cybersecurity of SEBI REs. This framework shall supersede existing SEBI cybersecurity circulars/ guidelines/ advisories/ letters (list of such superseded circulars/ guidelines/ advisories/ letters are given as part of the framework attached as Annexure1).
Objective:
4. The key objective of CSCRF is to address evolving cyber threats, to align with the industry standards, to encourage efficient audits, and to ensure compliance by SEBI REs. The CSCRF also sets out standards formats for reporting by REs.
Approach:
5. The CSCRF is standards based and broadly covers the five cyber resiliency goals adopted from Cyber Crisis Management Plan (CCMP) of Indian Computer Emergency Response Team (CERT-In) for countering Cyber Attacks and Cyber Terrorism including:
5.1. Anticipate
5.2. Withstand
5.3. Contain
5.4. Recover
5.5. Evolve
These cyber resiliency goals have been linked with the following cybersecurity functions:
6.1. Governance
6.2. Identify
6.3. Protect
6.4. Detect
6.5. Respond
6.6. Recover
CSCRF follows a graded approach and classifies the REs in the following five categories based on their span of operations and certain thresholds like number of clients, trade volume, asset under management, etc.:
7.1. Market Infrastructure Institutions (MIIs)
7.2. Qualified REs
7.3. Mid-size REs
7.4. Small-size REs
7.5. Self-certification REs
The framework provides a structured methodology to implement various solutions for cybersecurity and cyber resiliency. In order to facilitate better understanding and ease of compliance, the document is divided into four parts:
8.1. Part I: Objectives and Standards – It contains definitions, framework compliance matrix, audit report timelines, objectives and standards.
8.2. Part II: Guidelines – It contains guidelines which provide recommendations or suggestions on how to achieve a particular outcome or meet certain objectives and implement respective standards. There are certain guidelines, which are mandatory in nature and have been specified accordingly.
8.3. Part III: Compliance Formats – It contains standard formats for the submission of CSCRF compliance reports.
8.4. Part IV: Annexures and References - It contains guidelines to auditors, scenario-based cyber resilience testing, Cyber Capability Index (CCI), functional efficacy of Security Operations Centre (SOC), etc.
CSCRF highlights the importance of governance and supply chain risk Management and at the same time, it focuses on evolving security guidelines such as data classification and localization, Application Programming Interface (API) security, Security Operations Centre (SOC) and measuring its efficacy, Software Bill of Materials (SBOM), etc.
CSCRF aims to ensure that even smaller REs are equipped with adequate cybersecurity measures and achieve resiliency against cybersecurity incidents/ attacks.
Cyber Capability Index (CCI) for MIIs and Qualified REs shall help these REs to monitor and assess their progress and cyber resilience on a periodic basis.
CSCRF mandates that all REs are required to establish appropriate security monitoring mechanisms through Security Operation Centre (SOC). The onboarding of SOC can be done through RE’s own/ group SOC or Market SOC or any other third-party managed SOC for continuous monitoring of security events and timely detection of anomalous activities.
As compliance with the cybersecurity guidelines may be onerous for smaller REs due to the lack of knowledge and expertise in cybersecurity and the cost factor involved in setting up own SOC. Therefore, CSCRF mandates NSE and BSE to set up Market SOC (M-SOC) with the objective of providing cybersecurity solutions to such categories of REs.
CSCRF contains provisions with respect to various areas such as requirements of IT services, Software as a Service (SaaS) solutions, hosted services, classification of data, audit for software solutions/ applications/ products used by REs, etc.
In order to simplify and streamline the reporting of compliance, structured formats for reports and submissions have been provided in the CSCRF.
Applicability:
16. The framework shall be applicable to the following REs:
16.1. Alternative Investment Funds (AIFs)
16.2. Bankers to an Issue (BTI) and Self-Certified Syndicate Banks (SCSBs)
16.3. Clearing Corporations
16.4. Collective Investment Schemes (CIS)
16.5. Credit Rating Agencies (CRAs)
16.6. Custodians
16.7. Debenture Trustees (DTs)
16.8. Depositories
16.9. Designated Depository Participants (DDPs)
16.10. Depository Participants through Depositories
16.11. Investment Advisors (IAs)/ Research Analysts (RAs)
16.12. KYC Registration Agencies (KRAs)
16.13. Merchant Bankers (MBs)
16.14. Mutual Funds (MFs)/ Asset Management Companies (AMCs)
16.15. Portfolio Managers
16.16. Registrar to an Issue and Share Transfer Agents (RTAs)
16.17. Stock Brokers through Exchanges
16.18. Stock Exchanges
16.19. Venture Capital Funds (VCFs)
Implementation Period:
17. Since new standards and controls have been added in CSCRF, a glidepath for adoption of CSCRF provisions has been provided as under:
17.1. For six categories of REs where cybersecurity and cyber resilience circular already exists – by January 01, 2025.
17.2. For other REs where CSCRF is being issued for the first time – by April 01, 2025.
REs shall put in place appropriate systems and procedures to ensure compliance with the provisions (i.e., applicable standards and guidelines) of CSCRF, and conduct cyber audit as per CSCRF after the above-mentioned timelines. Cyber audit reports along with other required documents shall be submitted as per timelines provided in the CSCRF.
The reporting of compliance with respect to CSCRF shall be done to the authority as per the existing mechanism of reporting for cybersecurity audit.
The detailed framework is enclosed at Annexure-1 of this circular.
This circular is being issued in exercise of powers conferred under Section 11 (1) of the Securities and Exchange of India Act, 1992, to protect the interests of investors in securities and to promote the development of, and to regulate the securities market.
The circular is issued with the approval of Competent Authority.
This circular is available on SEBI website at www.sebi.gov.in under the category “Legal” and drop “Circulars”.
Yours Faithfully,
Shweta Banerjee
Deputy General Manager
Phone: 022-26449509
Email: shwetas@sebi.gov.in
Annexure-1
Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI Regulated Entities (REs) Version 1.0 Date: August 20, 2024 Securities and Exchange Board of India Plot no. C4-A, G Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400051, India Tel.: +91-22-26449000/40459000 Website: www.sebi.gov.in
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Executive Summary
The Information Technology Act, 2000 defines Cybersecurity as “Protecting information, equipment, devices, computer, computer resource, communication device and information stored therein from unauthorised access, use, disclosure, disruption, modification or destruction”.
Technology has been a driving force in shaping the securities market, enabling greater efficiency, accessibility, and affordability. However, with swift technological advancements, protection of IT infrastructure and data has become a key concern for SEBI and its Regulated Entities (REs). Since 2015, SEBI has issued various cybersecurity and cyber resilience frameworks to address cybersecurity risks and enhance cyber resilience of SEBI REs. Further, SEBI has also issued several advisories on cybersecurity best practices for REs from time to time.
In order to enhance the scope of the current cybersecurity and cyber resilience framework, to ensure the need for uniformity of cybersecurity guidelines for all REs and to strengthen the mechanism to deal with cyber risks, threats, incidents, etc., the Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI REs has been formulated. CSCRF is a result of coordinated efforts after an extensive consultations and discussions with the stakeholders including Market Infrastructure Institutions (MIIs), REs, industry associations, government organizations (for example Indian Computer Emergency Response Team - CERT-In, National Critical Information Infrastructure Protection Centre, etc.), Industry Standard Forum (ISF), information security auditors, industry experts, Cloud Service Providers (CSPs), etc., and has also been reviewed by SEBI’s High Powered Steering Committee on Cybersecurity (HPSCCS).
The framework provides a standardized approach to implement various cybersecurity and cyber resilience methodologies. Standards such as ISO 27000 series, CIS v8, NIST 800-53, BIS Financial Stability Institute, CPMI-IOSCO guidelines, etc. were referred to while formulating this framework.
The framework follows a graded approach and classifies the REs in the following five categories based on their span of operations and certain thresholds 1 like number of clients, trade volume, asset under management, etc.:
i. Market Infrastructure Institutions (MIIs)
ii. Qualified REs
iii. Mid-size REs
iv. Small-size REs
v. Self-certification REs
1 Refer ‘Thresholds for REs’ categorization’ section
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The framework is divided into four parts:
i. Part I: Objectives and Standards: The objectives highlight goals which a security
control needs to achieve. The standards represent established principles for compliance with CSCRF.
ii. Part II: Guidelines: The guidelines recommend measures for complying with
standards mentioned in this document. However, few of the guidelines are mandatory in nature and shall be complied by REs as applicable.
iii. Part III: Structured formats for compliance
iv. Part IV: Annexures and References
For ease of compliance, REs are required to comply with the all applicable standards and mandatory guidelines as mentioned in CSCRF. The Structure of CSCRF The framework is broadly based on two approaches: cybersecurity and cyber resilience. Cybersecurity approach covers various aspects from governance measures to operational controls and the cyber resilience goals include Anticipate, Withstand, Contain, Recover, and Evolve. The framework also specifies guidelines to ensure standards are implemented in a uniform manner. The summary of the CSCRF is as follows:
i. Cyber Resilience Goal: Anticipate | Cybersecurity function: Governance
a. REs shall establish, communicate and enforce cybersecurity risk management roles, responsibilities, and authorities to foster accountability and continuous improvement. b. A comprehensive cybersecurity and cyber resilience policy shall be documented and implemented with the approval of the Board/ Partners/ Proprietor.
c. CSCRF mandates MIIs, Qualified REs, and mid-size REs to prepare cyber risk
management framework for identification and analysis, evaluation, prioritization, response and monitoring the cyber risks on a continuous basis. d. Cyber Capability Index (CCI): This shall be applicable only to MIIs and Qualified REs. MIIs shall conduct third-party assessment of their cyber resilience using CCI on a half-yearly basis. Qualified REs shall do self-assessment of their cyber resilience using CCI on a yearly basis. e. REs shall be solely accountable for all aspects related to third-party services including (but not limited to) confidentiality, integrity, availability, nonrepudiation, security of their data and logs, and ensuring compliance with laws, regulations, circulars, etc. issued by SEBI/ Government of India. Accordingly, REs shall be responsible and accountable for any violations of the same.
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ii. Cyber Resilience Goal: Anticipate | Cybersecurity function: Identify
a. REs shall identify and classify critical systems based on their sensitivity and criticality for business operations, services and data management. The Board/ Partners/ Proprietor of the RE shall approve the list of critical systems. b. Risk assessment (including post-quantum risks 2 ) of RE’s IT environment shall be done on a periodic basis. Risk assessment shall include comprehensive scenario-based testing for assessing risks (including both internal and external risks) related to cybersecurity in REs’ IT environment.
c. Threats, vulnerabilities, likelihoods, and impacts shall be used to understand
inherent risks and undertake risk response prioritization.
iii. Cyber Resilience Goal: Anticipate | Cybersecurity function: Protect
a. Authentication and access policy along with effective log collection 3 and retention policy shall be documented and implemented. b. REs shall design and implement network segmentation techniques to restrict access to the sensitive information, hosts, and services.
c. Layering of Full-disk Encryption (FDE) along with File-based Encryption (FE)
shall be used for data protection. d. There shall be separate production and non-production environments for the development of all software/ applications for critical systems and further feature enhancements. e. Periodic audits shall be conducted by a CERT-In empanelled IS auditing organization to audit the implementation and provide compliance with the applicable standards and mandatory guidelines mentioned in the CSCRF. f. Vulnerability Assessment and Penetration Testing (VAPT) shall be done to detect vulnerabilities in the IT environment for all critical systems, infrastructure components and other IT systems as defined in the framework. To undertake this activity, a comprehensive VAPT scope has also been specified. g. Application Programming Interface (API) security and Endpoint security solutions shall be implemented with rate limiting, throttling, and proper authentication and authorisation mechanisms. h. ISO 27001 certification: ISO 27001 certification shall be mandatory for MIIs and Qualified REs as it provides essential security standards with respect to Information Security Management System (ISMS).
2 Quantum computing is a rapidly emerging technology that exploits quantum mechanics’ laws to solve complex problems. Post-quantum cryptography solutions can avert post-quantum risks and provide protection against quantum attacks. 3 With all relevant fields including verbosity and relevancy.
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iv. Cyber Resilience Goal: Anticipate | Cybersecurity function: Detect
a. REs shall establish appropriate security mechanisms through Security Operations Centre (SOC) [RE’s own/ group SOC, third-party SOC, or market SOC] for continuous monitoring of security events and timely detection of anomalous activities. b. Bombay Stock Exchange (BSE) and National Stock Exchange (NSE) have been mandated to setup Market SOC. Further, small-size REs and Selfcertification REs have been mandated to be onboarded on the Market SOC.
c. MIIs and Qualified REs shall measure functional efficacy of their SOC on a halfyearly basis. Rest of the REs shall obtain functional efficacy of the SOC utilized
by them on a yearly basis from the SOC service providers. A quantifiable method and an indicative list of parameters for measuring SOC efficacy has been given in this framework. The report of functional efficacy of Market SOC shall be provided by BSE and NSE to SEBI on a periodic basis. d. Red Teaming: MIIs and Qualified REs shall conduct red teaming exercises as
part of their cybersecurity framework.
v. Cyber Resilience Goal: Withstand & Contain | Cybersecurity function:
Respond a. All cybersecurity incidents shall be reported in a timely manner through the SEBI incident reporting portal. b. All REs shall establish a comprehensive Incident Response Management plan and the corresponding SOPs.
c. All REs shall formulate an up-to-date Cyber Crisis Management Plan (CCMP).
d. In the event of an incident, Root Cause Analysis (RCA) shall be conducted to identify the cause(s) leading to the incident. e. Where RCA is inconclusive, a forensic analysis shall be undertaken for detailed investigation of the cybersecurity incident.
vi. Cyber Resilience Goal: Recover | Cybersecurity function: Recover
a. A comprehensive response and recovery plan shall be documented. The plan shall be triggered to ensure prompt restoration of systems affected by the cybersecurity incident. An indicative recovery plan has been provided in the CSCRF. b. Actions taken during recovery process shall be informed to all the relevant stakeholders as required.
vii. Cyber Resilience Goal: Evolve
Adaptive and evolving controls to tackle identified vulnerabilities and to reduce attack surfaces shall be created and incorporated into the RE’s cybersecurity and cyber resilience strategy.
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viii. Compliance requirements
The compliance reporting for CSCRF shall be done by the REs to their respective authorities 4 in the standardized formats mentioned in this framework as per the stated periodicity. A glide-path has been given to REs to comply with the CSCRF standards and mandatory guidelines. Since new standards and controls have been added in CSCRF, a glide-path for adoption of CSCRF provisions has been provided as under:
a. For six categories of REs where cybersecurity and cyber resilience circular already exists – by January 01, 2025. b. For other REs where CSCRF is being issued for the first time – by April 01, 2025. Further, to ensure the uniformity in auditing REs w.r.t. CSCRF, an auditors’ checklist and guidelines has been included in this framework. Future proofing of CSCRF It is envisaged that quantum computing may be a reality in near future and it may be able to break the encryption schemes widely used today. Thus, quantum computing may evolve into one of the biggest cybersecurity threats and it may potentially expose financial systems to cyber-attacks. While it is still uncertain when quantum technology would be adopted on a large scale, its potential as a cyber threat to the securities market ecosystem is already a matter of concern. The CSCRF has provisions to address ‘harvest now - decrypt later’ attacks through continuous risk assessment and adoption of robust data protection measures. The framework will continue to be updated based on the maturity of the technologies and their adoption by the REs to meet the future cybersecurity needs of securities market. --o--
