SEBI CSCRF Compliance Services
Secure India's Securities Market Infrastructure
India's securities market infrastructure forms the backbone of the nation's financial system, facilitating trillions of rupees in daily transactions across stocks, bonds, derivatives, and other financial instruments. As financial markets increasingly digitize and threats to financial infrastructure intensify, robust cybersecurity and cyber resilience have become critical imperatives. The Securities and Exchange Board of India (SEBI) has established the Cyber Security and Cyber Resilience Framework (CSCRF) as the comprehensive regulatory framework for cybersecurity in India's securities market. SEBI CSCRF is mandatory for all Market Infrastructure Institutions (MIIs) and Stock Brokers, providing detailed requirements for cybersecurity governance, risk management, security controls, incident management, and cyber resilience. The framework addresses the unique security challenges facing securities market entities including high-value financial transactions requiring strong authentication and fraud prevention, real-time trading systems demanding high availability and performance, interconnected market infrastructure creating systemic risks, sophisticated cyber threats targeting financial institutions, regulatory reporting and compliance obligations, protection of investor data and confidentiality, and business continuity requirements for critical financial infrastructure. SEBI CSCRF establishes 17 comprehensive control areas covering cybersecurity governance, cybersecurity strategy, risk management, asset management, data security and privacy, access control, cryptography, security testing, security operations, network security, application security, endpoint security, cloud security, third-party risk management, incident response, business continuity, and security awareness. At Glocert International, we provide expert SEBI CSCRF compliance assessment and implementation services to help securities market entities meet regulatory requirements. Whether you're a stock exchange, depository, clearing corporation, or stockbroker, our experienced team guides you through CSCRF readiness assessment, gap analysis and remediation planning, security control implementation, policy and procedure development, and annual compliance audits and certifications. Partner with Glocert International to achieve SEBI CSCRF compliance, meet regulatory requirements, protect market infrastructure and investor assets, and build robust cyber resilience in India's financial markets.
What is SEBI CSCRF?
The SEBI Cyber Security and Cyber Resilience Framework (CSCRF) is the comprehensive regulatory framework established by the Securities and Exchange Board of India to strengthen cybersecurity and resilience of securities market infrastructure. Originally issued in 2018 and periodically updated, CSCRF is mandatory for Market Infrastructure Institutions (Stock Exchanges, Clearing Corporations, Depositories) and Stock Brokers/Trading Members.
SEBI CSCRF recognizes that securities markets are critical national infrastructure requiring the highest levels of cybersecurity protection. The framework establishes detailed requirements across 17 control areas, providing specific controls, implementation guidance, and compliance verification mechanisms. CSCRF takes a risk-based, defense-in-depth approach emphasizing preventive controls, detective capabilities, and resilience measures.
SEBI CSCRF Background and Evolution
SEBI developed CSCRF in response to:
- Growing Cyber Threats: Increasing sophistication and frequency of attacks targeting financial institutions globally
- Market Digitalization: Rapid adoption of technology and electronic trading creating new attack surfaces
- Systemic Risk: Interconnected market infrastructure where one breach can cascade across the ecosystem
- Investor Protection: Need to protect investor assets and data from cyber threats
- International Standards: Alignment with global best practices for financial sector cybersecurity
SEBI continues to update CSCRF based on evolving threats, technological changes, and lessons from cyber incidents.
Who Must Comply with SEBI CSCRF?
CSCRF compliance is mandatory for:
- Market Infrastructure Institutions (MIIs):
- Stock Exchanges (NSE, BSE, MCX, etc.)
- Clearing Corporations (NSCCL, ICCL, etc.)
- Depositories (NSDL, CDSL)
- Depository Participants (DPs)
- Stock Brokers and Trading Members:
- Stock Brokers registered with SEBI
- Trading Members of exchanges
- Depository Participants
- System Auditors: Entities conducting CSCRF audits must be empaneled by SEBI
- Third-Party Service Providers: Vendors providing critical services to MIIs and brokers must meet applicable CSCRF requirements
Different entities have different compliance tiers based on size, risk, and systemic importance. Market Infrastructure Institutions typically face the most stringent requirements as critical infrastructure.
