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Market intermediaries

SEBI CSCRF Compliance for Regulated Entities

CSCRF consolidated a decade of scattered SEBI cyber circulars into one framework, with obligations scaling by the RE category SEBI assigns. The Cyber Capability Index turns it from a checklist into a scored audit instrument.

What SEBI CSCRF requires of market intermediaries

  • RE category confirmed in writing by your Stock Exchange or Depository — it determines every obligation below.
  • Cyber Capability Index self-assessment you can reproduce, with the working, not just the score.
  • SOC coverage via your own SOC, a market/shared C-SOC, or a managed provider — with evidence of alert triage.
  • Incident reporting to SEBI and CERT-In on separate clocks; the six-hour CERT-In window starts at detection.
  • VAPT with retest, and demonstrable recovery against stated RTO.

Evidence assessors actually ask for

Documentation is rarely the blocker — evidence that controls genuinely operate is. These are the artefacts requested first in this sector.

  • Category confirmation from the exchange or depository
  • CCI working papers and board consideration of the result
  • SOC alert samples worked end to end
  • VAPT report and the retest confirming closure
  • A dated restoration test with timings against RTO

Where market intermediaries usually come unstuck

  • Self-certifying a higher CCI than the evidence supports.
  • Conflating the SEBI and CERT-In reporting clocks.
  • A recovery objective that has never been proven by an actual restoration.

Related

SEBI CSCRF auditCSCRF checklistFinancial servicesCSCRF guide
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