4 Refer ‘CSCRF Compliance, Audit Report Submission, and Timelines’ section.
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Table of Contents
Abbreviations ......................................................................................................................................20
Definitions............................................................................................................................................26
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5. Cyber Resilience Goal: WITHSTAND & CONTAIN | Cybersecurity function:
RESPOND.......................................................................................................................................71
5.1. RS.MA: Incident Management ..................................................................................71
5.2. RS.CO: Incident Response Reporting and Communication.............................72
5.3. RS.AN: Incident Analysis...........................................................................................73
5.4. RS.IM: Improvements..................................................................................................73
6. Cyber Resilience Goal: RECOVER | Cybersecurity function: RECOVER .............74
6.1. RC.RP: Incident Recovery Plan Execution............................................................74
6.2. RC.CO: Incident Recovery Communication..........................................................74
6.3. RC.IM: Improvements..................................................................................................75
7. Cyber Resilience Goal: EVOLVE......................................................................................76
7.1. EV.ST: Strategies .........................................................................................................76
8. Exemption Table...................................................................................................................77
Part II: CSCRF Guidelines..............................................................................................................79
Part III: Structured Formats for CSCRF Compliance............................................................133
Annexure-A: VAPT Report Format ........................................................................................133
Annexure-B: Cyber Audit Report Format ............................................................................142
Annexure-C: Recovery Plan Template (Reference Guide)..............................................150
Part IV: CSCRF Annexures and References ...........................................................................152
Annexure-D: Audit Guidelines................................................................................................152
Annexure-E: Scenario-based Cyber Resilience Testing .................................................155
Annexure-F: Guidelines on Outsourcing of Activities.....................................................158
Annexure-G: Application Authentication Security............................................................159
Annexure-H: Data Security on Customer Facing Applications .....................................160
Annexure-I: Data Transport Security....................................................................................161
Annexure-J: Framework for Adoption of Cloud Services ...............................................162
Annexure-K: Cyber Capability Index (CCI)..........................................................................163
Annexure-L: VAPT Scope ........................................................................................................188
Annexure-M: Cyber-SOC Framework for MIIs....................................................................189
Annexure-N: Functional Efficacy of SOC ............................................................................190
Annexure-O: Classification and Handling of Cybersecurity Incidents........................198
Annexure-P: Reporting Format for Self-certification REs...............................................205
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Abbreviations
SN. Abbreviation Explanation/ Expansion
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25. COTS Commercial Off The Shelf
26. CSCRF Cybersecurity and Cyber Resilience Framework
27. CSIRT-Fin Computer Security Incident Response Team – Finance
sector
28. CSK Cyber Swachhta Kendra
29. CSP Cloud Service Provider
30. CTCL Computer to Computer Link
31. CTI Cyber Threat Intelligence
32. CTO Chief Technology Officer
33. CVE Common Vulnerabilities and Exposures
34. CWE Common Weakness Enumeration
35. DB Database
36. DC Domain Controller
37. DDoS Distributed Denial-of-Service
38. DEV Development
39. DKIM Domain Keys Identified Mail
40. DLP Data Loss Prevention
41. DMARC Domain-based Message Authentication Reporting &
Conformance
42. DNS Domain Name System
43. DR Disaster Recovery
44. EDR Endpoint Detection and Response
45. EPP Endpoint Protection Platforms
46. EPSS Exploit Prediction Scoring System
47. FDE Full-disk Encryption
48. FPO Follow-on Public Offer
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49. FSB Financial Stability Board
50. HPSC-CS High Powered Steering Committee on Cyber Security
51. GoI Government of India
52. IaaS Infrastructure as a Service
53. IBT Internet Based Trading
54. IDS Intrusion Detection System
55. IOAs Indicators of Attack
56. IOCs Indicators of Compromise
57. IOSCO International Organization of Securities Commissions
58. IP Internet Protocol
59. IPO Initial Public Offer
60. IPS Intrusion Prevention System
61. IS Information Security
62. ISACA Information Systems Audit and Control Association
63. ISMS Information Security Management System
64. ISO International Organization for Standardization
65. IT Information Technology
66. KRA KYC (Know Your Client) Registration Agency
67. MASVS Mobile Application Security Verification Standard
68. MD Managing Director
69. MeitY Ministry of Electronic and Information Technology
70. MFA Multi-Factor Authentication
71. MII Market Infrastructure Institution
72. MTTC Mean Time to Contain
73. MTTD Mean Time to Detect
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74. MTTR Mean Time to Respond
75. NCIIPC National Critical Information Infrastructure Protection
Centre
76. NDR Near Disaster Recovery
77. NEAT National Exchange for Automated Trading
78. NIST National Institute of Standards and Technology
79. NSE National Stock Exchange
80. OS Operating System
81. OT Operational Technology
82. OTP One Time Password
83. OWASP Open Web Application Security Project
84. PaaS Platform as a Service
85. PDC Primary Data Centre
86. PII Personal Identifiable Information
87. PIM Privileged Identity Management
88. POLP Principle of Least Privilege
89. PQC Post Quantum Cryptography
90. QA Quality Assurance
91. QKD Quantum Key Distribution
92. QRTA Qualified Registrar to an Issue and Share Transfer Agent
93. RAT Remote Access Trojan
94. RBA Risk Based Authentication
95. RBI Reserve Bank of India
96. RCA Root Cause Analysis
97. RDP Remote Desktop Protocol
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98. RE Regulated Entity 5
99. RPO Recovery Point Objective
100. RTO Recovery Time Objective
101. SaaS Software as a Service
102. SANS SysAdmin, Audit, Network and Security
103. SBOM Software Bill of Materials
104. SCOT Standing Committee on Technology
105. SIEM Security Information and Event Management
106. SIT System Integration Test
107. SLA Service Level Agreement
108. SMB Server Message Block
109. SME Small and Medium Enterprises
110. SOAR Security Orchestration, Automation, and Response
111. SOC Security Operations Centre
112. SOP Standard Operating Procedure
113. SPF Sender Policy Framework
114. SSDLC Secure Software Development Life Cycle
115. SSVC Stakeholder-Specific Vulnerability Categorization
116. STQC Standardisation Testing and Quality Certification
117. TLP Traffic Light Protocol
118. UAT User Acceptance Test
119. UCC Unique Client Code
120. UEBA User Entity and Behavior Analytics
121. URL Uniform Resource Locator
5 Entities within SEBI’s purview, refer to Securities Contracts (Regulation) Act 1956, SEBI Act 1992, and Depositories Act 1996.
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122. VAPT Vulnerability Assessment & Penetration Testing
123. VBA Visual Basic for Application
124. VPN Virtual Private Network
125. WAF Web Application Firewall
126. XDR Extended Detection and Response
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Definitions
6 https://www.fsb.org/wp-content/uploads/P130423-3.pdf 7 https://www.fsb.org/wp-content/uploads/P130423-3.pdf 8 https://www.fsb.org/wp-content/uploads/P130423-3.pdf
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6. Cyber Threat –
A circumstance with the potential to exploit one or more vulnerabilities that adversely affects cybersecurity. – FSB Cyber Lexicon 9
7. Cybersecurity Incident (Incident)–
Any real or suspected adverse event in relation to cybersecurity that violates an explicitly or implicitly applicable security policy resulting in unauthorised access, denial of service or disruption, unauthorised use of a computer resource for processing or storage of information or changes in data, information without authorisation. – CERT-In Cybersecurity directions 10
8. Hosted Service -
Any IT/ SaaS provider rendering IT services/ SaaS solutions hosted on IT infrastructure either owned or controlled and managed by the service provider shall be broadly construed as hosted services. Hosted services have to fulfil the following technical specifications:
9 https://www.fsb.org/wp-content/uploads/P130423-3.pdf 10 Refer Q 3. In CERT-In Cybersecurity directions: https://www.certin.org.in/PDF/FAQs_on_CyberSecurityDirections_May2022.pdf
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9. ISO 27001 certification 11 –
ISO 27001 certification is a globally recognized standard for Information Security Management Systems (ISMS) published by the International Organization for Standardization (ISO). It helps organizations become risk-aware, proactively identify, and address weaknesses and promote a holistic approach to information security. 10.IT and Cybersecurity Data IT and Cybersecurity Data includes the following data (but not limited to):
a. Logs and metadata related to IT systems and their operations. However, such data should not contain the following:
i. Any Regulatory Data, and
ii. Sensitive data such as internal network architecture, vulnerability details,
details of admin/ privileged users of REs, password hashes, system configuration, etc. b. Further, it should not be ordinarily possible to generate Regulatory Data from IT and Cybersecurity Data. 11.Major Change/ Major Release CSCRF has mandated VAPT after every major release. The following changes (including but not limited to) are broadly considered as major release(s) or major change(s):
a. Implementation of a new SEBI circular. b. Changes in core versions of software (e.g., .net, SQL, Oracle, Java, etc.)
c. Any changes in policy of login and/ or password management.
d. Significant system modifications that alter how data is exchanged with stock exchanges (e.g., file format changes, message protocol changes, etc.). e. Introduction of new security protocols (e.g., switching from SSL to TLS 1.3). f. Expansion into new financial markets (e.g., adding currency trading). g. Implementation of new processes/ schema changes. 12.Market Infrastructure Institutions (MIIs) – Stock Exchanges, Depositories and Clearing Corporations or any other institutions as specified by SEBI are collectively referred to as Market Infrastructure Institutions (MIIs). For applicability and inclusion of REs as MIIs, refer to section 2 (“Thresholds for REs’ categorization”) of CSCRF. Box Item 1: REs under MIIs category for compliance with CSCRF
11 https://www.iso.org/standard/27001
In the context of CSCRF, following REs are constituted as MIIs:
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13.Principle of Least Privilege (PoLP) –
Principle of Least Privilege (PoLP) is an information security concept which maintains that a user or entity shall only have access to the specific data, resources and applications needed to complete its required task. 14.Red team exercise – An exercise, reflecting real-world conditions that is conducted as a simulated adversarial attempt to compromise organizational missions or business processes and to provide a comprehensive assessment of the security capabilities of an organization and its systems. 15.Regulated Entity (RE) 12 - The term ‘Regulated Entity’ refers to SEBI registered/ recognised intermediaries (for example stock brokers, mutual funds, KYC Registration Agencies, QRTAs, etc.) and Market Infrastructure Institutions (Stock Exchanges, Depositories and Clearing Corporations) regulated by SEBI. 16.Regulatory Data – Regulatory Data includes the following (but not limited to):
a. Data related to core and critical activities of the RE, as well as any supporting/ ancillary data impacting core and critical activities. b. Data w.r.t to communication between investors and REs through applications (e.g., Chat communication, messages, emails etc.).
c. Data that is required by the laws/ regulations/ circulars, etc. issued by SEBI
and Govt. of India from time to time. d. Data that is deemed necessary or sensitive by the RE/ SEBI/ central or state government. e. The Regulatory Data shall be stored in an easily accessible, legible and usable form, within the legal boundaries of India. However, for the investors whose country of incorporation is outside India, the REs shall keep the data, available and easily accessible in legible and usable form, within the legal boundaries of India. Further, if the copy retained within India is not in readable format, the REs must maintain an application/system to read/ analyse the saved data.
17. Risk –
As defined by OWASP 13, Risk = Likelihood × Impact; where Likelihood = Threat × Vulnerabilities. Likelihood is a measure of how likely a vulnerability is to be discovered and exploited by an attacker. Impact is the magnitude of harm that can be expected as a result from the consequences of threat exploitation.
12 Entities within SEBI’s purview, refer to Securities Contracts (Regulation) Act 1956, SEBI Act 1992, and Depositories Act 1996. 13 Refer Risk-rating methodology: https://owasp.org/www-community/OWASP_Risk_Rating_Methodology
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18.Risk-based Authentication (RBA) –
Risk-based authentication is a non-static authentication mechanism that takes into account the profile of the agent requesting access to the system to determine the risk profile associated with that transaction. It checks and applies varying levels of stringency to authentication processes based on the likelihood that access to a given system could result in it being compromised. 19.Root Cause Analysis (RCA) – A principle-based, systems approach for the identification of underlying causes associated with a particular set of risks. 20.Secure Software Development Life Cycle (SSDLC) – Secure Software Development Life Cycle (SSDLC) involves integrating security testing at every stage of software development, from design, to development, to deployment and beyond. 21.Software Bill of Materials (SBOM) – A formal record containing the details and supply chain relationships of various components used in building software. Software developers and vendors often create products by assembling existing open source and commercial software components. The SBOM enumerates these components in a product.
22. Trusted Channels –
A protected communication link established between the cryptographic module and a sender or receiver (including another cryptographic module) to securely communicate and verify the validity of plaintext CSPs, keys, authentication data, and other sensitive data. It is also called a secure channel.
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CSCRF
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Figure 1: CSCRF Overview
CSCRF
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The cyber resiliency goals cover different cybersecurity functions. These functions are to be implemented by REs through various cybersecurity controls. The controls are divided into the following three categories:
i. Objectives: The objectives highlight goals, which a security control needs to
achieve.
ii. Standards: The standards represent established principles for compliance
with CSCRF.
iii. Guidelines: The guidelines recommend measures for complying with
standards mentioned in this document. However, few of the guidelines are mandatory in nature and shall be complied by REs as applicable. Accordingly, the CSCRF document is divided into four parts:
i. Part I: Objectives and Standards
ii. Part II: Guidelines
iii. Part III: Compliance Formats
iv. Part IV: Annexures and References
For ease of compliance, REs are required to comply with the standards and mandatory guidelines as mentioned in the CSCRF. Since new standards and controls have been added in CSCRF, a glide-path for adoption of CSCRF provisions has been provided as under:
i. For six categories of REs where cybersecurity and cyber resilience
circular already exists – by January 01, 2025.
ii. For other REs where CSCRF is being issued for the first time – by April
01, 2025.
Accordingly, the following SEBI circulars/ guidelines/ letters/ advisories shall be deprecated as per the above-mentioned timelines.
Table 1: List of SEBI cybersecurity circulars to get supersede with CSCRF
S.
No.
Regulated Entity Circular Subject (Circular Number) Date of issuance
CSCRF
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S.
No.
Regulated Entity Circular Subject (Circular Number) Date of issuance Modification in Cyber Security and Cyber Resilience framework for Stock Exchanges, Clearing Corporations and Depositories (SEBI/HO/MRD/TPD/P/CIR/2023/147) August 24, 2023 Guidelines for MIIs regarding Cyber Security and Cyber Resilience (SEBI/HO/MRD/TPD/P/CIR/2023/146) August 29, 2023
2. Stock Brokers /
Depository
Participants
Cyber Security & Cyber Resilience framework for Stock Brokers / Depository Participants (SEBI/HO/MIRSD/CIR/PB/2018/147) December 03, 2018 Clarification to Cyber Security & Cyber Resilience framework for Stock Brokers / Depository Participants (CIR/HO/MIRSD/DOS2/CIR/PB/2019/03 8) March 15, 2019 Cyber Security & Cyber Resilience framework for Stock Brokers / Depository Participants – Clarifications (SEBI/HO/MIRSD/DOP/CIR/P/2019/109 ) October 15, 2019 Modification in Cyber Security and Cyber resilience framework for Stock Brokers / Depository Participants (SEBI/HO/MIRSD/TPD/P/CIR/2022/80) June 07, 2022 Modification in Cyber Security and Cyber resilience framework for Stock Brokers / Depository Participants (SEBI/HO/MIRSD/TPD/P/CIR/2022/93) June 30, 2022
3. Mutual Funds /
Asset
Management
Companies
(AMCs)
Cyber Security and Cyber Resilience framework for Mutual Funds / Asset Management Companies (AMCs) (SEBI/HO/IMD/DF2/CIR/P/2019/12) January 10, 2019 Modification in Cyber Security and Cyber Resilience Framework of Mutual Funds/ Asset Management Companies (AMCs) (SEBI/HO/IMD/IMDI/DOF2/P/CIR/2022/81) June 09, 2022
4. KYC Registration
Agencies (KRAs)
Cyber Security &Cyber Resilience framework for KYC Registration Agencies (SEBI/HO/MIRSD/DOP/CIR/P/2019/111 ) October 15, 2019
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S.
No.
Regulated Entity Circular Subject (Circular Number) Date of issuance Modification in Cyber Security and Cyber resilience framework of KYC Registration Agencies(KRAs) (SEBI/HO/MIRSD/DoP/P/CIR/2022/74) May 30, 2022 Modification in Cyber Security and Cyber resilience framework of KYC Registration Agencies (KRAs) (SEBI/HO/MIRSD/TPD/P/CIR/2022/95) July 05, 2022
5. Qualified
Registrars to an
Issue / Share
Transfer Agents
(QRTAs)
Cyber Security and Cyber Resilience framework for Registrars to an Issue/ Share Transfer Agents (hereinafter referred to as RTAs) (SEBI/HO/MIRSD/CIR/P/2017/100) September 08, 2017 Cyber Security & Cyber Resilience framework for Qualified Registrars to an Issue / Share Transfer Agents (SEBI/HO/MIRSD/DOP/CIR/P/2019/110 ) October 15, 2019 Modification in Cyber Security and Cyber resilience framework of Qualified Registrars to an Issue and Share Transfer Agents(“QRTAs”) (SEBI/HO/MIRSD/MIRSD_RTAMB/P/CI R/2022/73) May 27, 2022 Modification in Cyber Security and Cyber resilience framework of Qualified Registrars to an Issue and Share Transfer Agents (“QRTAs”) (SEBI/HO/MIRSD/TPD/P/CIR/2022/96) July 06, 2022 6 Portfolio Managers Cyber Security and Cyber Resilience framework for Portfolio Managers (SEBI/HO/IMD/IMD-PoD1/P/CIR/2023/046) March 29, 2023 7 All Regulated Entities Advisory for SEBI Regulated Entities (REs) regarding Cybersecurity best practices (SEBI/HO/ITD/ITD_VAPT/P/CIR/2023/0 32) February 22, 2023 8 Stock Exchanges, Clearing Corporations and Depositories (except Commodities Cyber Security Operations Center for SEBI registered intermediaries (CIR/MRD/CSC/151/2018) December 14, 2018
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S.
No.
Regulated Entity Circular Subject (Circular Number) Date of issuance Derivatives Exchanges and their Clearing Corporations)
Table 2: List of SEBI cybersecurity letters/ advisories to get supersede with
CSCRF
S.
No.
Entity to which letter is issued
Letter Subject (Letter Number) Date of issuance
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S.
No.
Entity to which letter is issued
Letter Subject (Letter Number) Date of issuance
10. NSE Clearing Limited
(Formerly known as
National Securities
Clearing Corporation
Ltd.)
Submission of Cyber Audit Report
(SEBI/HO/ITD/ITD_INSADT_D/P/
OW/2022/0000063951/1)
December
26, 2022
11. National Securities
Depositories Ltd.
Submission of Cyber Audit Report
(SEBI/HO/ITD/ITD_INSADT_D/P/
OW/2022/0000063954/1)
December
26, 2022
12. MIIs Recommendations of High
Powered Steering Committee –
Cyber Security in meeting dated
February 21, 2019
(SEBI/HO/MRD/CSC/OW/P/2019
/10055/5)
April 22,
2019
13. Association of Mutual
Funds in India (AMFI)
Review of Cyber Security and
Cyber Resilience framework for
Mutual Funds/Asset Management
Companies (AMCs)
(SEBI/HO/IMD/IMD-TPD1/P/OW/2023/16538)
All letters with subject ‘Review of
Cyber Security and Cyber
Resilience framework for Mutual
Funds/Asset Management
Companies (AMCs)’ dated April
19, 2023 issued to Mutual
Funds/AMCs or Trustee Services shall be superseded with CSCRF.
April 19,
2023
14. Association of Mutual
Funds in India (AMFI)
Review of Cyber Security and
Cyber Resilience framework for
Mutual Funds/Asset Management
Companies (AMCs)
(SEBI/HO/IMD/IMD-SEC3/P/OW/2023/22970/1)
June 06,
2023
15. National Stock
Exchange of India Ltd.
Implementation of Cyber
Capability Index
(SEBI/HO/MRD/CSC/OW/P/2019
/28528/1)
October
30, 2019
16. Bombay Stock
Exchange of India
Implementation of Cyber
Capability Index
(SEBI/HO/MRD/CSC/OW/P/2019
/28516/1)
October
30, 2019
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S.
No.
Entity to which letter is issued
Letter Subject (Letter Number) Date of issuance
17. Central Depository
Services Ltd.
Implementation of Cyber
Capability Index
(SEBI/HO/MRD/CSC/OW/P/2019
/28517/1)
October
30, 2019
18. Indian Clearing
Corporation Ltd.
Implementation of Cyber
Capability Index
(SEBI/HO/MRD/CSC/OW/P/2019
/28523/1)
October
30, 2019
19. Metropolitan Stock
Exchange of India Ltd.
Implementation of Cyber
Capability Index
(SEBI/HO/MRD/CSC/OW/P/2019
/28525/1)
October
30, 2019
20. Metropolitan Clearing
Corporation of India Ltd.
Implementation of Cyber
Capability Index
(SEBI/HO/MRD/CSC/OW/P/2019
/28524/1)
October
30, 2019
21. NSE Clearing Limited Implementation of Cyber
Capability Index
(SEBI/HO/MRD/CSC/OW/P/2019
/28526/1)
October
30, 2019
22. National Securities
Depositories Ltd.