SEBI CSCRF Structure
CSCRF is organized into 17 control areas with specific controls under each:
- Governance and Strategy: Cybersecurity governance, board oversight, security strategy
- Risk Management: Cyber risk assessment, treatment, monitoring
- Technical Controls: Network, application, endpoint, cloud security
- Operational Controls: Security operations, incident response, business continuity
- Organizational Controls: Policies, awareness, third-party management
SEBI CSCRF Regulatory Authority
CSCRF is governed and enforced by:
- Securities and Exchange Board of India (SEBI): Primary regulatory authority for securities markets
- SEBI Cyber Security Cell: Specialized unit monitoring cybersecurity in securities markets
- CERT-Fin: Computer Emergency Response Team for financial sector (coordination)
- Ministry of Finance: Oversight of financial sector cybersecurity
CSCRF Compliance Verification
SEBI requires:
- Annual CSCRF Audits: By empaneled System Auditors
- Quarterly Compliance Reporting: To SEBI on security posture and incidents
- Incident Reporting: Immediate notification of significant cyber incidents
- On-Site Inspections: SEBI may conduct inspections and assessments
- Board Certifications: Board-level certification of CSCRF compliance
Why SEBI CSCRF Compliance Matters
CSCRF compliance is essential for securities market entities:
1. Regulatory Mandate and License Maintenance
SEBI CSCRF is not optional—it is a regulatory requirement for operating in India's securities markets. SEBI expects full compliance from Market Infrastructure Institutions and Stock Brokers. Non-compliance can result in severe consequences including monetary penalties up to ₹25 crore under SEBI Act, suspension of trading or operational privileges, license revocation or cancellation, mandatory security improvements and re-audits, increased regulatory oversight and inspections, public disclosure of non-compliance, restrictions on business expansion and new products, and reputational damage affecting market position. For Market Infrastructure Institutions, CSCRF compliance is critical to maintaining status as critical financial infrastructure. For Stock Brokers, compliance affects ability to attract and retain clients increasingly focused on cybersecurity.
2. Protection of Market Infrastructure
Securities market infrastructure processes high-value, time-sensitive transactions that are attractive targets for cybercriminals and state-sponsored actors. Threats include:
- Trading System Attacks: Manipulation of trading platforms, order spoofing, unauthorized transactions
- DDoS Attacks: Disruption of trading, clearing, or settlement systems
- Data Breaches: Theft of investor data, trading strategies, sensitive financial information
- Insider Threats: Malicious or negligent employees with access to critical systems
- Ransomware: Encryption of trading data or systems demanding ransom
- Supply Chain Attacks: Compromise through third-party vendors and service providers
- Market Manipulation: Cyber-enabled fraud and market manipulation schemes
CSCRF controls provide defense-in-depth protection against these threats, reducing likelihood and impact of successful attacks.
3. Investor Protection and Trust
Investors entrust securities market entities with their assets and sensitive financial information. CSCRF compliance ensures protection of investor funds and assets, confidentiality of trading strategies and positions, privacy of personal and financial information, integrity of account data and transactions, and availability of trading and account access systems. Cybersecurity breaches severely damage investor confidence. High-profile incidents have caused investors to withdraw assets, switch brokers, and avoid affected markets. CSCRF compliance demonstrates commitment to protecting investor interests, building trust that supports market participation and liquidity.
4. Systemic Risk Mitigation
Securities markets are highly interconnected ecosystems where participants depend on each other for smooth functioning. A cyber incident at one institution can cascade throughout the system affecting stock exchanges using same infrastructure, clearing corporations settling trades, depositories holding securities, brokers executing orders, and investors accessing accounts. CSCRF's focus on resilience and coordination helps prevent single points of failure, establish backup systems and redundancies, enable rapid incident response across ecosystem, and maintain market operations during cyber events. Systemic cyber risk represents significant threat to financial stability. CSCRF compliance reduces this risk protecting India's broader financial system.
5. Business Continuity and Operational Resilience
Securities markets cannot tolerate extended downtime. Trading must continue, settlements must process, and investors must access accounts. CSCRF business continuity and cyber resilience requirements ensure critical trading systems remain available, data backups enable rapid recovery, disaster recovery sites provide redundancy, incident response capabilities contain and resolve issues quickly, and alternative communication channels maintain operations. Organizations with strong CSCRF compliance experience shorter outages, faster recovery from incidents, and minimal business disruption, protecting revenue and market position.
