Executive Summary
RBI-regulated NBFCs face examination on the quality and traceability of their cyber-security evidence, not just the existence of policies. This case (client name withheld under NDA) shows how CyberSigma turned fragmented controls into an examination-ready programme aligned to the RBI Cyber Security Framework.
Client Overview
The client is a mid-size NBFC operating across India with digital lending and collections. Leadership needed to be examination-ready against the RBI Cyber Security Framework and IS audit expectations.
- Industry: NBFC / BFSI
- Region: India
- Scope: RBI Cyber Security Framework, IS audit, VAPT
Challenge
The NBFC faced an upcoming RBI inspection with inconsistent evidence, gaps against the Cyber Security Framework, and no structured IS audit trail.
- Gaps against the RBI Cyber Security Framework controls
- Weak, non-traceable evidence for examination
- No structured IS audit or VAPT submission history
- Unclear control ownership across teams
Objectives
- Achieve RBI Cyber Security Framework readiness
- Build examination-grade, traceable evidence
- Complete IS audit and VAPT with submission-ready reporting
- Establish control ownership and board reporting
Our Approach
1. Framework Gap Assessment
We mapped the RBI Cyber Security Framework controls to the NBFC environment and scored the gaps by risk and examination exposure.
2. Evidence & IS Audit
We built traceable evidence, ran the IS audit, and structured VAPT for RBI submission.
3. Remediation
Prioritised, developer-ready remediation with tracked SLAs until critical gaps were closed.
4. Examination Readiness
Board reporting, control ownership and an examination-ready documentation pack.
Solution
- Mapped RBI Cyber Security Framework controls to the environment and scored gaps by examination risk
- Built traceable, examination-grade evidence and ran the IS audit
- Structured VAPT for RBI submission with tracked remediation SLAs
- Established control ownership and board reporting
Results
- Closed priority gaps ahead of the RBI inspection
- Produced examination-grade, traceable evidence
- IS audit and VAPT completed with submission-ready reporting
- Clear control ownership and board-level reporting established
Timelines and outcomes reflect the documented engagement record for this client; results vary with scope and readiness.
What We Delivered
- Control-by-control gap assessment against the applicable RBI framework/Master Direction
- Examination-grade evidence pack with traceable control ownership
- IS audit execution and report in submission-ready form
- VAPT structured for regulatory submission with remediation tracking
- Board and senior-management reporting pack
The standard artefact set for this engagement type; per-client environment and architecture details are shared under NDA during procurement, not published.
Lessons Learned
- Examiners test evidence traceability, not policy existence — every control needed a named owner and a dated artefact trail before the inspection, not during it.
- The IS audit calendar drove everything: working backwards from the submission date left no room for remediation discovered late, so gaps were scored by examination exposure first.
- Control ownership spread across teams was the silent risk; the ownership matrix did more for inspection readiness than any single technical fix.
Talk to the team that ran this engagement
This was a real RBI Cyber Security Framework & IS Audit engagement. If you are preparing for the same, speak to a specialist who has delivered it — not a sales rep. We will give you a clear read on your scope, gaps and the fastest path, and reply within four business hours.
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