Implementation of Cyber
Capability Index
(SEBI/HO/MRD/CSC/OW/P/2019
/28527/1)
October
30, 2019
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2. Thresholds for REs’ categorization:
The applicability of various standards and guidelines of CSCRF is based on different categories of REs. CSCRF follows a graded approach and classifies REs in the following five broad categories:
i. Market Infrastructure Institutions (MIIs)
ii. Qualified REs
iii. Mid-size REs
iv. Small-size REs
v. Self-certification REs
The category of REs shall be decided at the beginning of the financial year based on the data of the previous financial year. Once the category of RE is decided, RE shall remain in the same category throughout the financial year irrespective of any changes in the parameters during the financial year. The category shall be validated by the respective reporting authority at the time of compliance submission. Further, the criteria given and their thresholds for different categories will continue to be updated as and when required. Entity-wise categorization and corresponding thresholds shall be as follows:
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S.
No
.
Criteria Selfcertification
REs
Small-size REs Mid-size
REs
Qualified
REs 14
1 Active
Clientbase as per UCC
Less than or equal to 10 ,000 active clients and not providing IBT or Algo trading facility More than. 10,000 and up to 50,000 More than 50,000 and up to 5,00,000 More than 5,00,000 Less than or equal to 10,000 active clients and providing IBT facility /Algo trading facility
4. Collective Investment Scheme (CIS)
CIS shall be under Self-certification REs category.
5. Credit Rating Agency (CRA)
CRAs shall be under Self-certification REs category.
6. Custodians
Table 5: Criteria and thresholds for Custodians categorization
S.
No.
Criteria Small-size REs Mid-size REs Qualified REs 1 AUC Less than Rs. 1 Lakh crores Rs. 1 Lakh crores and above but less than Rs. 10 Lakh crores Rs. 10 Lakh crores and above
7. Debenture Trustee (DT)
DTs which have not added any new issuer of listed debt security as client in the last three financial years shall be excluded from submission of compliance with CSCRF. Remaining DTs shall be under the Self-certification REs category.
8. Depository Participants (DPs)
Table 6: Criteria and thresholds for DPs categorization
S. No. Criteria Small-size REs Mid-size REs Qualified REs 1 Type of DP N.A. Non-institutional DP Institutional DP
9. Designated Depository Participants (DDPs)
To get approval as a DDP, an entity, inter alia, is required to have valid SEBI registration as a Depository Participant (DP) as well as a Custodian. Therefore,
14 As per SEBI circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2023/24 dated February 06, 2023, enhanced obligations and responsibilities have been casted upon Qualified Stock Brokers (QSBs) defined based on their size of operations, trading volumes, amount of client funds handled by them etc. Hence, such QSBs shall be categorized as Qualified REs.
CSCRF
Version 1.0 categorization of highest category among DPs and Custodians shall be applicable to DDPs for submission of compliance with CSCRF. 10.Foreign Portfolio Investors (FPIs) FPIs shall be excluded from submission of compliance with CSCRF. 11.Foreign Venture Capital Investors (FVCI) FVCI shall be excluded from submission of compliance with CSCRF. 12.Investment Advisors (IAs)/ Research Analysts (RAs) a. Investment Advisors (IAs)
Table 7: Criteria and thresholds for IAs categorization
Individual IAs Non-individual IAs
Individual IAs shall be excluded from submission of compliance with CSCRF. Non-individual IAs shall be categorized as Small-size REs. b. Research Analysts (RAs)
Table 8: Criteria and thresholds for RAs categorization
All RAs who are not registered in other category of REs Institutional RAs who are registered in other category of REs All RAs who are not registered in other categories of REs shall be excluded from submission of compliance with CSCRF. However, SEBI SaaS circular titled “Advisory for Financial Sector Organizations regarding Software as a Service (SaaS) based solutions” dated November 03, 2020 is applicable to RAs under which a declaration shall be submitted in respect of SaaS for managing their governance, risk compliance functions, and to improve their cybersecurity posture. Institutional RAs who are registered with SEBI in other category of REs shall be classified as Qualified REs/ Mid-size REs/ Small size REs based on their categorization in their respective other REs/ group entity category. 13.KYC Registration Agencies (KRAs) KRAs shall be treated at par with MIIs category for the applicability of the CSCRF. 14.Limited Purpose Clearing Corporation (LPCC) LPCC shall be excluded from submission of compliance with CSCRF.
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15.Merchant Bankers (MBs)
Table 9: Criteria and thresholds for MBs categorization
S.
No.
Merchant Banker Category for CSCRF
1 An entity or its parent/ subsidiary/ associate company which is a part of a conglomerate/ Systemically Important Financial Institutions Qualified REs 2 MBs which are engaged in any activity pertaining to issue management inter alia Public Issues (IPOs, FPOs, IPOs by SME), Public Offers by REITs/InvITs, Buy-Back of Securities, Delisting of Equity Shares, Open Offer under SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011 Mid-size REs 3 All other MBs which are not covered in clause 1 & 2 of this table above. Small-size REs a. Wherever the MB is a listed entity, the compliance requirement shall also be intimated to Stock Exchanges. 16.Mutual Funds (MFs)/ Asset Management Companies (AMCs)
Table 10: Criteria and thresholds for MFs/ AMCs categorization
S.
No.
Criteria Small-size REs Mid-size REs Qualified REs 1 AUM Less than Rs. 10,000 crores Rs. 10,000 crores and above but less than Rs. 1 lakh crore Rs. 1 lakh crores and above 17.Portfolio Managers
Table 11: Criteria and thresholds for Portfolio Managers categorization
S.
No.
Criteria Selfcertification
REs
Small-size REs Mid-size REs Qualified
REs
1 AUM Less than Rs.
1000 crores
Rs. 1000 crores and above but less than Rs. 3000 crores Rs. 3000 crores and above N.A. 18.Qualified Depository Participants (QDPs) QDPs shall be excluded from CSCRF compliance. 19.Real Estate Investment Trust (REIT)/ Infrastructure Investment Trust (InvIT) REITs/ InvITs shall be excluded from submission of compliance with CSCRF.
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20.Registrar to an Issue and Share Transfer Agents (RTA)
Table 12: Criteria and thresholds for RTA categorization
S. No. Criteria Small-size
REs
Mid-size
REs
Qualified
REs
MIIs
1 Servicing number of folios
10,000 and above but less than 1 crore
1 crore and above but less than 2 crore
N.A. QRTAs a. RTAs servicing less than 10,000 folios shall be excluded from submission of compliance with CSCRF. 21.Vault Managers Vault Managers shall be excluded from submission of compliance with CSCRF. 22.Venture Capital Funds (VCFs) –
Table 13: Criteria and thresholds for VCFs categorization
S. No. Criteria Selfcertification
REs
Small-size
REs
Mid-size
REs
Qualified REs
1 Sum of corpus of all schemes of the VCF
Less than
Rs. 100 crores
Rs. 100 crores and above but less than Rs.
500 crores
Rs. 500 crores and above but less than
Rs. 1000 crores
Rs. 1000 crores and above
23.In case an RE is registered under more than one category of REs, then the provision of highest category under which such an RE falls shall be applicable to that RE.
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3. IT Committee for REs
3.1. In order to address various technology related issues of REs, SEBI has
issued circulars for composition of technical committees for MIIs, and MFs/ AMCs summarized as below:
Table 14: SEBI circular for REs and composition of their technical committees
S. no.
Regulated
Entity
Name of the
Committee
Circular subject (Circular number)
Date
CSCRF
Version 1.0 decision-making given the ever expanding role of IT in securities market. In the absence of IT Committee for REs for Small-size REs and Selfcertification REs, the compliance to CSCRF shall be reviewed and approved by MD/ CEO/ Board member/ Partners/ Proprietor.
3.5. The brief 15 Terms of Reference (ToRs) of IT Committee for REs with respect
to CSCRF shall be as follows:
i. The committee shall undertake periodic reviews of implementation of
cybersecurity and cyber resilience policy of the RE.
ii. The committee shall also perform periodic reviews of cybersecurity
incident (if any), its impact, RCA and plans to strengthen the cyber resilience in order to mitigate re-occurrence of such incidents in future.
iii. The committee shall deliberate on the matters which may be referred by
the Board/ Partners/ Proprietor of the RE and/ or SEBI.
iv. The committee shall review various compliances as part of CSCRF and
make recommendations to the Board/ Partners/ Proprietor of the RE.
15 In case of existing SCOT/ IT Committees, the above-mentioned ToRs shall be considered as an addendum (and not a replacement) to the existing ToRs of the committees.
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4. CSCRF Compliance, Audit Report Submission, and
Timelines:
This section provides details regarding submission of compliance with the CSCRF including ISO audit, VAPT, Cyber audit, etc. and the corresponding applicable timelines. 4.1.Compliance with the Standards/ Guidelines Unless specified otherwise, the compliance reporting for CSCRF shall be done by the REs to their respective authority(ies) as per the existing mechanism, for example, MIIs shall submit the compliance with CSCRF to SEBI, stock brokers shall submit the compliance with CSCRF to stock exchanges, depository participants to shall submit the compliance with CSCRF to depositories, etc. Further, the compliance with the applicable standards and mandatory guidelines mentioned in CSCRF shall be as follows:
Table 15: Applicability and periodicity of standards mentioned in CSCRF
S.
No.
Standard/ Guidelines and
Clause
Applicability Periodicity
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S.
No.
Standard/ Guidelines and
Clause
Applicability Periodicity unused tokens review (PR.AA.S5) Other REs Half-yearly
8. Review of privileged users’
activities (PR.AA.S11)
MIIs and
Qualified REs
Quarterly
Other REs Half-yearly
9. Cybersecurity training
program (PR.AT.S1)
All REs Annually
10. Review of RE’s systems
managed by third-party service providers
(GV.SC.S4)
MIIs and
Qualified REs
Half-yearly
Other REs Annually
11. Functional Efficacy of SOC
(DE.CM.S1 – Guideline 4)
MIIs and
Qualified REs
Half-yearly
Other REs who are utilizing thirdparty managed SOC or Market SOC services Annually
12. Red Teaming exercise
(DE.DP.S4)
MIIs and
Qualified REs
Half-yearly
13. Threat hunting (DE.DP.S5) MIIs and
Qualified REs
Quarterly
14. Cybersecurity scenariobased drill exercise for
testing adequacy and effectiveness of recovery plan (RC.RP.S3) MIIs and Qualified REs Half-yearly Other REs Annually
15. Review of periodically and
update their contingency plan, continuity of operations plan (COOP) (RS.MA.S3) MIIs and Qualified REs Half-yearly Mid-size and small-size REs Annually
16. Evaluation of cyber resilience
posture (EV.ST.S5)
Mid-size and
Small-size REs
Annually
Note: During cyber audit, auditors shall also validate the adherence to the above-mentioned periodicities. 4.2.ISO Audit and Certification
4.2.1. It is mandated (as per standard PR.IP.S16) that MIIs and Qualified REs
shall obtain ISO 27001 (latest version) certification. Accordingly, all MIIs and Qualified REs shall obtain ISO 27001 within 1 year of issuance of CSCRF. The evidence of certification shall be submitted along with the cyber audit report to the authority(ies) as given below:
CSCRF
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Table 16: Reporting authority for ISO certification evidence submission
S.
No.
Regulated Entity Reporting authority
16 Unless otherwise specified, all audits mentioned in CSCRF have to be conducted by CERT-In empanelled IS auditing organization.
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S.
No.
Regulated Entity Periodicity
2. Rest of the REs At least once
VAPT activity shall commence in the first quarter of the financial year
4.3.3. The timeline for VAPT activity for SEBI REs shall be as follows:
Table 19: VAPT report submission and observations closure timeline
S.
No.
Activity Timeline
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S. No. Category Example
17 Unless otherwise specified, all certifications / audits mentioned in CSCRF have to be conducted by CERT-In empanelled IS auditing organization.
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Table 21: Cyber audit periodicity for REs
S.
No.
Regulated Entity Periodicity
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4.4.4. The closure of audit observations shall be regularly tracked by IT
Committee for REs. Additionally, all open observation after 3 months of completion of cyber audit shall be approved by IT Committee for REs and shall be closed before start of next audit exercise.
4.4.5. The follow-on audit report and open observations must be placed before
their respective IT Committee for REs for their confirmation and appropriate directions.
4.4.6. REs categorised as self-certification shall be required to conduct only
VAPT audit through CERT-In empanelled IS auditing organisation and no other audit is required to be conducted. Self-certification (format attached at Annexure-P) shall be submitted for compliance with the applicable CSCRF provisions signed by RE’s authorised signatory (MD/ CEO/ Board member/ Partners/ Proprietor).
4.5. Market SOC
4.5.1. The Market SOC shall be set up in accordance with the CSCRF
requirements and shall ensure that participating REs are in compliance with CSCRF as applicable to them.
4.5.2. The Market SOC shall be setup:
a. Mandatorily by NSE and BSE b. Optionally by NSDL and/ or CDSL
4.5.3. The report of functional efficacy of Market SOC shall be provided by BSE
and NSE (also NSDL and CDSL, if applicable) to SEBI on a periodic basis.
4.5.4. The timeline for setting-up of Market SOC shall be January 01, 2025.
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Part I: CSCRF Objectives and Standards
The main objectives of CSCRF are to proactively strengthen the security posture of the REs and prepare the operations of the REs to withstand and recover from the cyber incidents. This section breaks down the objectives and standards as per the cyber resilience goals and cybersecurity functions that REs are expected to achieve.
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1.2. GV.RR: Roles, Responsibilities and Authorities
i. GV.RR: Objective
Cybersecurity roles, responsibilities, and authorities to foster accountability, performance assessment, and continuous improvement are established and communicated.
ii. GV.RR: Standard
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1.4. GV.OV: Oversight
i. GV.OV: Objective
Results of organization-wide cybersecurity risk management activities, performance, and outcomes are used to inform, improve, and adjust the risk management strategy.
ii. GV.OV: Standard
CSCRF
Version 1.0 procedures to address them. Cyber risk management objectives shall be agreed to by the REs’ stakeholders.
2. Cybersecurity risk management activities and outcomes shall be
included in risk management processes of the REs.
3. Different scenarios and their respective responses shall be documented
and tested on a periodic basis to check the risk management plan of the REs.
4. Risk tolerance and risk appetite statements shall be established,
communicated, and maintained. REs shall determine and clearly express their risk tolerance and risk acceptance. The risk tolerance of the REs shall be informed by their role in critical infrastructure and/ or sector specific risk analysis. REs shall maintain a risk register which shall be periodically reviewed by their IT Committee for REs. Box Item 5: Cyber risk management Cyber risk management enables an organization to identify, prioritize, manage and monitor risks to their IT/ information systems and infrastructure. Cyber risk management is a continuous and iterative process that necessitates continuous improvement and assessment of security controls by incorporating emerging new information and responding to latest threat landscape. Cyber risk management includes:
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3. Contracts with suppliers and third-party service providers shall include
appropriate measures to meet the objectives of the RE’s cybersecurity program and cybersecurity supply chain risk management plan (including manpower adequacy in cybersecurity domain).
4. REs shall monitor, review and ensure compliance of third-party service
providers performing critical activities for their respective organization on a periodic basis.
5. SBOM shall be obtained for all new software procurements of core and
critical activities and kept updated with every upgrade or change. In case the SBOM cannot be obtained for the legacy or proprietary systems, the Board/ Partners/ Proprietor of the organization shall approve the same with proper limitation, rationale, and risk management approach.
6. Response and recovery planning, and testing shall be conducted along
with third-party service providers.
7. Concentration risk on outsourced agencies shall be assessed and
reviewed to achieve operational resiliency.
8. Third-party service providers shall also be mandated to follow similar
standards of information security.
Box Item 6: Software Bill of Materials (SBOM) Recent security breaches at third-party vendors like Apache (Log4j), Solarwinds, etc. have led to the introduction of Software Bill of Materials (SBOM) that enables an organization to identify possible vulnerabilities in the applications/ software solutions. With introduction of SBOM, the following benefits are envisaged for REs:
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2. Cyber Resilience Goal: ANTICIPATE | Cybersecurity function: IDENTIFY
Figure 3: Overview of Identify function
2.1. ID.AM: Asset Management
i. ID.AM: Objective
The data, personnel, devices, systems, and facilities that enable the RE to achieve its business purposes are identified and managed consistently in accordance with their relative importance to organizational objectives and the RE’s risk strategy.
ii. ID.AM: Standard
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6. All inventoried IT assets and data are managed throughout their
lifecycles.
2.2. ID.RA: Risk Assessment
i. ID.RA: Objective
The cybersecurity risk to the organization, assets, and individuals is assessed and understood by the RE.
ii. ID.RA: Standard
18 Quantum computing is a rapidly emerging technology that exploits quantum mechanics’ laws to solve complex problems. Post-quantum cryptography solutions can avert post-quantum risks and provide protection against quantum attacks. 19 Within 24 hours of receiving or as indicated by SEBI.
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5. REs shall monitor ongoing quantum computing developments for
cybersecurity threats, and ensure that senior management and relevant thirdparty service providers are aware of the possible risks associated with this technology.
6. REs shall enhance their crypto-agility to ensure a seamless transition to
quantum-resistant solutions without disrupting their current IT systems.
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3. Cyber Resilience Goal: ANTICIPATE | Cybersecurity function: PROTECT
Figure 4: Overview of Protect function
3.1. PR.AA: Identity Management, Authentication, and Access Control
i. PR.AA: Objective
Access to physical and logical assets and associated facilities is limited to authorized users, processes and devices, and is managed commensurate with the assessed risk of unauthorized access.
ii. PR.AA: Standard
CSCRF
Version 1.0 asserted in interactions. Users, devices, and other assets are authenticated (single-factor or multifactor) commensurate with the risk of the transaction (e.g., individuals’ security and privacy risks and other organizational risks).
7. All critical systems shall have MFA implemented for all users accessing
from untrusted network to trusted network.
8. A comprehensive log management policy shall be documented and
implemented.
9. User logs shall be uniquely identified and stored for a specified period.
10. Physical access to assets is managed, monitored, and protected. Physical
access to the critical systems shall be monitored and recorded on a continuous basis. Individuals shall be screened before granting access to RE’s organizational information and information systems.
11. Privileged users’ activities shall be reviewed periodically. Access
restriction shall be there for employees as well as third-party service providers. If it is required to grant access, it shall be for the limited timeperiod, on need-to-know basis and shall be subject to stringent supervision and monitoring.
12. Remote access to assets shall be strictly tracked and administered.
13. A comprehensive data-disposal and data-retention policy shall be
documented and implemented.
14. Comprehensive SOPs shall be documented for handling storage media
devices and their disposal.
15. Access control for using systems such as endpoint devices, networks,
APIs, removable media, laptops, mobiles, etc. shall be defined and implemented.
16. Mobile applications shall be properly vetted against security requirements,
and thoroughly tested before deployment.
17. API security with proper authentication and authorization mechanisms
shall be defined and implemented.