6. Competitive Advantage in Market
As cybersecurity awareness grows, investors and institutional clients increasingly evaluate security when selecting brokers and trading platforms. Strong CSCRF compliance provides competitive advantages including enhanced reputation for security and reliability, ability to attract security-conscious institutional clients, confidence from foreign institutional investors (FIIs), reduced cyber insurance premiums, ability to offer innovative digital services securely, and marketing differentiation based on security credentials. Brokers and exchanges with strong security posture win business from security-conscious clients, while those with poor security lose clients and opportunities.
7. Prevention of Financial Losses
Cyber incidents in securities markets can result in massive financial losses including:
- Direct Financial Theft: Unauthorized transactions, fraudulent fund transfers
- Trading Losses: From manipulated orders or erroneous trades
- Regulatory Fines: From SEBI and other authorities
- Incident Response Costs: Forensics, remediation, system recovery
- Legal Liabilities: Lawsuits from affected investors
- Reputational Damage: Client attrition and lost business
- Operational Downtime: Lost trading revenue during system unavailability
CSCRF compliance represents investment in prevention substantially less expensive than incident costs. The framework's risk-based approach ensures resources focus on protecting highest-value assets and most critical systems.
8. Alignment with Global Standards
SEBI CSCRF aligns with international financial sector cybersecurity standards including:
- ISO 27001: Information security management
- NIST Cybersecurity Framework: US cybersecurity framework widely adopted globally
- COBIT: IT governance framework
- PCI DSS: Payment card industry security (for card-linked accounts)
- G7 Fundamental Elements: G7 cyber elements for financial sector
This alignment enables entities serving international clients to leverage CSCRF compliance for multiple frameworks, demonstrate security to foreign partners and investors, adopt global best practices, and support international expansion strategies.
Our SEBI CSCRF Compliance Services
Glocert International provides comprehensive SEBI CSCRF compliance services for Market Infrastructure Institutions, Stock Brokers, and securities market participants.
CSCRF Readiness Assessment
We conduct comprehensive readiness assessments evaluating your current cybersecurity posture against all 17 CSCRF control areas. Our assessment identifies gaps, evaluates control maturity, determines compliance tier readiness, and provides prioritized remediation roadmap. We deliver detailed report documenting findings, risk ratings, and implementation recommendations aligned with your entity type and systemic importance.
Gap Analysis and Remediation Planning
We provide detailed gap analysis mapping current state to required CSCRF controls, identifying missing or inadequate controls, assessing control effectiveness, and prioritizing remediation based on risk and regulatory requirements. We develop practical, phased remediation plans with timelines, resource requirements, quick wins and strategic initiatives, and minimal business disruption during implementation.
Cybersecurity Control Implementation
We assist with implementing required CSCRF controls across all 17 areas including governance structures and CISO appointment, risk management frameworks, network segmentation and security architecture, application security and secure coding, endpoint protection and device management, cloud security controls, cryptographic implementations, security monitoring and SIEM, incident response capabilities, and business continuity and disaster recovery. We provide technical expertise, vendor selection guidance, and implementation best practices.
Policy and Procedure Development
We develop comprehensive cybersecurity policies and procedures required by CSCRF including information security policy, cybersecurity strategy document, risk management framework, incident response plan, business continuity and disaster recovery plans, third-party risk management policy, acceptable use policy, access control policy, and control area-specific procedures. Documentation is tailored to your organization meeting SEBI requirements while being practical and implementable for trading floor operations.
Cyber Risk Assessment
We conduct formal cyber risk assessments meeting CSCRF requirements including asset identification and valuation of trading systems, threat analysis for financial sector, vulnerability assessment including technical testing, risk evaluation and scoring, risk treatment planning, and residual risk documentation and acceptance. We use industry-standard risk methodologies adapted for securities market context and deliver comprehensive risk registers meeting SEBI expectations.