Box Item 8: Application Programming Interface (API) security Application Programming Interface: A system access point or library function that has a well-defined syntax and is accessible from application programs or user code to provide well-defined functionality. Application Programming Interface (API) is an interface that allows software applications to interact and communicate with each other using a set of definitions and protocols. Since APIs have become key component of modern software application development, the practice of preventing or mitigating attacks on APIs has also become critical. API security refers to processes and solutions to mitigate vulnerabilities and risks in APIs. OWASP has released API Top 10 security threats after a sharp increase in API-related security threats. API security guidelines broadly include the following categories:
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Version 1.0 increase the exposure and vulnerability of the data to potential breaches, fraud or misuse.
3. Rate Limiting: Rate limiting and throttling protects bandwidth of the systems by
enforcing a limit on how often an API is called and also prevents API abuse.
4. Secure API development: Incorporating secure-by-design strategy safeguards
APIs and prevents misconfigurations and flaws.
5. Zero-trust approach: With zero-trust approach, API security assumes no implicit
trust for any entity. Further, it also mitigates potential OWASP Top 10 API security risks. 3.2.PR.AT: Awareness and Training
i. PR.AT: Objective
The RE’s personnel and partners are provided cybersecurity awareness education, and are trained to perform their cybersecurity related duties and responsibilities consistent with related policies, procedures, and agreements.
ii. PR.AT: Standard
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3. Adequate capacity to ensure Availability of data shall be maintained.
4. Measures against data leaks shall be implemented. Appropriate tools
shall be put in place to prevent any data leakage.
5. The development and testing environment(s) shall be separated from the
production environment. For the development of critical software/ applications development, there shall be atleast one non-production environment to perform rigorous testing before deploying them to the production environment.
6. MIIs shall put in place integrity mechanisms to verify software, firmware,
and information integrity of its critical systems and other systems connected to its critical systems. Box Item 9: Data Classification To ensure the smooth functioning of the securities market as well as sovereign control over data, SEBI has given high priority to security controls on the various kinds of data generated, managed, or processed by the REs. Taking this into consideration, CSCRF mandates REs to set up robust security controls for such data. The data classification given below is technology agnostic, which will lead to a more enabled and strengthened environment for SEBI and REs. CSCRF has defined the following categories of data:
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Version 1.0 services include necessary software solutions hosted at the service providers’ own and/ or third-party infrastructure. This could lead to business functions becoming more and more dependent on the service providers. The hosted services/ software-as-a-service (SaaS)/ Cloud Service Providers (CSPs) usually store the data (business data, personal data etc.) where the processing of the data occurs. This results into data residing at the service providers’ own and/ or thirdparty infrastructure. While REs do not have a direct control on where their data is stored by the service providers, it is important to note that the REs’ data may be stored on servers outside the legal boundaries of India. If the REs’ data resides outside the legal boundaries of India, SEBI and its REs may not have sovereign control on it which may cause governance issues and put limitations on the compliance of various laws related to data protection and cybersecurity in the country. In order to protect interests of investors, and SEBI REs and their businesses, SEBI has envisaged data localization. Data localization means that all the data generated (including creation and storage) within the legal boundaries of India remains within the legal boundaries of India. Data localization ensures data sovereignty and data residency together. It will also lead to better governance and oversight. SEBI REs shall ensure that processing and storage of data is done within legal boundaries of India. CSCRF has mandated REs to keep the original Regulatory Data available and easily accessible in legible and usable form, within the legal boundaries of India. However, for the investors whose country of incorporation is outside India, the REs shall keep the original Regulatory Data, available and easily accessible in legible and usable form, within the legal boundaries of India. Further, if the Regulatory Data retained within India is not in readable form, the REs must maintain an application/ system to read/ analyse the retained data. However, the IT and Cybersecurity Data which is to be sent to/ consumed by global/ international SOC of the REs, and SaaS based cybersecurity solutions, has been exempted from being maintained within the legal boundaries of India. For the above-mentioned SaaS based cybersecurity solutions and SOC offerings utilized by the REs (where the data is not processed/ stored within the legal boundaries of India), the IT and Cybersecurity Data sent to such solutions shall be classified, assessed and periodically reviewed (at least once in a year) by the respective IT Committee for REs or equivalent body of the RE. Additionally, such IT and Cybersecurity Data shall be approved by the Board/ Partners/ Proprietor annually.
3.4. PR.IP: Information Protection Processes and Procedures
i. PR.IP: Objective:
Security policies (that address purpose, scope, roles, responsibilities, management commitment, and coordination among organizational entities), processes, and procedures are maintained and used to manage protection of information systems and assets.
ii. PR.IP: standard:
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5. If the source code of software/ application is not owned by the REs,
then in such a case, the REs shall obtain an undertaking/ certificate from the third-party service providers stating that their software/ application is free of known vulnerabilities, malwares, malicious/ fraudulent code and any covert channels.
6. Testing/ certification of software/ applications shall broadly address the
objectives such as product/ version/ module(s) functions only in a manner that it is intended to do, it is developed as per the best secure design/ coding practices and standards, it addresses known flaws/ threats due to insecure coding, etc.
7. REs shall document backup and recovery plan of data to ensure that
there is no data loss.
8. REs shall implement, test, and maintain data backups. Further, drills
for restoration of backup data shall be conducted on a periodic basis.
9. Policies and regulations regarding the physical operating environment
for REs’ assets shall be defined and adhered to.
10. Effectiveness of protective technologies shall be measured on a regular
basis in line with the SLAs.
11. Response plans (incident response and business continuity) and
recovery plans (incident recovery and disaster recovery) shall be put in place and regularly tested and updated.
12. A vulnerability management plan shall be developed and implemented.
13. For applicable cloud instances of REs, SEBI circular ‘Framework for
Adoption of Cloud Services by SEBI Regulated Entities (REs)’ shall be complied with.
14. Only CERT-In empanelled IS auditing organizations shall be
onboarded for external audit (including cyber audit) of REs to audit the implementation of standards and mandatory guidelines (as applicable) mentioned in this framework.
15. All software services in the form of SaaS/ Hosted services, COTS,
customized COTS, in-house developed software, etc. shall be certified for application security and functional audit. COTS products empanelled by stock exchanges/ depositories shall be certified for application security testing, and functional audit by STQC at the time of empanelment.
16. MIIs and Qualified REs shall obtain ISO 27001 certification.
17. MIIs and Qualified REs shall follow globally recognized standards such
as CIS Critical Security Controls to enhance their cyber resilience.
3.5. PR.MA: Maintenance
i. PR.MA: Objective:
Maintenance and repairs of organizational control and information system components are performed consistent with policies and procedures.
ii. PR.MA: Standard:
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4. Cyber Resilience Goal: ANTICIPATE | Cybersecurity function: DETECT
Figure 5: Overview of Detect function
4.1. DE.CM: Security Continuous Monitoring
i. DE.CM: Objective:
The REs’ information systems and assets are monitored to identify cybersecurity events and verify the effectiveness of protective measures.
ii. DE.CM: Standard:
20 SEBI through its circular CIR/MRD/CSC/148/2018 dated December 07, 2018 has mandated all stock exchanges, Clearing Corporations, and Depositories (except Commodities Derivatives Exchanges and their Clearing Corporation) to have a Cyber Security Operations Centre (C-SOC) that would be 24×7×365 set-up manned by dedicated security analysts to identify, respond, recover, and protect from cybersecurity incidents.
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3. All anomalies and alerts generated shall be properly monitored and
investigated within stipulated time.
4. Capacity utilization shall be monitored for all the critical systems in the
organization.
5. Cybersecurity audit, configuration audit, implementation audit, change
management audit, and VAPT shall be conducted to detect vulnerabilities in IT environment. Box Item 11: Security Operations Centre (SOC) and Market SOC The key functions performed by SOC are as follows:
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2. The Market SOC shall be set up in accordance with the CSCRF
requirements and shall ensure that participating REs are in compliance with CSCRF as applicable to them.
3. The Market SOC shall bridge technological gap for small REs and
provide them robust SOC services. However, the responsibility and accountability for compliance with CSCRF rests with the REs.
4. The Market SOC shall evolve continuously in order to incorporate new
security controls and guidelines that may be issued by SEBI from time to time.
5. The Market SOC provider shall ensure that the REs participating in their
SOC adhere to the minimum IT guidelines and security protocols all the time.
6. NSE and BSE (NSDL and CDSL, if applicable) shall carry out audit of
their Market SOC activity annually and submit the report to SEBI. Functional efficacy of market SOC shall be measured in accordance with Annexure-N of CSCRF and shall be reported along with market SOC providers’ cyber audit report.
4.2. DE.DP: Detection Process
i. DE.DP: Objective
Detection processes and procedures are maintained and tested to ensure awareness of anomalous events.
ii. DE.DP: Standard
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5. Cyber Resilience Goal: WITHSTAND & CONTAIN | Cybersecurity function:
RESPOND
Figure 6: Overview of Respond function
5.1. RS.MA: Incident Management
i. RS.MA: Objective:
Incident response plans and procedures are executed and maintained in order to ensure response to detected/ known cybersecurity incidents.
ii. RS.MA: Standard:
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4. Cybersecurity incidents shall be contained and mitigated. Further, newly
identified vulnerabilities shall be mitigated or documented as accepted risks.
5. MIIs and Qualified REs shall get onboarded to CSK (Cyber Swachhta
Kendra) and other CERT-In initiatives as notified from time to time. Box Item 12: Cybersecurity Incidents – Classification and Response CSCRF has classified cybersecurity incidents into four categories:
21 Refer Q 30 in CERT-In Cybersecurity directions: https://www.certin.org.in/PDF/FAQs_on_CyberSecurityDirections_May2022.pdf
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Version 1.0 applicable) within a stipulated time. Any/ all other cybersecurity incident(s) shall be reported to SEBI, CERT-In and NCIIPC (as applicable) as per guidelines.
3. In the event of a cybersecurity incident, REs shall coordinate with
stakeholders as per their CCMP.
5.3. RS.AN: Incident Analysis
i. RS.AN: Objective:
Incident analysis is conducted to ensure effective response and support recovery activities.
ii. RS.AN: Standard:
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6. Cyber Resilience Goal: RECOVER | Cybersecurity function: RECOVER
Figure 7: Overview of Recover function
6.1. RC.RP: Incident Recovery Plan Execution
i. RC.RP: Objective:
Recovery processes and procedures are executed and maintained to ensure timely restoration of systems or assets affected by cybersecurity incidents.
ii. RC.RP: Standard:
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ii. RC.CO: Standard:
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7. Cyber Resilience Goal: EVOLVE
Figure 8: Overview of Evolve goal
7.1. EV.ST: Strategies
i. EV.ST: Objective
A major component of cyber resilience is the ability to adapt and improve the security posture to stay ahead of threats.
ii. EV.ST: Standard
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8. Exemption Table
8.1.Self-certification REs and small-size REs shall be exempted from compliance with standards mentioned below in Table 25. Following exemptions shall be applicable for small-size REs and self-certification REs provided they are onboarded to Market SOC.
Table 25: Standards exempted for Self-certification REs and small-size REs
S.no Standard Code Standard name
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29. PR.DS.S1 Protect: Data Security – Standard 1
30. PR.DS.S5 Protect: Data Security – Standard 5
31. PR.DS.S6 Protect: Data Security – Standard 6
32. PR.IP.S3 Protect: Information Protection Processes and
Procedures – Standard 3
33. PR.IP.S16 Protect: Information Protection Processes and
Procedures – Standard 16
34. PR.IP.S17 Protect: Information Protection Processes and
Procedures – Standard 17
35. PR.MA.S1 Protect: Maintenance – Standard 1
36. PR.MA.S2 Protect: Maintenance – Standard 2
37. DE.CM.S4 Detect: Security Continuous Monitoring – Standard 4
38. DE.DP.S4 Detect: Detection Process – Standard 4
39. DE.DP.S5 Detect: Detection Process – Standard 5
40. RS.MA.S2 Respond: Incident Management – Standard 2
41. RS.MA.S3 Respond: Incident Management – Standard 3
42. RS.MA.S5 Respond: Incident Management – Standard 5
43. EV.ST: S1 Evolve: Strategies – Standard 1
44. EV.ST: S2 Evolve: Strategies – Standard 2
45. EV.ST: S3 Evolve: Strategies – Standard 3
46. EV.ST: S4 Evolve: Strategies – Standard 4
Along with Standards mentioned in Table 25, Self-certification REs shall be exempted from compliance to periodic cyber audit by CERT-In empanelled IS auditing organizations, i.e., Protect – Information Protection Processes and Procedures – Standard 14 (PR.IP.S14) and periodic evaluation of cybersecurity posture – Evolve – Strategies -Standard 5 (EV.ST.S5).
8.2. Mid-size REs shall be exempted from compliance to standards mentioned below
in Table 26. Following exemptions shall be applicable mid-size REs provided they are onboarded to Market SOC.
Table 26: Standards exempted for Mid-size REs
S.no Standard Code Standard name
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Part II: CSCRF Guidelines
This section contains CSCRF guidelines that provides a direction to REs for the implementation of standards mentioned in CSCRF. There are certain guidelines which are mandatory in nature and have been written under ‘Applicability’ column (Refer section 2 “Thresholds for REs’ categorization”). Cyber Resilience goal: ANTICIPATE Cybersecurity control: GOVERNANCE GV.OC: Guidelines GV.OC.S2, GV.OC.S3
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Version 1.0 but not limited to logs, user details, etc.) pertaining to the RE. In this process, SEBI or SEBI authorized personnel/ agency may access RE's IT infrastructure, applications, data, documents, including other necessary information given to, stored or processed by third-party service providers.
4. Engage a forensic auditor to identify the root cause of any incident (cybersecurity or
other incidents) related to RE.
5. SEBI shall seek the audit reports of the audits conducted by RE.
GV.RR: Guidelines
GV.RR.S3
22 https://www.nciipc.gov.in/documents/Roles_Responsibilities-CISO.pdf
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c. Employment screening procedures, employment policies and agreement,
employment termination procedures etc. are followed.
2. REs shall sign a confidentiality and integrity agreement with third-party service providers
and conduct due diligence of all third-party service providers accessing their IT systems. GV.PO: Guidelines GV.PO.S1, GV.PO.S2, GV.PO.S5
CSCRF
Version 1.0 aforementioned policies may form a part of RE’s cybersecurity policy or may be standalone policies.
4. REs shall formulate a policy for mobile and web applications and associated services
with the approval of their Board/ Partners/ Proprietor. The contours of the policy, while discussing the parameters of any “new product” including its alignment with the overall business strategy and inherent risk of the product, risk management/ mitigation measures, compliance with regulatory instructions, customer experience, etc., shall explicitly include security requirements from Functionality, Security and Performance (FSP) angles.
5. All information/ data (classified as Regulatory Data and IT and Cybersecurity Data) that
is consumed/ handled by REs shall be made accessible to SEBI when required. If there is any dependency on external party, REs shall facilitate information sharing with SEBI by including it in their agreement with external party.
6. The Cybersecurity Policy shall include the following process to identify, assess, and
manage cybersecurity risks associated with processes, information, networks and systems:
a. ‘Identify’ critical IT assets and risks associated with such assets. b. ‘Protect’ assets by deploying suitable controls, tools and measures.
c. ‘Detect’ incidents, anomalies and attacks through appropriate monitoring
tools/processes. d. Respond’ by taking immediate steps after identification of the incident, anomaly or attack. e. ‘Recover’ from incident through incident management and other appropriate recovery mechanism All REs
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7. REs shall follow Plan-Do-Check-Act concept while creating and using the documented
information. For example, activities under the ‘Plan’ phase shall be guided by Policies, the ‘Do’ phase will follow Procedures (SOPs), and the ‘Check’ and ‘Act’ phases will refer to the Policies and Procedures. All REs except small-size, Selfcertification REs
8. As part of compliance management with respect to CSCRF, REs shall apply following
key aspects (including but not limited to) for implementing compliance management:
a. Assess Compliance with applicable guidelines/ policies/ laws/ circulars/ regulations, etc. issued by SEBI or GoI. b. Develop compliance policies and procedures
c. Implement controls such as security measures
d. Train employees e. Monitor and review compliance management processes f. Regular audits and reporting. All REs except small-size, Selfcertification REs
9. The Board/ Partners/ Proprietor of the REs shall constitute an IT Committee for REs
comprising experts proficient in technology. This IT Committee of REs shall meet on a periodic 23 basis to review the implementation of the cybersecurity and cyber resilience policy approved by their Board/ Partners/ Proprietor, and such review shall include goal setting for a target level of cyber resilience, and establishing a plan to improve and strengthen cybersecurity and cyber resilience. The review shall be placed before the Board/ Partners/ Proprietor of REs for appropriate action. All REs except small-size, Selfcertification REs (Mandatory)
23 Refer ‘CSCRF Compliance, Audit Report Submission, and Timelines’ section.
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10.The aforementioned committee and the senior management of the REs, including the CISO, shall periodically review instances of cybersecurity incidents/ attacks, if any, domestically and globally, and take steps to strengthen cybersecurity and cyber resilience. All REs except small-size, Selfcertification REs (Mandatory) 11.The cybersecurity policy shall encompass the principles prescribed by National Critical Information Infrastructure Protection Centre (NCIIPC) of National Technical Research Organisation (NTRO), GoI in the report titled ‘Guidelines for Protection of National Critical Information Infrastructure’ and subsequent revisions, if any, from time to time. All REs which have been identified as CII by NCIIPC (Mandatory) 12.REs shall incorporate best practices from standards such as ISO 27001, ISO 27002, etc. or their subsequent revisions, if any, from time to time. All REs except small-size, Selfcertification REs GV.OV: Guidelines GV.OV.S4
24 Refer ‘CSCRF Compliance, Audit Report Submission, and Timelines’ section.
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GV.RM.S1,
GV.RM.S2
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Version 1.0 e. REs shall periodically assess level of employee cybersecurity awareness, for e.g., through phishing test success rate, etc. f. REs shall undertake periodic IT asset management for functions such as number of devices on the network running end-of-life (EOL) software, number of devices no longer receiving security updates, unidentified devices on the internal network, integration of third-party devices and services into the network, etc. Further, IT asset management may also be utilized for process of managing assets’ access and permissions, patching cadence, security rating, third-party security rating, number of known vulnerabilities, etc. g. Risk-based transaction monitoring or surveillance process shall be implemented as part of fraud risk management system across all delivery channels. GV.RM.S3
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2. Where applications (for e.g.: NSE’s NEAT, BSE’s BOLT etc.) are offered to users over
the internet by MIIs , the responsibility of ensuring cyber resilience of such applications resides with the MIIs and not with the users who are using the applications. MIIs (Mandatory)
3. The responsibility, accountability and ownership of outsourced activities lies primarily
with REs. Therefore, REs shall come up with appropriate monitoring mechanisms through a clearly defined framework to ensure that all the requirements as specified in CSCRF shall be complied with. The periodic 25 reports submitted to SEBI shall highlight the critical activities handled by the third-party service providers and REs shall certify that the above-mentioned requirement is complied with.
4. REs shall conduct background checks and ensure signing of Non-Disclosure
Agreement, and cybersecurity compliance for all third-party service providers. All REs (Mandatory) GV.SC.S5
25 Refer ‘CSCRF Compliance, Audit Report Submission, and Timelines’ section.
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c. All primary (top level) components with all their transitive dependencies
(including third-party dependencies whether in-house or open-source components) and relationships d. Encryption used e. Cryptographic hash of the components f. Frequency of updates g. Known unknown (where a SBOM does not include a full dependency graph) h. Access control
i. Methods for accommodating occasional incidental errors.
GV.SC.S7
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4. SEBI circulars on outsourcing of activities, currently mandated and updated from time
to time, shall be complied with by the respective REs. List of currently mandated SEBI circulars on outsourcing of activities has been attached at Annexure-F. Cyber Resilience goal: ANTICIPATE Cybersecurity control: IDENTIFY ID.AM: Guidelines ID.AM.S1, ID.AM.S4
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6. REs shall put in place configuration management database approach to:
a. Understand and inventorise their IT assets - both logical (e.g., data, software) and physical (e.g., hardware). b. Understand which data or systems are most critical for providing critical services as well as any associated interdependencies. MIIs (Mandatory) ID.AM.S6
7. All IT assets shall be inventoried in ITSM tool.
8. REs shall integrate cybersecurity considerations into product life cycles.
All REs except small-size, selfcertification REs (Mandatory) ID.RA: Guidelines ID.RA.S1, ID.RA.S2
26 Refer Definitions section for the Risk definition.
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Version 1.0 authentication solution shall analyse factors such as device, location, network, sensitivity, etc. Cyber Resilience goal: ANTICIPATE Cybersecurity control: PROTECT PR.AA: Guidelines PR.AA.S1, PR.AA.S2, PR.AA.S3, PR.AA.S7, PR.AA.S9
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Version 1.0 g. Existing user accounts and access rights shall be periodically reviewed by the owner of the system in order to detect dormant accounts, accounts with excessive privileges, unknown accounts or any type of discrepancy. h. Proper ‘end of life’ mechanisms shall be adopted for user management to deactivate access privileges of users who are leaving the organization or whose access privileges have been withdrawn. This includes named user IDs, default user IDs and generic email IDs.
i. All critical systems accessible over the internet shall have multi-factor security (such
as VPNs, Firewall controls, etc.) and MFA. j. MFA shall be enabled for all users and systems that connect using online/ internet facility and also particularly for VPNs, webmail, and accounts that access critical systems from non-trusted environments to trusted environments.
2. Network Security Management
a. Adequate controls shall be deployed to address virus/ malware/ ransomware attacks on servers and other IT systems. These controls may include host/ network/ application based IPS, customized kernels for Linux, anti-virus and anti-malware software, etc. Anti-virus definition files updates and automatic anti-virus scanning shall be done on a regular basis. b. All REs shall establish baseline standards to facilitate consistent application of security configurations to OS, databases, network devices, enterprise mobile devices, etc. within the IT environment. REs shall also conduct regular enforcement checks to ensure that baseline standards are applied uniformly.
c. The LAN and wireless networks within REs’ premises shall be secured with proper
access controls.
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3. Access Controls, Password Policy/ Authentication Mechanism
a. PIM solution or PIM process shall be implemented to keep track of privileged access. b. REs shall implement an access policy which addresses strong password controls for users’ access to systems, applications, networks and databases, etc. Illustrative examples for this are given in Annexure-G.
c. REs shall formulate an Internet access policy to monitor and regulate the use of
internet and internet based services such as social media sites, cloud-based internet storage sites, etc. within the critical IT infrastructure of REs. d. REs shall deploy controls and security measures to supervise staff with elevated system access entitlements (such as admin or privileged users). Such controls and measures shall inter-alia include restricting the number of privileged users, periodic 27 review of privileged users’ activities, disallow privileged users from accessing systems logs in which their activities are being captured, strong controls over remote access by privileged users, etc.
4. Network Security Management
a. REs shall apply appropriate network segmentation/ isolation techniques to restrict access to the sensitive information, hosts and services. Segment to segment access shall be based on strong access control policy and principle of least privilege. All REs except small-size, selfcertification REs (Mandatory)
27 Refer Table 15 in ‘CSCRF Compliance, Audit Report Submission, and Timelines’ section.
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Version 1.0 b. REs shall install network security devices, such as WAF, proxy servers, IPS, etc. to protect their IT infrastructure which is exposed to the internet, from security exposures originating from internal and external sources.
c. REs shall deploy web and email filters on the network. These devices shall be
configured to scan for known bad domains, sources, and addresses, block these before receiving and downloading message and filter out emails with known malicious indicators, such as known malicious subject lines, and block suspicious Internet Protocol (IP) addresses, malicious domains/URLs at the firewall. All emails, attachments, and downloads both on the host and at the mail gateway shall be scanned with a reputable antivirus solution. d. Network devices of REs shall be configured in line with whitelist approach of IPs, ports and services for inbound and outbound communication with proper ACL implementation. e. REs shall implement DNS filtering services to ensure clean DNS traffic is allowed in the environment. DNS security extension for secure communication shall be used. f. Management of critical servers/ applications/ services/ network elements shall be restricted through enterprise identified intranet systems. g. REs shall implement SPF, DMARC, and DKIM for email security. h. Email protection shall include (but not limited to) best practices like strong password protection, MFA, spam filtering, email encryption, secure email gateway, permissible attachments types, etc.
i. REs shall block malicious domains/IPs after diligently verifying them without
impacting the operations. CSIRT-Fin/ CERT-In advisories which are published periodically shall be referred for latest malicious domains/ IPs, C&C DNS and links.
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PR.AA.S8
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Version 1.0 a. As many OEMs and their service partners as well as System Integrators provide remote support services to organisations, REs shall ensure that these services are well-governed, controlled, logged and an oversight is maintained on all the activities done by remote support service providers. The above shall be complemented by regular monitoring and audit to ensure compliance of the defined policies for privileged users and remote access. b. REs shall ensure secure usage of RDP in IT systems. Further, it shall be implemented strictly on a need-to-use basis, and it must employ MFA. Remote access, if necessary, shall be given to authorised personnel from whitelisted IPs for a predefined time period, and with a provision to log all activities.
c. Employees and third-party service providers who may be given authorized access to
the critical systems, networks and other IT resources of REs shall be subject to stringent supervision, monitoring and access restrictions. d. Environmental controls (temperature, water, smoke, etc.), service availability alerts (power supply, servers, etc.), access logs, etc. shall be monitored. All REs except small, selfcertification REs (Mandatory) PR.AA.S13, PR.AA.S14
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PR.AA.S15
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Threat actors often target and use DCs as a staging point to spread ransomware network-wide. a. REs shall ensure that DCs are patched as and when patch is released and it must be reviewed on a quarterly basis to ensure the implementation of the same. b. REs shall ensure that no unnecessary software is installed on DCs, as these can be leveraged to run arbitrary code on the system.
c. REs shall ensure that access to DCs should be restricted to the Administrators
group. Users within this group shall be limited and have separate accounts used for day-to-day operations with non-administrative permissions. d. REs shall ensure that DC host firewalls are configured to prevent direct internet access. PR.AA.S16, PR.AA.S17
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2. Mobile Application Security
a. The mobile application shall perform root detection and root cloaking detection. The application shall not work on emulators or virtual devices. b. REs shall explore the feasibility of implementing a code that checks if the device is rooted/ jailbroken prior to the installation of the mobile application and disallow the mobile application to install/ function if the phone is rooted/ jailbroken.
c. Device Policy enforcement such as detection of developer option, USB debugging,
Mock Location, time settings manipulation, etc. shall be configured. d. Mobile application shall check new network connections or connections for unsecured networks like VPN connection, proxy and unsecured Wi-Fi connections. e. Mobile application shall have anti-malware capabilities covering application spoofing, RAT, screen mirroring, overlay malwares, key loggers, tap jacking, etc. f. Controls to prevent reverse engineering and application tampering shall be implemented in the mobile applications. These controls shall also validate the signature during runtime for authenticity of the application. g. Mobile application shall perform checksum validation and the checksum of applications shall be published in public domain. h. Mobile application shall identify the presence of active remote access, screen mirroring, active voice call, alert users, etc. to prevent online frauds.
i. Mobile application shall require re-authentication whenever the device of the
application remains unused for a designated period and also each time the investor/ user launches the application. j. Mobile application shall not store/ retain sensitive personal/ investor authentication information such as user IDs, passwords, keys, hashes, hard coded reference, etc.
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Version 1.0 on the device and the application shall also securely wipe out any sensitive investor/ user information from memory when the investor/ user exits the application. k. Mobile application shall be secured against common vulnerabilities such as SQL injection, etc.
l. REs shall ensure that the usage of raw SQL queries in mobile application to fetch or
update data from databases is avoided. Additionally, sensitive information shall be written to the database in an encrypted form. m.Mobile application shall implement device-binding solution to create a unique digital identity based on device, mobile number and SIM. n. OWASP – MASVS shall be referred for implementing mobile application security and other protection measures. o. REs shall consider implementing measures such as installing a “containerized” app on mobile/ smart phones for exclusive business use that is encrypted and separated from other smartphone data/ applications; implement measures to initiate a remote wipe on the containerized app, rendering the data unreadable, in case of requirement may also be considered. All REs except small-size, selfcertification REs
3. Guidelines for Application Security and Emerging Technologies
REs shall prepare SOPs for open source application security and concerns from emerging technologies like Generative AI security. MIIs and Qualified REs PR.AT: Guidelines PR.AT.S1, PR.AT.S2
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3. Majority of the infections are primarily introduced via phishing emails, malicious adverts
on websites, and third-party apps and programs. Hence, thoughtfully designed security awareness campaigns that stress the avoidance of clicking on links and attachments in email, shall be established as an essential pillar of defence. Additionally, the advisories issues by CERT-In/ CSIRT-Fin may be referred for assistance in conducting exercises for public awareness.
4. REs shall conduct periodic training programs to enhance knowledge of IT/ cybersecurity
policy and standards among the employees incorporating up-to-date cybersecurity threats. Wherever possible, this shall be extended to outsourced staff, third-party service providers, etc.
5. The training programs shall be reviewed and updated to ensure that the contents of the
program remain current and relevant.
PR.AT.S3
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Version 1.0 seamless and immediate notification to his entities. On such notification by the customer/investor, they may endeavour to build the capability for seamless/ instant reporting of fraudulent transactions to the corresponding beneficiary/ counterparty’s entities; vice-versa have mechanism to receive such fraudulent transactions reported from other entities.
4. Improve and maintain customer/ investor awareness and education with regard to
cybersecurity risks.
5. Encourage customers/investors to report phishing mails/ phishing sites and on such
reporting take effective remedial action.
6. Educate the customers/investors on the downside risk of sharing their login credentials/
passwords/ OTP etc. to any third-party and the consequences thereof. PR.DS: Guidelines PR.DS.S1, PR.DS.S2, PR.DS.S3
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Version 1.0 exchanging and transferring information with external parties. Illustrative measures to ensure security during transportation of data over the internet are given in Annexure-I. d. The information security policy shall also cover use of devices such as mobile phones, photocopiers, scanners, etc., which can be used for capturing and transmission of sensitive data within their IT infrastructure. For instance, defining access policies for personnel, network connectivity for such devices, etc. e. REs shall allow only authorized data storage device within their IT infrastructure through appropriate validation processes.
2. Application Security in Customer Facing Applications:
a. Application security for Customer facing applications offered over the Internet such as IBTs (Internet Based Trading applications), portals containing sensitive or private information and Back office applications (repository of financial and personal information offered by REs to Customers) are paramount as they carry significant attack surfaces by virtue of being available publicly over the Internet for mass use. An illustrative list of measures for ensuring security in such applications is provided in Annexure-G. All REs except self-certification REs (Mandatory)
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3. Security controls for mobile and web applications shall focus on how these applications
handle, store, and protect PII and other business related data.
4. Web and mobile applications shall not store sensitive information in HTML hidden
fields, cookies, or any other client-side storage to avoid any compromise in the integrity of the data.
5. REs shall renew their digital certificates used in IT systems well in time.
6. REs shall implement measures to control usage of VBA/macros in office documents,
control permissible attachment types in email systems.
7. REs shall have a documented data migration policy specifying SOPs and processes
for data migration while ensuring data integrity, completeness and consistency. PR.DS.S5
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Version 1.0 product updates and patches/ fixes are included in the source code escrow arrangement.
2. For all the software and applications, where vulnerabilities will be identified at a later
date, REs shall ensure that the vulnerabilities shall be mitigated in a time bound manner. REs shall also stipulate timelines in their SLA with their third-party service providers for the timely compliance and closure of identified vulnerabilities.
3. REs shall put in place appropriate third-party service providers (including software
vendors) risk assessment process and controls proportionate to their criticality/ risk in order to manage supply chain risks effectively.
4. REs shall ensure that maintenance and necessary support for applications/ software is
provided by the third-party service providers (including software vendors) and the same is enforced through a formal agreement. PR.IP: Guidelines PR.IP.S1
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c. For running services, non-default ports shall be used wherever applicable. Open
ports on networks and systems, which are not in use or can be potentially used for exploitation of data, shall be blocked. All open ports shall be monitored and appropriate measures shall be taken to secure them. d. Practice of whitelisting of ports based (at firewall level) on business usage shall be implemented rather than blacklisting of certain ports. Traffic on all other ports which have not been whitelisted shall be blocked by default. e. REs shall restrict execution of “PowerShell” and “wscript” in their environment, if not required. Additionally, REs shall also ensure installation and use of latest version of PowerShell, with enhanced logging enabled, script block logging and transcription enabled. Send the associated logs to a centralized log repository for monitoring and analysis. f. REs shall utilize host based firewall to prevent Remote Procedure Call (RPC) and Server Message Block (SMB) communications among endpoints wherever possible to limit lateral movement as well as other attack activities. PR.IP.S3
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2. Change Management process shall include (but not limited to) submission, planning
(impact analysis, rollout plan), approval, and implementation, review (postimplementation), closure, etc.
3. REs shall have a clearly defined framework for change management including
requirements justifying exception(s), duration of exception(s), process of granting exception(s), and authority for approving and for periodic review of exception(s) given. PR.IP.S4, PR.IP.S6
3. Secure Software Development Life Cycle (SSDLC)
a. All REs shall ensure that regression testing is undertaken before new or modified systems are implemented. The scope of tests shall cover business logic, security controls and system performance under various stress-load scenarios, and recovery conditions. b. For any production release, vulnerability assessment shall be undertaken. For all major release, VAPT shall be conducted by the REs to assess the risk and vulnerabilities generated from recent additions/ modifications in applications/ software. All REs except small-size, selfcertification REs (Mandatory)
4. Secure Software Development Cycle (SSDLC)
a. REs shall prepare business requirement document with clear mentioning of security requirements, session management, audit trail, logging, data integrity, security event tracking, exception handling, etc. b. For secure rollout of software and applications, threat modelling and application security testing shall be conducted during development.
c. REs shall refer to standards, security guidelines for application security and other
protection measures given by OWASP (for e.g. OWASP-ASVS).
All REs
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Version 1.0 d. REs shall adopt the principle of defence-in-depth to provide a layered security mechanism. e. Before introducing new technologies for critical systems, REs shall ensure that IT/ security team has assessed evolving security concerns and achieved fair level of maturity with such technologies before incorporating them into IT infrastructure. PR.IP.S14
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Version 1.0 g. For conducting audits, CERT-In ‘IT Security Auditing Guidelines for Auditee Organizations’ may be followed by REs. Additionally, CERT-In ‘Guidelines for CERT-In Empanelled IS Auditing Organizations’ (attached at Annexure-D) may be mandated for empanelled IS auditing organizations. h. Due diligence with respect to the audit process and the tools used for such audits shall be undertaken by REs to ensure competence and effectiveness of audits.
i. REs shall strive for building an automated tool and suitable dashboards (preferably
integrated with log aggregator) for submitting compliance with CSCRF. A dashboard shall be available at the time of cyber audit, onsite inspection/ audit by SEBI or any agency appointed by SEBI. MIIs and Qualified REs (Mandatory) PR.IP.S15
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2. Tests/ audits stated above at point 1 (a-b) shall be limited to cybersecurity aspects.
Application security testing shall also include API security and API discovery. Scope of functional audit shall cover data integrity, report integrity, and transaction integrity, etc.
3. With respect to empanelled COTS used by Stock Brokers and Depository Participants:
a. Before empaneling any COTS solutions for supplying software/ products to their respective stock brokers and depository participants, Stock Exchanges and Depositories shall conduct tests/ audits stated above at point 1 (a-b) through STQC. b. The Stock Exchanges and Depositories shall prepare a SOP for inclusion of tests/ audits in their vendor empanelment process for COTS solutions.
c. The empanelment shall be approved by the Stock Exchanges and Depositories only
after receipt of compliance reports from STQC and VAPT report from the COTS vendor.
4. Customized COTS:
a. REs shall ensure that the compliance with tests/ audits stated above at point 1 (a-d) by CERT-In empanelled IS auditing organization for any customized COTS.
5. Inhouse developed software:
a. REs shall ensure compliance with aforementioned point 1 is submitted by CERT-In empanelled IS auditing organization.
6. Software services in form of SaaS/ hosted services used by REs:
i. REs shall be required to submit compliance with the technical specification
mentioned in hosted services definition for the SaaS/ hosted services used by them.
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ii. REs shall also submit compliance with adoption of hosted services and SaaS as per
the various functions of CSCRF including Governance, Identify, Protect, Detect, Respond, and Recover. PR.IP.S16
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PR.MA.S3
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Version 1.0 systems/applications in a timely manner. The policy shall be approved by IT Committee for REs. Additionally, the above-mentioned policy on patch management shall be reviewed by IT Committee for REs atleast on an annual basis.
9. REs shall ensure that post application of any patch/ update, the resources deployed are
adequate enough to deliver the expected performance.