Security Testing and Assessment
We provide security testing services required by CSCRF including vulnerability assessments and penetration testing, web application security testing, mobile application security assessment, API security testing, social engineering and phishing simulations, red team exercises, and security code reviews. Testing follows CSCRF timelines and methodologies providing evidence for annual audits.
Security Awareness and Training
We provide comprehensive security awareness training meeting CSCRF requirements including general awareness for all employees, specialized training for IT and security staff, CSCRF compliance training for leadership, trading floor security protocols, phishing and social engineering awareness, incident reporting procedures, and data protection and confidentiality. Training is customized for securities market context with financial examples and regulatory considerations.
Annual CSCRF Audit Support
We support your annual CSCRF audit by empaneled System Auditors including pre-audit readiness assessment, evidence collection and documentation, control effectiveness demonstrations, remediation of identified issues, liaison with System Auditor, and SEBI reporting support. Our preparation ensures smooth audits and favorable outcomes minimizing findings and corrective actions.
Ongoing Compliance Monitoring
We help establish ongoing compliance monitoring including security dashboards and metrics, quarterly self-assessments, control effectiveness monitoring, incident tracking and reporting to SEBI, vulnerability management, and continuous improvement processes. Sustained compliance requires ongoing attention ensuring controls remain effective and documentation stays current as systems and threats evolve.
SEBI CSCRF 17 Control Areas
CSCRF organizes cybersecurity controls into 17 comprehensive areas:
1. Cyber Security Governance
Establishes governance structure including board oversight, CISO appointment, security steering committee, security policies, and integration with enterprise governance. Board must approve cybersecurity strategy and receive regular updates.
2. Cyber Security Strategy
Requires documented cybersecurity strategy aligned with business objectives, defining security vision, objectives, initiatives, resources, and timelines. Strategy must address emerging threats and technology changes.
3. Cyber Risk Management
Comprehensive risk management including risk assessment methodology, asset identification, threat and vulnerability analysis, risk evaluation and treatment, continuous risk monitoring, and risk reporting to board and SEBI.
4. Cyber Asset Management
Complete inventory of IT assets including hardware, software, data, networks. Asset classification based on criticality and sensitivity. Lifecycle management from procurement to secure disposal.
5. Data Security and Privacy
Protection of investor data and trading information through data classification, encryption, access controls, data masking, secure data transfer, data retention and disposal, and privacy controls aligned with data protection regulations.
6. Access Control
User access management including unique user IDs, strong authentication (multi-factor for privileged accounts), role-based access control, least privilege principle, access reviews, and segregation of duties preventing fraud.
7. Cryptography
Cryptographic controls for data protection including encryption algorithms and key lengths, key management lifecycle, digital signatures, secure protocols (TLS 1.2+), hardware security modules (HSMs) for key storage, and compliance with RBI/government crypto standards.
8. Cyber Security Testing
Mandatory security testing including annual vulnerability assessments, penetration testing (external and internal), web/mobile application security testing, social engineering tests, and remediation of findings within specified timeframes.
9. Cyber Security Operations
Security operations center (SOC) capabilities including 24/7 security monitoring, SIEM for log analysis, threat intelligence, malware protection, patch management, vulnerability management, and security baselines.
10. Network Security
Network protection including firewalls, intrusion detection/prevention systems (IDS/IPS), network segmentation separating trading from corporate networks, DMZ for external connections, VPN for remote access, DDoS protection, and network monitoring.
11. Application Security
Secure software development lifecycle (SDLC) including security requirements, threat modeling, secure coding practices, code reviews, security testing during development, change management, and security in DevOps (DevSecOps).
12. Endpoint Security
Protection of workstations, laptops, mobile devices including endpoint detection and response (EDR), antivirus/anti-malware, device encryption, mobile device management (MDM), USB/removable media controls, and secure remote work capabilities.
13. Cloud Security
Security for cloud services and applications including cloud security architecture, data protection in cloud, cloud access security broker (CASB), cloud configuration management, cloud audit and compliance, and vendor management for cloud providers.
14. Third Party Cyber Risk Management
Vendor and partner security including vendor risk assessments, security requirements in contracts, vendor security monitoring, fourth-party risk (vendor's vendors), incident notification requirements, and supply chain security.
15. Cyber Incident Response Management
Incident response capabilities including documented incident response plan, incident detection and triage, incident classification, containment and eradication, recovery procedures, post-incident review, and reporting to SEBI within required timeframes.
16. Cyber Crisis Management and Cyber Resilience (Business Continuity)
Business continuity and disaster recovery including business impact analysis, continuity plans for critical trading systems, disaster recovery sites and capabilities, data backup and recovery, annual BC/DR testing, and crisis management procedures.
17. Cyber Security Awareness and Training
Security awareness program including annual training for all employees, specialized training for IT/security staff, phishing simulations, security awareness campaigns, incident reporting training, and documented training records.
SEBI CSCRF Compliance Tiers
SEBI defines compliance tiers based on entity type and systemic importance:
| Tier | Entities | Requirements |
|---|---|---|
| Tier 1: Market Infrastructure Institutions | Stock Exchanges, Clearing Corporations, Depositories | Most stringent requirements. All 17 control areas fully implemented. Dedicated CISO. 24/7 SOC. Advanced security capabilities. |
| Tier 2: Large Stock Brokers | Brokers with client assets >₹1,000 crore or significant retail base | Comprehensive requirements. All 17 areas with some flexibility. CISO or security head. Robust security program. |
| Tier 3: Medium Stock Brokers | Brokers with moderate client base and assets | Core controls across all areas. Risk-based implementation. Designated security personnel. Essential security capabilities. |
| Tier 4: Small Stock Brokers | Brokers with limited client base and assets | Baseline controls. Foundational security. May outsource some capabilities. Proportionate to size and risk. |
Tier Assignment: SEBI assigns tiers based on client asset size, number of clients, trading volumes, systemic importance, and nature of business (institutional vs. retail). Higher tiers face stricter requirements, more frequent audits, and enhanced reporting obligations. All tiers must demonstrate compliance through annual System Auditor certification.
Benefits of SEBI CSCRF Compliance:
Regulatory Compliance
Meets mandatory SEBI requirements, maintains securities license, avoids penalties, and ensures continued market access.
Market Protection
Protects trading infrastructure, investor assets, and market integrity from cyber threats and attacks.
Investor Confidence
Builds trust with investors through demonstrated security commitment, attracting and retaining clients.
Cyber Resilience
Ensures business continuity, rapid incident recovery, and operational resilience during cyber events.
SEBI CSCRF Services Pricing
Our SEBI CSCRF services pricing is transparent and based on your entity type, tier, complexity, and current security maturity. We offer competitive rates with no hidden fees.
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Get a personalized estimate based on your entity type, compliance tier, and CSCRF requirements.
Contact Us for PricingWhat's Included in CSCRF Pricing:
- Comprehensive readiness assessment across all 17 control areas
- Current state evaluation and tier-appropriate requirements
- Detailed gap analysis and findings report
- Cyber risk assessment and risk register
- Remediation roadmap and implementation plan
- Policy and procedure development/review
- Security control implementation guidance
- Security testing (VA/PT) coordination
- Staff training and awareness programs
- Annual audit preparation and support
- SEBI reporting assistance
- Ongoing compliance consulting
Note: SEBI CSCRF services pricing varies based on entity type (MII vs. Stock Broker), compliance tier (Tier 1-4), size and number of locations, IT infrastructure complexity, number of systems and applications, current security maturity level, whether seeking initial compliance or annual audit support, and level of implementation assistance required. Contact us for a detailed, no-obligation quote tailored to your specific securities market entity needs.
Frequently Asked Questions (FAQ)
Find answers to common questions about SEBI CSCRF compliance:
SEBI CSCRF (Cyber Security and Cyber Resilience Framework) is the comprehensive cybersecurity regulatory framework established by Securities and Exchange Board of India for securities market entities. CSCRF is mandatory for Market Infrastructure Institutions (Stock Exchanges, Clearing Corporations, Depositories) and Stock Brokers/Trading Members. The framework comprises 17 control areas covering governance, strategy, risk management, technical controls, operations, and resilience. CSCRF is mandatory because securities markets are critical financial infrastructure processing high-value transactions, attractive targets for sophisticated cyber threats, interconnected systems where incidents can cascade, holders of sensitive investor data and assets, and subject to high regulatory expectations. SEBI requires compliance for licensing and operation with enforcement through annual audits by empaneled System Auditors, quarterly compliance reporting, penalties for non-compliance up to ₹25 crore, and potential license suspension/revocation. CSCRF protects market integrity, investor assets, and systemic stability of India's financial markets.