10.REs shall also establish processes for tracking patch compliance across all IT systems/ applications and reporting the same to their respective IT Committee for REs on a quarterly basis. 11.Based on the criticality of the patches, REs shall ensure that patches are implemented at both PDC and DR site within the upper/ maximum time limit as defined below. However, for emergency patching, patches shall be deployed within timelines as stipulated by the OEMs. S. No. Criticality of Patch Upper/ maximum Timeline 1 High 1 week 2 Moderate 2 weeks 3 Low 1 month (Mandatory) Cyber Resilience goal: ANTICIPATE Cybersecurity control: DETECT DE.CM: Guidelines DE.CM.S1, DE.CM.S2, 1. Security Continuous Monitoring All REs (Mandatory)
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DE.CM.S3 a. REs shall establish appropriate security monitoring systems and processes to facilitate continuous monitoring of security events/ alerts and timely detection of unauthorized or malicious activities, unauthorized changes, unauthorized access and unauthorized copying and transmission of data/ information held in contractual or fiduciary capacity, by internal and external parties. The security logs of systems, applications and network devices exposed to the internet shall also be monitored for anomalies. b. Suitable alerts shall be generated in the event of detection of unauthorized or abnormal system activities, transmission errors or unusual online transactions.
c. To enhance the security monitoring, REs (except client-based stock brokers having
less than 100 clients) are mandated to employ SOC services for their systems. REs may choose any of the following models to use SOC services:
i. RE’s own SOC/ group SOC
ii. Market SOC implemented mandatorily by NSE, BSE and optionally by NSDL and/
or CDSL
iii. Any other third party managed SOC
d. Small-Size and Self-certification category REs are mandated to be on-boarded on above-mentioned Market SOC.
2. Functional efficacy of SOC
a. REs shall measure functional efficacy of their SOC using the quantifiable method given in Annexure-N. b. REs shall review the functional efficacy of SOC on a half-yearly basis. MIIs and Qualified REs (Mandatory)
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c. REs shall deploy solutions such as BAS, CART, decoy, vulnerability management,
etc. to enhance their cybersecurity posture. d. Those REs who are utilizing third-party managed SOC services or market SOC shall obtain SOC efficacy report (using the quantifiable method given in Annexure-N) from their SOC provider on a yearly basis. All REs having third-party managed SOC or market SOC (mandatory)
3. MIIs shall have a cybersecurity Operations Centre (C-SOC) that would be a 24×7×365
set-up manned by dedicated security analysts to identify, respond, recover and protect from cybersecurity incidents 28. The C-SOC for MIIs shall function in accordance with SEBI circular CIR/MRD/CSC/148/2018 dated December 07, 2018 which has been attached at Annexure-M. MIIs (Mandatory) DE.CM.S4
28 Refer SEBI circular CIR/MRD/CSC/148/2018 dated December 07, 2018.
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Communications capacity – (“bandwidth” to ensure communications are made in a timely manner).
4. Capacity management shall be;
a. Pro-active – for example, using capacity considerations as part of change management; b. Reactive – e.g. triggers and alerts for when capacity usage is reaching a critical threshold so that timely increments (temporary or permanent) can be made. DE.CM.S5
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5. Revalidation of VAPT post closure of observations shall be done in a time bound manner
to ensure that all the open vulnerabilities have been fixed.
6. In case of vulnerabilities being discovered in COTS (used for core business) or
empanelled applications, REs shall report them to the vendors and the designated stock exchanges and/ or depositories in a timely manner. Stock Brokers/ Depository Participants falling under Qualified REs and Mid-size REs (Mandatory) DE.DP: Guidelines DE.DP.S4
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DE.DP.S5
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c. Develop/ hire people with appropriate skill-sets,
d. Prepare cyber playbooks, e. Create knowledge database for all known adverse conditions and attacks RS.MA.S5
29 Refer Q 30 in CERT-In Cybersecurity directions: https://www.cert-in.org.in/PDF/FAQs_on_CyberSecurityDirections_May2022.pdf
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3. The incident shall also be reported to CERT-In in accordance with the guidelines/
directions issued by CERT-In from time to time. Additionally, the REs, whose systems have been identified as “Protected system” by NCIIPC shall also report the incident to NCIIPC.
4. The quarterly reports containing information on cyber-attacks, threats, cybersecurity
incidents and breaches experienced by REs and measures taken to mitigate vulnerabilities, threats and attacks including information on bugs/ vulnerabilities, threats that may be useful for other REs and SEBI, shall be submitted to SEBI within 15 days from the quarter ended June, September, December and March of every year.
5. Such details, which are deemed useful for sharing with other REs, in a masked manner,
shall be shared using mechanism to be specified by SEBI from time to time. While sharing the above-mentioned sensitive information, TLP may be followed with four levels of sensitivity: white, green, amber, or red.
6. During the processing of reported incidents by SEBI, REs shall provide regular reports
(such as RCA, forensic analysis report, etc.) on the progress of the incident analysis. RS.CO.S2
30 REs shall decide the impact of cyber-attack.
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4. If the cyber-attack is of low impact 31 and has a narrow/low reach, the REs shall inform
all the affected customers/ stakeholders.
5. REs shall notify the customer/ investor, through alternate communication channels, of
all transactions including buy/ sell, payment or fund transfer above a specified value determined by the customer/ investor. All REs (Mandatory) RS.AN: Guidelines RS.AN.S1, RS.AN.S2, RS.AN.S3
31 REs shall decide the impact of cyber-attack.
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RS.AN.S4,
RS.AN.S5
32 Half-yearly for MIIs and Qualified REs. Once in two years for Mid-size and small-size REs.
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RS.IM.S2
3. The updates and changes in the contingency plan, COOP, training exercises, and
incident response and recovery plan shall be communicated and approved by the Board/ Partners/ Proprietor. All REs Cyber Resilience goal: RECOVER Cybersecurity control: RECOVER RC.RP: Guidelines RC.RP.S1
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5. REs shall explore the possibility of retaining spare hardware in an isolated environment
to rebuild systems in an event that starting REs’ operations from PDC and/ or DRS is not feasible. The REs shall also try to keep spare hardware in ready-to-use state for delivering critical services and such systems shall be updated as and when new changes (for example OS patches, security patches, etc.) are implemented in the primary systems. This spare hardware shall regularly undergo testing in-line with the response and recovery plan of the REs.
6. REs shall take all necessary precautions while updating the ‘golden’ server images and
data backup to ensure that server images and data backups are undamaged/unbroken.
7. In case of ransomware attacks that specifically target backups, conventional data
backups may not be effective. Therefore, REs shall create backups in an isolated and immutable (and/ or air-gapped) manner to ensure recovery if production system is compromised.
8. REs shall undertake regular business continuity drills to check the readiness of the
organization and effectiveness of existing security controls at the ground level. One such drill scenario recommended to be tested is recovering from a ransomware attack considering both PDC and DRS have been impacted. This shall assess the effectiveness of people, processes and technologies to deal with such attacks. RC.RP.S2
33 Refer https://www.bis.org/cpmi/publ/d146.pdf.
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REs. The recovery plan shall be scenario-based and in line with the RTO and RPO specified.
2. REs shall conduct comprehensive scenario-based cyber resilience testing at least 2
times in a financial year (periodicity of such testing shall be of 6 months), to validate their ability to recover and resume operations following a cybersecurity incident/ attack within prescribed RTO and RPO defined by SEBI. In this regard, REs shall incorporate extreme plausible cyber-attack scenarios into their cyber response and recovery planning. The said scenarios may be devised by REs in consultation with their respective IT Committee for REs based on the learning from various sources such as past cybersecurity incidents, near-miss analysis, data from Security Operations Centre, honeypot logs analysis, etc.
3. REs shall periodically conduct backup testing and restore back-up data to check its
usability.
4. For cyber resilience testing, REs shall also include stakeholders such as critical thirdparty service providers, market intermediaries, linked REs, etc.
5. The result of the Cyber resilience testing shall be placed before IT Committee for REs.
The lessons learned from conducting such cyber resilience testing shall be shared with SEBI within 3 months from the end of the relevant period of conducting cyber resilience testing. Status of the observations found during the cyber resilience testing shall be monitored and tracked by IT Committee for REs. MIIs and Qualified REs (Mandatory) RC.RP.S3
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RC.RP.S4
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2. REs shall try to incorporate lessons learned from incidents reported (if any) by other
REs.
RC.IM.S2
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8. In order to include heterogeneity, apply different audit/logging regimes at different
architectural layers.
9. REs shall look for feasibility of deploying diverse operating systems. Attack or
compromise on one type of OS may not affect other OS deployed.
10. RE shall maintain extra capacity of IT assets for information storage, processing, or
communications.
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Part III: Structured Formats for CSCRF Compliance
Annexure-A: VAPT Report Format
REPORTING FORMAT FOR MARKET ENTITIES TO SUBMIT THEIR COMPLIANCE AND FINDINGS OF VAPT NAME OF THE ORGANISATION: <Name> ENTITY TYPE: <Intermediary Type> ENTITY CATEGORY: <Category of the RE as per CSCRF> RATIONALE FOR THE CATEGORY: <> PERIOD OF AUDIT: <> NAME OF THE AUDITING ORGANISATION: <Name> Date on which VAPT Report presented to ‘IT Committee for REs’: <Date> RE’s Authorised signatory declaration:
I/ We hereby confirm that the information provided herein is verified by me/ us and I/ we shall take the responsibility and ownership of this VAPT report. Signature:
Name of the signatory:
Designation (choose whichever applicable): <MD/ CEO/ Board member/ Partners/ Proprietor> Company stamp:
Annexures:
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Table of Contents
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This is to be submitted by the auditor on the RE’s letter head.
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2. Executive Summary
<Auditing Organization to provide an executive summary of the findings>
3. Scope of VAPT
S.
No.
Type of Assessment List the details of the assessment
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6. Summary of the VAPT Report:
6.3.Details of Vulnerability Assessment findings:
S.
No.
Vulnerability Assessment Findings Details
Scope
Vulnerability Assessment
Auditor
Remarks
5. Number of Identified vulnerabilities
Closure
Timelines
Open vulnerabilities (Shall be applicable during final submission)
6. Critical High Medium Low Total Critical High Medium Low Total
7. Critical Assets
8. VA of infrastructure -
Internal and External
9. VA of Applications - Internal
and External
10. WiFi Testing
11 API Security Testing
12. Network Segmentation
13. VA of mobile applications
14. OS and DB Assessment
15. VA of cloud deployments
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16 Configuration Audit
17. Others, please specify
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6.4. Details of Penetration Testing findings:
S.
No.
Penetration Testing Findings Details
Scope
Penetration Testing Auditor
Remarks
5. Identified vulnerabilities
Closure
Timelines
Open vulnerabilities (Shall be applicable during final submission)
6. Critical High Medium Low Total Critical High Medium Low Total
7. Critical Assets
8. External Penetration Testing -
Infrastructure and Application
9. PT of mobile applications
10. PT of cloud deployments
11. Others, please specify
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7. Detailed Report
Detailed report to be submitted for all the items in the scope as per the below mentioned format (to be submitted only when sought by SEBI):
S.
No
URL/
Application
Name
Type of Risk
(Critical/ High/
Medium/ Low)
Observations/
Vulnerability
Reference
(CVE/ CWE/
OWASP/
Best
Practice)
EPSS/
SSVC score
Impact Recommendations Management
Comments with specific closure timelines
1.
2.
…
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8. Risk Rating description
Rating Description
CRITICAL The failure has an impact on the system delivery resulting in outage of services offered by the RE. HIGH Represents weakness in control with respect to threat(s) that is/are sufficiently capable and impacts asset (s) leading to regulatory non-compliance, significant financial, operational and reputational loss. These observations need to be addressed with utmost priority. MEDIUM Represents weakness in control with respect to threat(s) that is/are sufficiently capable and impacts asset (s) leading to exposure in terms of financial, operational and reputational loss. These observations need to be addressed within a reasonable timeframe. LOW Represents weaknesses in control, which in combination with other weakness can develop into an exposure. Suggested improvements for situations not immediately/directly affecting controls.
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Annexure-B: Cyber Audit Report Format
Cyber audit report format for compliance submission NAME OF THE ORGANISATION: <Name> ENTITY TYPE: <Intermediary Type> ENTITY CATEGORY: <Category of the RE as per CSCRF> RATIONALE FOR THE CATEGORY: <> PERIOD OF AUDIT: <> NAME OF THE AUDITING ORGANISATION: <Name> Date on Which Cyber Audit Report presented to ‘IT Committee for REs’ :
<Date>
RE’s Authorised signatory declaration:
I/ We hereby confirm that the information provided herein is verified by me/ us and I/ we shall take the responsibility and ownership of this cyber audit report. Further, this is to certify that:
a. Comprehensive measures and processes including suitable incentive/ disincentive structures, have been put in place for identification/ detection and closure of vulnerabilities in the organization’s IT systems. b. Adequate resources have been hired for staffing our Security Operations Centre (SOC).
c. There is compliance by us with CSCRF.
Signature:
Name of the signatory:
Designation (choose whichever applicable): <MD/ CEO/ Board member/ Partners/ Proprietor> Company stamp:
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Table of Contents
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This is to be submitted by the auditor on the company’s letter head.
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2. Executive Summary
<Auditing Organization to provide an executive summary of the findings>
3. Scope of audit/Terms of reference (as agreed between the auditee and auditor),
including the standard/specific scope for audit:-
3.1. List of SEBI Circulars/ Guidelines/ Advisories/ Letters covered:
S. No. SEBI circular/ letter/ advisory
Issue date
3.2. List of all IT infrastructure and geographical locations (including IT systems
of PDC, DR, Near site, Co-lo facility) covered under audit S.
No.
List of IT infrastructure/ Geographical locations/ Third-party vendors Details (assets ID, asset name, applications, etc.) of the Infrastructure assessed
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4. Methodology/ Audit approach (audit subject identification, pre-audit planning, data gathering methodology, sampling methodology
etc. followed by the Auditing Organization)
5. Summary of findings (including identification tests, tools used and results of tests performed)
S.No Number of Nonconformity
Number of observations
Risk rating Any other
Critical High Medium Low comments
1
6. Control-wise Compliance status of SEBI CSCRF:
S.N o
Standards prescribed by SEBI
CSCRF
(Clause number and text)
Description of
Finding(s)/
Observation( s)
Name of the system belongs to RE or thirdparty vendor Status/natu re of findings Risk rating (C/H/M/ L) of the finding s C/I/A affecte d Test case s used Root Cause Analysi s Impact analysi s Auditor recommendatio ns/ Corrective actions Deadline of correcti ve action(s) Manageme nt response Wheth er similar issue was reporte d in the last three audits. *List of documenta ry evidence including physical inspection/ sample size taken by the auditor 1 GV.OC. S1 2 GV.OC. S2 … N EV.ST.S 5 *Explicit reference to the key auditee organisational documents (by date or version) including policy and procedure documents
7. A brief description of the above-mentioned compliance requirements is as followsi. Standards prescribed by SEBI CSCRF (or any other cybersecurity circular/ letter/ guidelines) (Clause number and text)- The
clause corresponding to this observation w.r.t CSCRF (or any other cybersecurity circular/ letter/ guidelines) issued by SEBI.
ii. Description of findings/observations – Description of the findings in sufficient details, referencing any accompanying evidence
iii. Name of system belongs to RE or vendor-(Self Explanatory term)
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iv. Status/ Nature of Findings – The category can be specified, for example:
a. Non-compliant (Major/Minor) b. Work in progress
c. Observation
v. Risk Rating of the finding - A rating shall be given by the auditing organization for each of the observations, based on its
impact and severity, to reflect the risk exposure as well as the suggested priority for action Rating Description CRITICAL The failure shall have impact on the system delivery resulting in outage of services offered by the RE. HIGH Represents weakness in control with respect to threat(s) that is/are sufficiently capable and impacts asset (s) leading to regulatory non-compliance, significant financial, operational and reputational loss. These observations need to be addressed with utmost priority. MEDIUM Represents weakness in control with respect to threat(s) that is/are sufficiently capable and impacts asset (s) leading to exposure in terms of financial, operational and reputational loss. These observations need to be addressed within a reasonable timeframe. LOW Represents weaknesses in control, which in combination with other weakness can develop into an exposure. Suggested improvements for situations not immediately/directly affecting controls. .
vi. C/I/A Affected – The principles of Confidentiality/ integrity/ availability affected due to issued left unaddressed.
vii. Test cases used –The details of test cases used for arriving at this observation. The test cases may also be provided as
annexures with the report, if required.
viii. Root Cause analysis – A detailed analysis on the cause of the non-conformity.
ix. Impact Analysis – An analysis of the likely impact on the operations/ activity of the RE.
x. Auditor recommendations/ Corrective actions – The actions to be taken (by the RE) to correct the non-conformity.
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xi. Deadline of corrective action(s) -The RE shall specify the deadline not only for the corrective action(s) to be taken on the
system(s) where NC/ observation was found, but also specify the deadline for corrective action on systems with related functionalities/ configurations where similar observations could have been found/are found.
xii. Management response – Management action plan/taken to address the observation and/ or implementation of auditor’s
recommendation
xiii. Whether similar issue was reported in the last three audits – Yes/ No
xiv. List of documentary evidence including physical inspection/ sample size taken by the auditor
8. Format for exception reporting by the RE: These exceptions shall be approved by the IT Committee for REs
S.
No
.
Standard of
CSCRF
Descriptio n of noncomplianc e
Auditor observatio n
Auditor recommendati on
Managemen t comments
Comment of ‘IT
Committe e for REs’
Comments of Board of RE
Comments of Board of
Trustee
(wherever applicable)
Status of noncompliance
(open/closed)
Repeat observation in last 3 audits
Deadline for corrective action
Risk category of noncompliance
9. The audit report shall also include the following9.1. Audit report shall provide terms of reference (ToR) of audit which shall indicate the scope/perimeter of the coverage of the
systems audited in the cyber audit report regarding the compliances checked including areas (but not limited to) computer hardware, business applications, software, cyber governance, linkage with vendor systems/ other REs’ systems like stock brokers, RTAs, Fund Accountants, email systems, etc.
9.2. Audit report shall include open observations from previous audits and comments of auditors for compliances checked for
the same.
CSCRF
Annexure-B
Version 1.0
9.3. The auditor shall mention in the audit report the methodology adopted to check compliance. Further, the reason for
disagreement between auditor and management, if any, shall also be recorded in audit report.