CSCRF compliance is mandatory for: Market Infrastructure Institutions (MIIs): Stock Exchanges (NSE, BSE, MCX, etc.), Clearing Corporations (NSCCL, ICCL, etc.), Depositories (NSDL, CDSL), and Depository Participants. Stock Brokers and Trading Members: All stock brokers registered with SEBI, trading members of exchanges, and depository participants. System Auditors: Entities conducting CSCRF audits must be empaneled by SEBI. Third-Party Service Providers: Vendors providing critical services to MIIs and brokers must meet applicable requirements. Different entities have different compliance tiers: MIIs face most stringent Tier 1 requirements as critical infrastructure. Large brokers (client assets >₹1,000 crore) face Tier 2 requirements. Medium and small brokers face Tier 3 and Tier 4 requirements proportionate to size and risk. All tiers must comply with core CSCRF controls appropriate to their risk profile and systemic importance. Compliance is verified through annual System Auditor certification submitted to SEBI.
SEBI CSCRF organizes cybersecurity controls into 17 areas: 1. Cyber Security Governance - board oversight, CISO, policies. 2. Cyber Security Strategy - documented security strategy. 3. Cyber Risk Management - risk assessment and treatment. 4. Cyber Asset Management - asset inventory and lifecycle. 5. Data Security and Privacy - data protection controls. 6. Access Control - user access management. 7. Cryptography - encryption and key management. 8. Cyber Security Testing - VA/PT and security assessments. 9. Cyber Security Operations - SOC and security monitoring. 10. Network Security - firewalls, IDS/IPS, segmentation. 11. Application Security - secure SDLC. 12. Endpoint Security - workstation and device protection. 13. Cloud Security - cloud controls and management. 14. Third Party Cyber Risk Management - vendor security. 15. Cyber Incident Response Management - incident response capabilities. 16. Cyber Crisis Management and Resilience - BC/DR planning. 17. Cyber Security Awareness and Training - security training programs. Each area contains specific controls and implementation requirements detailed in SEBI CSCRF guidelines.
CSCRF implementation timeline varies based on entity characteristics: Small Brokers (Tier 4): 6-9 months for basic compliance with outsourced capabilities. Medium Brokers (Tier 3): 9-15 months for comprehensive controls. Large Brokers (Tier 2): 12-18 months for advanced security program. Market Infrastructure Institutions (Tier 1): 18-36 months for complete implementation of stringent requirements. Factors affecting timeline: Current security maturity and existing controls, IT infrastructure complexity and legacy systems, trading platform architecture, availability of security resources and budget, entity size and number of locations, leadership commitment and prioritization, and whether building capability in-house or outsourcing. Typical phases: Readiness assessment and gap analysis (4-8 weeks), remediation planning (2-4 weeks), control implementation (9-24 months depending on gaps), policy and procedure development (3-6 months, parallel), security testing (quarterly/annually), staff training (ongoing), System Auditor certification (6-8 weeks). Organizations with mature security programs achieve compliance faster. Early planning and phased approach optimize timeline and minimize trading floor disruption.
SEBI enforces CSCRF compliance strictly with serious consequences for non-compliance: Monetary Penalties: Up to ₹25 crore under Section 15A of SEBI Act for non-compliance. Amounts vary based on violation severity. Regulatory Actions: Warning letters and compliance orders, mandatory corrective action plans with deadlines, increased audit frequency and oversight, restrictions on business expansion and new products, and public disclosure of non-compliance status. Operational Restrictions: Suspension of trading or operational privileges, limitations on client onboarding, restrictions on technology changes. License Actions: License suspension for serious violations, license cancellation for persistent non-compliance. Incident-Based Penalties: Enhanced penalties if cyber incident resulted from CSCRF non-compliance, liability for investor losses, mandatory breach notification and remediation. Reputational Damage: Public reporting affecting client confidence, negative media coverage, loss of institutional clients. SEBI takes progressive approach: education and guidance initially, compliance deadlines and reminders, warnings for gaps, escalating penalties for continued non-compliance, license actions for serious or persistent violations. Early and ongoing compliance demonstrates commitment to investor protection and market integrity, avoiding enforcement actions that can be devastating for securities market entities.
CISO requirements vary by compliance tier: Tier 1 (MIIs): Dedicated Chief Information Security Officer (CISO) mandatory. Must be senior executive reporting to Board/CEO. Full-time dedicated role. Responsible for entire cybersecurity program. Cannot have conflicting responsibilities (e.g., also head IT operations). Tier 2 (Large Brokers): CISO or designated security head required. May have dual responsibilities if entity is smaller but must have clear security accountability. Tier 3-4 (Medium/Small Brokers): Designated security personnel/officer required. May be IT head with security responsibilities. Can outsource some security functions but accountability remains internal. CISO Qualifications: Relevant cybersecurity certifications (CISSP, CISM, etc.), experience in financial sector security preferred, understanding of trading operations and market infrastructure, and knowledge of SEBI regulations and CSCRF. CISO Responsibilities: Developing and implementing cybersecurity strategy, managing security operations and incident response, conducting risk assessments, ensuring CSCRF compliance, reporting to Board and SEBI, managing security budget and resources, and overseeing third-party security. Small brokers unable to hire dedicated CISO can engage virtual CISO (vCISO) services providing part-time expertise and compliance support.
CSCRF mandates regular security testing: Annual Requirements: External vulnerability assessment and penetration testing (VAPT), internal vulnerability assessment, web application security testing for client-facing portals and trading platforms, mobile application security testing, social engineering and phishing simulations, and security code reviews for critical applications. Additional Testing: Network security assessment, configuration reviews, wireless security testing, API security testing, and database security assessment. Testing Frequency: Annual minimum for all required tests. Quarterly vulnerability scans recommended. After major system changes or incidents. Before launching new trading platforms or services. Scope: All systems processing investor transactions, client-facing applications and portals, trading infrastructure and connectivity, data centers and DR sites, and third-party connections and APIs. Remediation: Critical findings: immediate remediation required. High findings: remediate within 30 days. Medium/Low: remediate based on risk. Tracked through next audit cycle. Documentation: Testing reports provided to System Auditor, remediation evidence for audit, quarterly reporting to SEBI on vulnerabilities and fixes. Testing must be conducted by qualified security professionals or empaneled security testing firms. Evidence of testing and remediation is key requirement for annual CSCRF certification.
CSCRF Control Area 14 (Third Party Cyber Risk Management) addresses vendor security comprehensively: Vendor Risk Assessment: Security assessment before engagement, evaluation of vendor's security controls and certifications, assessment of vendor's own third parties (fourth-party risk), ongoing risk evaluation during relationship. Contractual Requirements: Security obligations in vendor contracts, data protection and confidentiality clauses, incident notification requirements (within 6 hours of detection), audit rights and compliance verification, liability and indemnification terms, termination provisions for security breaches. Vendor Categories: Critical vendors (trading platforms, connectivity providers) - highest scrutiny. Data processors (KYC, back-office) - data protection focus. IT infrastructure (cloud, hosting) - security controls verification. Other vendors - risk-based assessment. Vendor Monitoring: Periodic security questionnaires and assessments, review of vendor audit reports (SOC 2, ISO 27001), monitoring of vendor security incidents, evaluation of vendor security improvements. Data Sharing: Data minimization with vendors, encryption of data shared with vendors, access controls and authentication, secure data transmission protocols, data deletion after engagement ends. Securities entities remain responsible for vendor security - outsourcing doesn't transfer CSCRF accountability. Strong third-party risk management essential as vendor breaches can compromise trading infrastructure and investor data.