10. Any other relevant comments by the auditor:
11. Conclusion of cyber audit
CSCRF
Annexure-C
Version 1.0
Annexure-C: Recovery Plan Template (Reference Guide) Recovery Plan Template for REs 1 Cybersecurity incident recovery plan
i. Preparation: Measures taken in preparation for
cybersecurity incident (pre-incident).
ii. Identification
Checklist a. Source (Who has discovered or reported the incident?) b. When it was discovered?
c. Details of the incident
d. Incident occurred on on-prem/ cloud resource? e. What is the location (PDC/ DR/ Near DR, etc.) of the incident? f. The impact of the incident on the business operations g. What is the extent of the incident w.r.t applications and networks? h. Type of the incident (e.g. Phishing mail, weak credentials, ransomware attack, data breach, etc.)
i. How did the Cybersecurity Incident
occur?
iii. Containment
checklist a. Can the incident be isolated to identify the scope of the incident and determine what systems, services, data or networks are compromised? If so, what are the steps taken, if not, explain why it can’t be isolated? b. Are the affected systems kept isolated from the non-affected ones?
c. Have the ‘golden’ server images
and data been identified? d. Is the latest data backup (as per prescribed RPO) available? e. Have the copies of the infected machines preserved for digital forensics and incident response experts for analysis? f. Has the threat been removed from the infected devices?
iv. Resolution
checklist
Resolving the cause of the incident:
a. Removing malware, b. Patching vulnerabilities,
c. Taking other measures etc.
Please specify resolution method.
CSCRF
Annexure-C
Version 1.0
v. Recovery
checklist a. Recover lost or corrupted data, b. Restore normal operations by returning systems and networks to a known good state
c. Taking other measures etc.
2 Cybersecurity incident recovery plan scenarios 3 Categorization of incidents 4 Key assumptions and pre-requisites 5 Authorization 6 Details of the Incident Response Team (IRT) (Internal/External) 7 Details of other teams involved (Internal/External) 8 Cybersecurity incident recovery invocation 9 Off site location address where ‘golden’ copy of server images and data are stored 10 Recover System(s) and Services 11 Recovery Actions 12 Lessons learned: Document lessons learned from the incident and incorporate them into incident response and recovery plans. 13 Post-incident: Measures taken to avoid reoccurrence of the cyber incident 14 Perform Hotwash
CSCRF
Version 1.0
Part IV: CSCRF Annexures and References
Annexure-D: Audit Guidelines
CSCRF
Annexure-D
Version 1.0 b. All audit reports shall be submitted strictly as per the format provided in CSCRF.
c. The coverage of the audit shall be as follows:
i. REs which have been declared as CIIs by NCIIPC shall follow the
guidelines/ circulars issued by NCIIPC for selecting sample size for critical/ non-critical assets.
ii. Rest of the REs shall take the sample size as mentioned in ‘CSCRF
Compliance, Audit Report’.
iii. RE shall ensure that 100% of their critical systems should get covered
under cyber audit. Further, RE shall ensure that for 25% of non-critical systems, sample size and sampling method should be mentioned explicitly in the audit report with the rationale of checking it on sample basis and the chosen sample size.
iv. As part of audit of the RE, the auditor shall verify, and certify, whether
there is a clear delineation/ demarcation of roles and responsibilities between the RE and Hosted service provider (as given in definitions
section). The auditor shall also verify, and certify, whether the abovementioned demarcations of roles and responsibilities have been
incorporated in the agreement/ contract signed between the RE and Hosted service provider. d. The auditors shall also validate the adherence to the timelines as stated in ‘Section 4: CSCRF Compliance, Audit Report Submission, and Timelines’ of CSCRF. e. For mandatory guidelines, auditor shall verify whether guidelines have been implemented as mentioned in the CSCRF. If there are any variations, auditors shall mention the same with relevant evidences in their report. f. For non-mandatory guidelines, auditors shall verify that whether REs have implemented equivalent controls or higher. If the implemented measures are not lower/ weaker than the stated guidelines, auditors shall mention the same with proper evidences in their report. g. For standards where no guidelines are mentioned, auditors shall verify that REs have implemented the industry best practices. h. Auditor shall ensure that the evidences are comprehensively stated with the observations made in the report. Auditors shall provide appropriate description of evidences verified for each standard/guidelines.
i. The risk-rating category (critical/ high/ medium/ low) shall be presented
clearly in the audit observations. j. Auditor shall compulsorily give their recommendations and suggestions to mitigate critical and high observations made in the report for the consideration of the REs. REs shall examine these recommendations and take it to their respective IT committee for REs for remediation. k. REs shall securely store the evidences provided by the auditor. These evidences may be scrutinized during regulatory inspections/investigations.
l. Auditors shall verify the closure of previous audit observations and mention
the status of the same in the audit report.
CSCRF
Annexure-D
Version 1.0 m.If any observation is repeated from the previous audit, auditor shall clearly mention them as repeat observation. n. Auditor’s report(s) shall include assessment of identification of assets as critical/ non-critical. o. Auditor’s report(s) shall be accompanied by the auditor’s certificate for adhering to the above-mentioned points.
3. Other recommended references:
a. IT Security Auditing Guidelines for REs: https://www.certin.org.in/PDF/guideline_auditee.pdf b. Guidelines for CERT-In empanelled Information Security Auditing Organizations: https://www.cert-in.org.in/PDF/Auditor_Guidelines.pdf
CSCRF
Annexure-E
Version 1.0
Annexure-E: Scenario-based Cyber Resilience Testing Scenario-based Cyber Resilience Testing This is a sample template for Stock Exchange. REs are encouraged to make their scenarios in consultation with their IT Committee for REs. Sample scenarios that are targeted to cover in Cyber Response plan as well as Cyber Resiliency Testing (Types of Attack × Potential Targeted Time intervals- On Core Systems):
Cyber
Attack->
DDoS Malware/ Malicious
Code Attack
Application
Level
Attacks
(SaaS Model)
DNS
Based
Attacks
(Internal &
Internet)
Brute
Force/Authentication based attack
AD
Time attack
Interval
Pre-open
Sessions
Before
BOD/early
Morning
Before 9:00 hrs
B/W 9:00 -
9:15 hrs
Regular
Trading
Sessions
09:15 -
15:30 hrs
Closing
Session
15:30 -16:00 hrs
Post 16:00 hrs
CSCRF
Annexure-E
Version 1.0
Attack Scenario Category Types of attacks Impact Response & Recovery DDOS Service Unavailability DDOS Protection services for auto mitigation. Malware Attacks Ransomware Service Unavailability, Data Corruption, Data exfiltration, Website Defacement
CSCRF
Annexure-E
Version 1.0
Attack Scenario Category Types of attacks Impact Response & Recovery DNS Based Attacks DNS Spoofing/Cache Poisoning Service Unavailability
CSCRF
Version 1.0
Annexure-F: Guidelines on Outsourcing of Activities SEBI’s existing circulars on outsourcing by REs are as follows:
'Outsourcing of activities, Business Continuity Plan (BCP) and Disaster Recovery (DR) and Cyber Security and Cyber Resilience framework - Limited Purpose Clearing Corporation (LPCC)' dated Nov 06, 2020 (Refer: https://www.sebi.gov.in/legal/circulars/nov-2020/outsourcing-ofactivities-business-continuity-plan-and-disaster-recovery-and-cyber-securityand-cyber-resilience-framework-limited-purpose-clearingcorporation_48106.html) ‘Outsourcing of activities by Stock Exchanges and Clearing Corporations’ dated Sep 13, 2017 (Refer: https://www.sebi.gov.in/legal/circulars/sep-2017/outsourcing-ofactivities-by-stock-exchanges-and-clearing-corporations_35932.html) ‘Outsourcing by Depositories’ dated Dec 09, 2015 (Refer: https://www.sebi.gov.in/legal/circulars/dec-2015/outsourcing-bydepositories_31219.html) ‘Guidelines on Outsourcing of Activities by Intermediaries’ dated Dec 15, 2011 (Refer: https://www.sebi.gov.in/legal/circulars/dec-2011/guidelines-onoutsourcing-of-activities-by-intermediaries_21752.html)
CSCRF
Version 1.0
Annexure-G: Application Authentication Security Illustrative Measures for Application Authentication Security are given below:
CSCRF
Version 1.0
Annexure-H: Data Security on Customer Facing Applications Illustrative Measures for Data Security on Customer Facing Applications are given below:
CSCRF
Version 1.0
Annexure-I: Data Transport Security
Illustrative Measures for Data Transport Security are given below:
CSCRF
Version 1.0
Annexure-J: Framework for Adoption of Cloud Services SEBI’s ‘Framework for Adoption of Cloud Services by SEBI Regulated Entities (REs)’ circular dated March 06, 2023:
(Refer: https://www.sebi.gov.in/legal/circulars/mar-2023/framework-for-adoption-ofcloud-services-by-sebi-regulated-entities-res-_68740.html )
CSCRF
Version 1.0
Annexure-K: Cyber Capability Index (CCI)
REPORTING FORMAT FOR MIIs AND QUALIFIED REs TO SUBMIT THEIR CCI SCORE NAME OF THE ORGANISATION: <Name> ENTITY TYPE: <Intermediary Type> ENTITY CATEGORY: <Category of the RE as per CSCRF> RATIONALE FOR THE CATEGORY: <> PERIOD: <> NAME OF THE AUDITING ORGANISATION (applicable for MIIs): <Name> RE’s Authorised signatory declaration:
I/ We hereby confirm that Cyber Capability Index (CCI) has been verified by me/ us and I/ We shall take the responsibility and ownership of the CCI report. Signature:
Name of the signatory:
Designation (choose whichever applicable): <MD/ CEO/ Board member/ Partners/ Proprietor> Company stamp:
Annexures:
CSCRF
Version 1.0
Cyber Capability Index (CCI)
A. BackgroundCCI is an index-framework to rate the preparedness and resilience of the cybersecurity framework of the Market Infrastructure Institutions (MIIs) and Qualified REs. While MIIs are required to conduct third-party assessment of their cyber resilience on a half-yearly basis, Qualified REs are directed to conduct selfassessment of their cyber resilience on an annual basis. B. Index Calculation Methodology1. The index is calculated on the basis of 23 parameters. These parameters have been given different weightages.
2. Implementation evidence to be submitted to SEBI only on demand.
3. All implementation evidences shall be verified by the auditor for conducting
third-party assessment of MIIs.
4. The list of CCI parameters, their corresponding target and weightages in the
index, is as follows:
CSCRF
Annexure-K
Version 1.0
Table 27: CCI parameters with corresponding measure, implementation evidence, target, and weightage
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs)
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs)
2. VAPT report
and its closure report.
3. Time taken to
close the identified vulnerabilities.
3. Security
Training
Measure
[PR.AT.S
1]
Information
Security Goal:
Ensure that organization’s personnel are adequately trained to carry out their assigned information security- related duties and responsibilities Percentage (%) of information system security personnel that have received security training within the past one years. Implement ation (Number of information system security personnel that have completed security training within the past year/total number of information system security personnel) ×100 100 %
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs)
4. Remote
Access
Control
Measure
[PR.AA.S
12]
Information
Security Goal:
Restrict access to information, systems, and components to individuals or machines that have been authenticated and are identifiable, known and credible. Percentage (%) of remote users logging through MFA. Effectiven ess (Number of remote users logging through MFA/ total number of remote users) ×100 100 %
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs) access points?
5. Evidence of
users who are allowed remote access through MFA, validated through Firewall, AD, or any dedicated system.
6. Based on
reviews of the incident database, IDS/
IPS logs and alerts, and/ or appropriate remote access point log files, how many access points have been used to gain unauthorized access within the reporting period?
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs)
5. Audit
Record
Review
Measure
[DE.CM.S
1]
Information
Security Goal:
Create, protect, and retain information system audit records to the extent needed to enable the monitoring, analysis, investigation, and reporting of unlawful, unauthorized, suspicious or abnormal activity. Percentage (%) of critical systems integrated with SIEM. Efficiency (Number of critical systems integrated with SIEM tool/total number of critical systems) ×100 100 %
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs)
6. Configurat
ion
Changes
Measure
[DE.CM.S
5]
Information
Security Goal:
Establish and maintain baseline configuration and inventories of organizational information systems (including hardware, software, firmware, and documentation) throughout the respective system development life cycles. Percentage (%) approved and implemented configuration changes identified in the latest automated baseline configuration. Implement ation (Number of approved and implemented configuration changes identified in the latest automated baseline configuration/ total number of configuration changes identified through automated or manual scans) × 100 100 %
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs) automated scanning over the last reporting period?
4. How many
change control requests were approved and implemented over the last reporting period?
5. Cyber audit
observation against
Standard 3 mentioned in
‘Detect:
Continuous
Security
Monitoring’ header in
CSCRF Part-I and respective guidelines in
Part-II.
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs)
7. Contingen
cy Plan
Testing
Measure
[RS.MA.S
3]
Information
Security Goal:
Establish, maintain, and effectively implement plans for emergency response, backup operations, and post-disaster recovery of organizational information systems to ensure the availability of critical information resources and continuity of operations in emergency situations. Percentage (%) of information systems that have conducted contingency plan testing at least once in a year. Effectiven ess (Number of information systems that have conducted contingency plans testing at least once in a year/ number of information systems in the system inventory) ×100 100 %
CSCRF
Annexure-K
Version 1.0
8. User
Accounts
Measure
[PR.AA.S
7]
Information
Security Goal:
All privilege users are identified and authenticated in accordance with information security policy. Percentage (%) of privileged access through PIM. Effectiven ess (Number of systems accessed through PIM/ total number of systems) ×100 100 %
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs)
9. Incident
Response
Measure
[RS.CO.S
2]
Information
Security Goal:
Track, document, and report incidents to appropriate organizational officials and/or authorities. Percentage (%) of incidents reported within required time frame. Effectiven ess (number of incidents reported on time/ total number of reported incidents) ×100 100 %
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs)
10. Maintenan
ce
Measure
[PR.MA.S
1]
Information
Security Goal:
Perform periodic and timely maintenance on organizational information systems and provide effective controls on the tools, techniques, mechanisms, and personnel used to conduct information system maintenance. Percentage (%) of system components that undergo maintenance in accordance with planned maintenance schedules. Efficiency (Number of system components that undergo maintenance according to planned maintenance schedules/ total number of system components) ×100 100 %
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs) or release for reuse. released for reuse) × 100 followed.
3. Cyber audit
observation against
Standard 14 mentioned in
‘Protect: Identity
Management,
Authentication, and Access
Control’ header in CSCRF Part-I and respective guidelines in
Part-II.
12. Physical
Security
Incidents
Measure
[PR.AA.S
10
]
Information
Security Goal:
Integrate physical and information security protection mechanisms to ensure appropriate protection of the organization’s Percentage (%) of physical security incidents allowing unauthorized entry into facilities containing information systems. Effectiven ess (Number of physical security incidents allowing unauthorized entry into facilities containing information systems/total number of physical security incidents) ×100 0% 1.Policy/procedu re ensuring the secure physical access to critical systems?
2. How many
physical security incidents occurred during the specified period?
3. How many of
the physical
1%
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs) information resources. security incidents allowed unauthorized entry into facilities containing information systems?
4. Cyber audit
Observation against
Standard 10 mentioned in
‘Protect: Identity
Management,
Authentication, and Access
Control’ header in CSCRF Part-I and respective guidelines in
Part-II.
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs)
13. Planning
Measure
[GV.RR.S
5]
Information
Security Goal:
Develop, document, periodically update, and implement security measures for authorised access to the information systems of the organisation. Percentage of employees who get authorized access to information systems only after they sign an acknowledge ment that they have read and understood confidentiality and integrity agreement. Implement ation (Number of users who are granted system access after signing confidentiality and integrity agreement/total number of users who are granted system access) ×100 100 %
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs)
14. Personnel
Security
Screening
Measure
[PR.AA.S
10]
Information
Security Goal:
Ensure that individuals occupying positions of responsibility within organizations are trustworthy and meet established security criteria for those positions. Percentage (%) of individuals screened before being granted access to organizationa l information and information systems. Implement ation (Number of individuals screened/total number of individuals having access to organization’s information and information systems) ×100 100 %
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs) information systems, and assets are understood and assessed. systems, and assets ) ×100 Assessment’ header in CSCRF Part-I and respective guidelines in
Part-II.
16. Service
Acquisitio n Contract
Measure
[GV.SC.S
3]
Information
Security Goal:
Ensure thirdparty providers employ adequate security measures to protect information, applications, and/or services outsourced by the organization. Percentage (%) of system and service acquisition contracts that include security requirements and/or specifications . Implement ation (Number of system and service acquisition contracts that include security requirements and specifications/ total number of system and service acquisition contracts) ×100 100 %
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs)
4. Whether the
acquisition contract includes SLA for vulnerabilities closure and timely implementation of patches?
5. Contracts for
adoption of
Cloud includes implementation of ‘security of the cloud’ , etc.
17. System
and
Communic ation
Protection
Measure
[PR.DS.S
4]
Information
Security Goal:
Allocate sufficient resources to adequately protect electronic information infrastructure. Percentage of mobile computers and devices that perform all cryptographic operations. Implement ation (Number of mobile computers and devices that perform all cryptographic operations/total number of mobile computers and devices) ×100 100 %
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs) computers and devices have cryptography implementation waivers?
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs)
18. Risk
Managem ent
[GV.RM.S
1,
GV.RM.S2
]
Based on risk appetite of the organization, cybersecurity risks are identified, analysed, evaluated, prioritized, responded, and monitored. Percentage (%) of organization information systems, and assets covered under risk management . Effectiven ess (Number of organization information systems, and assets covered under risk management/To tal number of organization information systems, and assets ) ×100 100 %
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs)
19. Critical
Assets
Identified
[ID.AM.S1
,
ID.AM.S2]
Objective of this measure is to ensure identification and management of assets in accordance with their relative importance to the organizational objectives and the organization’s risk strategy. Percentage (%) of the critical systems identified by REs among all other IT systems. Implement ation Measure (Number of critical systems Identified/ Total IT systems integrated with SOC) ×100 50% 1. Process to identify and approve the list of critical assets.
2. List of critical
assets identified as per the
ID.AM.S1.
3. Auditors
reports on identification of assets as critical/ noncritical.
9%
20. CSK
Events
[RS.MA.S
5]
Objective of this measure is to mitigate threats upon external IPs Number of CSK reported events closed in timely manner. Effectiven ess Measure (Total number of CSK reported events closed in 15 days/ Total number of CSK reported events to the organization)×1 00 100 %
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs)
21. Cybersecu
rity Policy
Document
[GV.PO.S
1]
Develop, document, periodically update, and implement cybersecurity policies and procedures for organizational information systems that describe the security controls in place or planned for information systems. Non quantifiable measure
CSCRF
Annexure-K
Version 1.0
S
No Measure
ID Goal/Objective Measure Measure
Type Formula Targ et
Implementation
Evidence
Weig htage
Selfasses sment score
Auditor comment s w.r.t. cyber audit (for
MIIs)
22. SOC
efficacy
How effective is our SOC operational?
SOC efficacy score
Effectiven ess
As specified in
SOC efficacy
(Annexure-N)
100
%
CSCRF
Version 1.0 Page 187 of 205
5. Based on the value of the index, the cybersecurity maturity level of the MIIs and
Qualified REs shall be determined as follows:
SN. Rating Index Score Rating
1 Exceptional Cybersecurity Maturity 100-91 2 Optimal Cybersecurity Maturity 90-81 3 Manageable Cybersecurity Maturity 80-71 4 Developing Cybersecurity Maturity 70-61 5 Bare Minimum Cybersecurity Maturity 60-51 6 Fail < =50 (The RE has scored below the cutoff in at least one domain/ subdomain)
6. MIIs and Qualified REs shall strive for building an automated tool and suitable
dashboards (preferably integrated with log aggregator) for submitting compliance. A dashboard shall be available at the time of cyber audit, onsite inspection/ audit by SEBI or any agency appointed by SEBI.
CSCRF
Version 1.0 Page 188 of 205
Annexure-L: VAPT Scope
Comprehensive Scope for Vulnerability Assessment and Penetration Testing (VAPT)
CSCRF
Version 1.0 Page 189 of 205
Annexure-M: Cyber-SOC Framework for MIIs
SEBI’s ‘Cyber-SOC Framework for MIIs’ circular (‘Cyber Security and Cyber Resilience framework of Stock Exchanges, Clearing Corporations and Depositories’ dated Dec 07, 2018):
(Refer: https://www.sebi.gov.in/legal/circulars/dec-2018/cyber-security-and-cyberresilience-framework-of-stock-exchanges-clearing-corporations-anddepositories_41244.html )
CSCRF
Annexure-N
Version 1.0 Page 190 of 205
Annexure-N: Functional Efficacy of SOC
REPORTING FORMAT FOR FUNCTIONAL EFFICACY OF SOC NAME OF THE ORGANISATION: <Name> ENTITY TYPE: <Intermediary Type> ENTITY CATEGORY: <Category of the RE as per CSCRF> RATIONALE FOR THE CATEGORY: <> PERIOD: <> RE’s Authorised signatory declaration:
I/ We hereby confirm that report of functional efficacy of SOC has been verified by me/ us and I/ We shall take the responsibility and ownership of the report. Signature:
Name of the signatory:
Designation (choose whichever applicable): <MD/ CEO/ Board member/ Partners/ Proprietor> Company stamp:
Annexures:
CSCRF
Annexure-N
Version 1.0 Page 191 of 205
Measuring and auditing functional efficacy of SOC
34 For the purpose of calculation, zero score shall be given for a category/ sub-category if the denominator is zero.
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Table 30: Methodology to assess the level of asset integration with SOC Technologies
S.
No.
SOC
Technologies
Weightage
(%) (W)
Systems
ID applicabl e
Count of
Systems to be integrated
(x) [to be identified from table
29]
Count of
Systems
Actually
Integrated and covered
(y)
Coverage
Score
Z=(y/x)
Weighte d Score
(Z×W)
1 PAM 10
S1, S2,
S4, S5,
S6
2
Anti-virus/
EPP 10 S3, S6
3 EDR 10 S3, S6
4 DLP 10
5 DAM 10 S5
6 WAF 10 S4
7
Emailgateway* 10
8
Webgateway/
Proxy* 10
9 DDoS* 10
1
0 SIEM 10
S1, S2,
S4, S5,
S6 n
Technology-Asset-Coverage-percentage C b) SOC Operations: To determine the efficiency of the periodic activities carried out by SOC personnel for effective threat management and regular maintenance of SOC technologies.
Table 31: Methodology to assess the performance of SOC operations
S.
No. Metric Value
Weightage
(W) (%)
Weighted
Score
1
Log ingestion into SIEM
Log sources reporting to SIEM [A] A 5 (A/B)×W Total No. of Log Sources (from Table 29) [B] B 2 Latency in Log Ingestion (benchmarking against 5 minutes) 5 IF C<5 then score = ((5-
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S.
No. Metric Value
Weightage
(W) (%)
Weighted
Score
Maximum log processing latency- latency between collection of the security event at the log source and processing it in SIEM (in minutes) [C] C C)/5)×W IF C>=5 then score = 0 3 SOC technology version control 5 (D/E)×W No. of technologies running on version ‘n-1’ and ‘n’ [D] D Total No. of technologies deployed [E] E 4 SOC technology vulnerability closure 5 (F/G)×W No. of open advisories (issued by CERT-In/ CSIRT-Fin) and vulnerabilities on SOC technologies [F] F Total advisories (issued by CERT-In/ CSIRTFin) and vulnerabilities reported on SOC technologies [G] G 5 SIEM Use cases 5 (H/I)×W No. of SOC technologies for which use cases are configured [H] H Total no. of SOC technologies [I] (from Table
30) I
6
Use cases that are not triggered
Use-cases that are not triggered [J] J
5 ((K-J)/K)×W Total no. of use cases [K] K 7 Playbooks Defined 10 (L/M)×W No. of playbooks defined associated with use cases [L] L Total no. of use cases [M] M 8 False Positives No. of false positives [N] N 10 ((O-N)/O)×W Total no. of alerts [O] O 9 False Negatives No. of false negatives [P] P 10 ((Q-P)/Q)×W Total no. of alerts [Q] Q 10 Threat Intel (benchmarking against 60 minutes) 5 IF R<60 then score = ((60- R)/60)×W IF R>=60 then score = 0 Mean Time to process the Threat Intel feed received (minutes) (R) R 11 Handling Critical Systems Critical Applications and assets' log ingestion in SIEM is being verified on a daily basis? Yes=1, No=0 (S) 2 S×W
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S.
No. Metric Value
Weightage
(W) (%)
Weighted
Score
Critical Applications and assets' integration with Anti-virus/ EDR, DAM, etc. verified on a daily basis? Yes=1, No=0 (T) 2 T×W Use-cases/rules configured on SIEM for critical systems? Yes=1, No=0 (U) 2 U×W Privilege access to critical systems verified on a weekly basis? Yes=1, No=0 (V) 2 V×W Configuration and data back-ups being taken periodically? Yes=1, No=0 (X) 2 X×W Total 75 Y *The above metric for SOC operations is not exhaustive, REs are required to add other metrics depending upon the maturity of their security infrastructure and availability of tools and technologies. 25% weightage is left to the REs. c) Competency of deployed SOC personnel: To assess the skill level of security professionals deployed in SOC through a combination of appropriate industry level certifications and years of experience to ensure that SOC operations are carried out in smooth and effective manner.
Table 32: Methodology to assess the competency of deployed SOC personnel
S. No.
Categor y of engineer s
Minimum
Certificatio n requireme nt
Weight age of categor y
[C] (%)
Years of
Experie nce
(YoE)
Weighta ge of subcategory
[w]
Count of
Engineer s having minimum required certificati ons # [x] Actual subcatego ry Score [z] = [x] × [w] categor y-wise score [A] = Sum [z] / Sum[x] Weight ed Score [B] = [A] × [C] 1 L1 CEH 35 2 0.25 2 3 0.50 3 4 0.75 4 5 1.00 5 L2 CEH + Any product OEM certificatio n 25 6 0.33 6 7 0.66 7 8 1.00 8 L3 CEH + CISM 40 9 0.25 9 10 0.50
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S. No.
Categor y of engineer s
Minimum
Certificatio n requireme nt
Weight age of categor y
[C] (%)
Years of
Experie nce
(YoE)
Weighta ge of subcategory
[w]
Count of
Engineer s having minimum required certificati ons # [x] Actual subcatego ry Score [z] = [x] × [w] categor y-wise score [A] = Sum [z] / Sum[x] Weight ed Score [B] = [A] × [C] 10 11 0.75 11 >=12 1.00 Final Score of Manpower P #Fractional YoE shall be converted to be the floor value of the experience for calculation. Example:
if an engineer has 2.6 YoE then it has to be counted in the category of 2 YoE. Engineers not having required minimum certification cannot be counted in the category. d) SOC Governance: To determine the capability of strategic management and the level of oversight of SOC through factors such as finances, personnel training and the involvement of IT Committees for REs and their Board.
Table 33: Methodology to assess the governance of SOC
S.
No
. Metric
Value
(A)
Weightage
(W)(%) Weighted Score
1
Budget for SOC
45 (2*B/A)×W
(maximum score can be
45)
Budget spent on cybersecurity [A] A
Budget Spent on SOC technology and governance (50% benchmarking) [B] B 2 Training Percentage of budget spent for training out of total budget forecasted for training E 10 (E/100)×W 3 Whether SOC review has been undertaken by IT Committee for REs Yes=1, No=0 (F) 5 F×W 4 Whether recommendations of technology committee have been submitted to governing board of RE Yes=1, No=0 (G) 5 G×W Total 65 H
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*The above metric for SOC operations is not exhaustive, REs are required to add other metrics depending upon the maturity of their security infrastructure and availability of tools and technologies. e) SOC Enrichments and Enhancements: To determine the level of proactiveness of SOC in leveraging deployed technologies, automation of alert responses and deploying latest SOC technologies. This will help the SOC to evolve and ensure its preparedness in case of a future breach.
Table 34: Methodology to assess proactiveness of SOC
S.
No. Metric Value(A)
Weightage
(W)(%)
Weighted
Score
1 Dashboard and Analytics
1.1
Using Native technology dashboard
Yes=1,
No=0 5
A×W
1.2 Custom developed dashboard
Yes=1,
No=0 5
A×W
2 Threat Hunting
2.1
Threat Hunting Exercise Carried out by:
Specialized Threat Hunting service provider Yes=1, No=0 5 A×W Internal Team Yes=1, No=0 3 A×W
2.2 Periodicity of the Exercise:
Quarterly Yes=1,
No=0 5
A×W
Half-Yearly Yes=1,
No=0 3
A×W
2.3 Hypotheses:
Total no. of hypotheses [T]
No. of hypotheses based on the open vulnerabilities [X] 5 (X/T)×W No. of Hypotheses based on IoCs [Y] 5 (Y/T)×W No. of Hypotheses based on IoAs [Z] 5 (Z/T)×W 3 Automation
3.1 Threat intel integration with SIEM Yes=1,
No=0 5
A×W
3.2 No. of SOAR actions triggered [T]
5 (T/S)×W
Total no. of different SOAR actions created [S] 4 Technologies implemented Decoy Yes=1, No=0 3 A×W
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S.
No. Metric Value(A)
Weightage
(W)(%)
Weighted
Score
Sandboxing Solution Yes=1,
No=0 3
A×W
UEBA Yes=1,
No=0 3
A×W
Vulnerability Management
Solution
Yes=1,
No=0 3
A×W
Encrypted Traffic Management Yes=1,
No=0 3
A×W
DNS Security
Yes=1,
No=0 3
A×W
Intrusion prevention system Yes=1,
No=0 3
A×W
Data classification solution Yes=1,
No=0 3
A×W
Total 75 E
*The above metric for SOC operations is not exhaustive, REs are required to add other metrics depending upon the maturity of their cybersecurity infrastructure and availability of tools and technologies. 25% weightage is left for this to the REs.
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Annexure-O: Classification and Handling of Cybersecurity Incidents A: Guidelines on Classification of Cybersecurity Incidents Threshold for classifying incidents:
35 Refer Annexure-I of Cert-IN direction No. 20(3)/2022 dated April 28, 2022 36 Refer Q 30 in CERT-In Cybersecurity directions: https://www.certin.org.in/PDF/FAQs_on_CyberSecurityDirections_May2022.pdf
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4. Any cyber incident that results in disruption, stoppage or variance in the normal
functions/ operations of systems of the entity thereby impacting normal/ regular service delivery and functioning of the entity, must be classified as High or Critical incident.
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B: Guidelines on Handling of Cybersecurity Incidents
37 Refer Q 30 in CERT-In Cyber security directions: https://www.certin.org.in/PDF/FAQs_on_CyberSecurityDirections_May2022.pdf 38 Cybersecurity incidents have to be reported by SEBI REs in accordance with the framework/circular/Standard Operating Procedure issued by SEBI.
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c. Whether the RE has communicated to all relevant stakeholders about
the incident. d. Whether RE has taken sufficient measures to control, mitigate and remediate the incident. e. Whether Root cause analysis (RCA) has been performed by RE. f. Whether lessons learnt have been implemented by RE. g. Whether the issues/loopholes identified in RCA stage have been addressed/plugged by the RE. h. Whether RE has hired any independent agency to conduct IS Audit/ forensic audit related to the incident (as per applicability).
i. Whether RE has addressed/plugged vulnerabilities identified in the audit
mentioned in point h above.
3.3. RE shall undertake the necessary activities and submit the relevant reports
as per the following timelines:
Table 36: Timelines for post-cyber incident activity(ies) and report
submission
S.
No.
Name of the Report/ Activity Timeline for Submission (from the date of reporting the incident or being brought to notice about the incident) 1 Interim Report* 3 Days 2 Mitigation measure 7 Days 3 Root Cause Analysis (RCA) report 30 Days# 4 Forensic Audit Report (on the incident) and its closure report Refer clause 3.4 below 5 Vulnerability Assessment and Penetration Testing (VAPT) for the incident and its closure reports 45 days 6 Any other report as required by SEBI To be submitted as per SEBI direction *The interim report must contain, inter alia, the following: Details of the incident including time of occurrence, information regarding affected processes/ systems/ network/ services, severity of the incident, and the steps taken to initiate the process of response and recovery. The RCA report shall inter-alia include exact cause of the incident (including root cause from vendor(s), if applicable), exact timeline and chronology of the incident, details of impacted processes/ systems network / services, details of corrective/ preventive measures taken (or to be taken) by the entity along with
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case-by-case basis on request of the RE taking into account the complexity and nature of the incident(s). The same shall be an exception rather than the rule.
3.4. The RCA, forensic audit, VAPT reports, and closure reports shall be reviewed
by the respective IT Committee for REs before the reports are submitted to SEBI. A report on the review conducted/ recommendations provided by IT Committee for REs shall also be submitted to SEBI along with the reports mentioned in Table 36.
3.5. SEBI shall examine the incident on the basis of reports submitted. Further, RE
shall classify the cybersecurity incident based on its severity as per Table 35 and the same shall be reviewed by respective IT Committee for REs of the RE before the reports are submitted to SEBI.
3.6. In case the reports are found to be deficient or inaccurate in any manner (for
instance no identification or incorrect identification of root cause, inaccurate sequence of events, etc.), appropriate regulatory action may be taken by SEBI. RE may be provided an additional time upto 15 days from the day of being notified of the deficiency/ inaccuracy, for submitting the accurate and complete report.
3.7. In the event of RE not submitting accurate and complete reports after being
provided additional time, appropriate regulatory action may be taken by SEBI (over and above the action mentioned in clause 3.6 above).
3.8. Critical or High category of cybersecurity incidents experienced by MIIs,
Qualified REs, and Mid-size REs shall be mandatorily put up for the review for HPSC-CS. Remaining incidents i.e., low and medium for all REs, and high and critical severity incidents for small-size and self-certification REs shall be processed by SEBI internally. The review by HPSC-CS and SEBI shall be as follows:
3.8.1. Review by HPSC-CS
i. For all the incidents placed before HPSC-CS, the committee may
confirm the severity or may recommend a different severity on the basis of its analysis.
ii. The committee will examine the reports, review the severity of the
incident and provide its recommendations on the same.
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iii. Further, if the committee determines that the incident occurred on
account of non-compliance of SEBI cybersecurity framework/ advisories, appropriate regulatory action may be taken by SEBI on the RE notwithstanding any action levied above.
iv. The recommendations of the committee shall be implemented by the
RE in a time-bound manner. The timelines for the implementation shall be decided by the committee based on the discussion with relevant stakeholders (i.e. SEBI and the RE).
v. RE may be required to submit audit report(s) to verify the
implementation of committee’s recommendations.
3.8.2. Review by SEBI
i. If the matter is not required to be put up for the review of HPSC-CS,
SEBI will examine the same (on the basis of the documents submitted by the RE).
ii. Further, if it is determined that the incident occurred on account of
non-compliance of SEBI cybersecurity framework/ advisories, appropriate regulatory action may be taken by SEBI on the RE notwithstanding any action levied above.
iii. RE shall formulate a remediation and mitigation plan. The timelines
for implementation of the measures shall also be decided based on the discussions (between SEBI and RE).
3.9. In case the recommendations are not implemented by the RE within the
prescribed timeline, appropriate regulatory action may be taken by SEBI.
4. Forensic Investigation/ Audit
4.1.For all incidents classified as High or Critical, the RE shall submit a forensic audit/ investigation report. 4.2.For incidents classified as low or medium, forensic report shall be submitted if the RCA is inconclusive or if the SEBI/ HPSC-CS directs the same. 4.3.After the completion of forensic audit, RE shall submit a final closure report, which shall include the root cause of the incident, its impact and measures to prevent recurrence. The timeline for submission of the reports (including closure reports), shall be decided based on discussion with all stakeholders. However, the maximum period for the submission of forensic audit report shall be 75 days from date of reporting of incident.
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In case the report is not submitted by the RE within the prescribed timeline, an appropriate regulatory action may be taken by SEBI. 4.4.For all the issues/ observations submitted in the forensic report, the RE shall provide a timeline for fixing the same. This timeline shall be submitted along with the forensic investigation/ audit report. Once the issues are resolved, the RE shall file a closure report for the same after review (of the report) by respective IT Committee for REs. 4.5.In case the issues are not fixed within the prescribed timeline, appropriate regulatory action may be taken by SEBI as deemed fit depending on the nature of incident.
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Annexure-P: Reporting Format for Self-certification REs REPORTING FORMAT FOR SELF-CERTIFICATION REs TO SUBMIT THEIR COMPLIANCE WITH APPLICABLE CSCRF PROVISIONS NAME OF THE ORGANISATION: <Name> ENTITY TYPE: <Intermediary Type> ENTITY CATEGORY: <Category of the RE as per CSCRF> RATIONALE FOR THE CATEGORY: <> PERIOD: <> RE’s Authorised signatory declaration:
I/ We hereby confirm that implementation of all applicable CSCRF provisions have been verified by me/ us and I/ We shall take the responsibility and ownership of this self-certification. Signature:
Name of the signatory:
Designation (choose whichever applicable): <MD/ CEO/ Board member/ Partners/ Proprietor> Company stamp:
Annexures:
VAPT report as submitted by the auditor
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Amended 4 times · last 2025-06-30
Source: Securities and Exchange Board of India — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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