CSCRF establishes strict incident reporting requirements: Reportable Incidents: Any breach or suspected breach of trading systems, unauthorized access to investor data or accounts, malware or ransomware affecting operations, DDoS attacks impacting trading availability, data breaches exposing client information, fraud or financial theft, significant system outages from security issues, and attempted attacks with potential impact. SEBI Reporting Timeline: Immediate notification (within 6 hours) of incident detection for critical incidents affecting trading or investor assets. Detailed report within 24 hours with incident analysis. Follow-up reports during investigation and remediation. Final incident report within 7 days with root cause, impact, and corrective actions. Report Contents: Incident timeline and detection method, systems and data affected, number of clients impacted, financial impact and losses, incident response actions taken, forensic investigation findings, root cause analysis, corrective and preventive measures, and lessons learned. Internal Reporting: Immediate escalation to CISO and management, board notification for major incidents, documentation in incident register. Other Reporting: Stock exchange notification if trading affected, CERT-In notification for certain incident types, law enforcement for fraud/theft. Timely, accurate incident reporting critical for regulatory compliance. Failure to report or delayed reporting leads to enhanced penalties. Incident reporting demonstrates transparency and commitment to addressing security issues.
Glocert International provides comprehensive SEBI CSCRF services: Readiness assessment evaluating current state across all 17 control areas and determining tier-appropriate requirements; Gap analysis identifying missing or inadequate controls with prioritized remediation roadmap; Cyber risk assessment meeting CSCRF risk management requirements; Control implementation support across technical, operational, and organizational domains; Policy and procedure development creating required CSCRF documentation; Security testing coordination managing VA/PT and security assessments; Security awareness training for trading floor and back-office staff; Annual audit preparation supporting System Auditor certification; SEBI reporting assistance for quarterly compliance and incident reporting; and Ongoing compliance monitoring maintaining readiness. Our team brings financial sector cybersecurity expertise, securities market operational understanding, SEBI regulatory knowledge, experience with MIIs and brokers, technical security assessment capabilities, and practical implementation guidance. We've supported stock exchanges, brokers, and depositories through successful CSCRF compliance. We serve as your partner ensuring efficient compliance, minimal trading disruption, and robust cyber resilience protecting India's securities markets.
Why Choose Glocert for SEBI CSCRF Compliance?
Financial Sector Cybersecurity Expertise
Glocert International specializes in financial sector cybersecurity, bringing deep expertise in securities market technology and operations, financial services threat landscape, trading platform security, market infrastructure protection, regulatory compliance in financial sector, and investor data protection. We understand both cybersecurity technical requirements and securities market operational realities including trading floor dynamics, high-frequency trading systems, settlement operations, and regulatory reporting. Our experience ensures implementations protect market operations while meeting SEBI requirements.
SEBI CSCRF Regulatory Knowledge
Our team has specific expertise in SEBI CSCRF framework and requirements, securities market regulations and compliance, SEBI enforcement approach and expectations, System Auditor certification process, incident reporting to SEBI, and relationships with empaneled System Auditors. We stay current with SEBI circulars, updates, and guidance ensuring our clients meet latest requirements. Our regulatory knowledge helps navigate complex compliance landscape efficiently.
Comprehensive Service Portfolio
Glocert offers complete CSCRF services including readiness assessments and gap analysis, cyber risk assessment and risk registers, security control implementation across all 17 areas, policy and procedure development, security testing (VA/PT) services, security operations center (SOC) setup, incident response planning and exercises, business continuity and disaster recovery planning, security awareness training programs, annual System Auditor audit preparation, SEBI reporting support, and ongoing compliance monitoring and consulting. We also provide ISO 27001 certification, PCI DSS compliance, and financial sector penetration testing enabling comprehensive financial cybersecurity programs.
Practical, Risk-Based Implementation
We understand securities entities operate in fast-paced, competitive environments with tight margins. Our approach emphasizes practical, implementable solutions balancing security and trading operations, risk-based prioritization addressing systemic risks first, cost-effective compliance maximizing value from security investments, minimal disruption to trading floor and client services, phased implementation aligned with business cycles, and sustainable security programs requiring reasonable ongoing effort. We partner with you to build cyber resilience protecting markets and investors while supporting business growth.
Related Services
Securities market entities often need complementary services. Glocert International also provides ISO 27001 certification for information security management, PCI DSS compliance for payment card processing, SOC 2 audits for service organization controls, financial sector penetration testing, cloud security assessments, and application security testing. We coordinate multiple engagements for comprehensive financial cybersecurity efficiently addressing CSCRF alongside other regulatory and security requirements.
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