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CERT-In empanelled · BFSI audit practice

RBI cybersecurity audit for NBFCs

RBI’s Master Direction on Information Technology Governance, Risk, Controls and Assurance Practices (and the earlier IT-framework and outsourcing directions) require NBFCs to run independent IT and cyber-security audits sized to their scale. CyberSigma is a CERT-In empanelled auditor with a dedicated BFSI practice: we assess your IT governance, cyber-security controls, VAPT posture, third-party/outsourcing risk and business continuity against the applicable RBI direction, and give you an auditable, prioritised report your Board and RBI inspection can rely on.

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Who needs it

Which NBFCs this applies to

RBI applies IT-governance and cyber-security expectations on a graded, scale-based basis. Middle- and upper-layer NBFCs face the fullest requirements, but base-layer entities still need proportionate IT and information-security controls, and lenders in digital-lending arrangements carry specific obligations.

Scope

What the audit covers

IT governance & risk
Board oversight, IT strategy, policies, risk management and MIS.
Cyber-security controls
Access control, network security, logging/monitoring, patch and vulnerability management.
VAPT & resilience
Application and infrastructure testing, business continuity and disaster recovery.
Third-party & outsourcing
Vendor due diligence, cloud and digital-lending partner risk under RBI outsourcing norms.
Regulation

Applicable RBI directions

The RBI Cybersecurity, Technology: Risk, Resilience and Assurance Framework Directions, 2026 (which replaced the 2023 IT Governance Master Direction and the 2016 Cyber Security Framework); the Master Direction on Digital Payment Security Controls where relevant; RBI outsourcing directions; and the Digital Lending Directions, 2025 for lending partnerships.

Timeline & cost

Timeline and cost factors

Timeline
A focused NBFC audit typically runs 3–6 weeks depending on layer, systems and the number of outsourced/digital-lending arrangements.
Cost factors
NBFC layer and size, number of applications and third parties, whether VAPT is bundled, and remediation support scope.
Evidence & deliverables

What you provide and receive

Required evidence
Policies, access reviews, patch and vulnerability records, logs, BCP/DR tests, vendor contracts and prior audit closure evidence.
Deliverables
A Board-ready audit report mapped to the applicable RBI direction, a prioritised remediation plan, and closure retest evidence.
Common failures

Findings boards underestimate

  • Weak outsourcing/vendor governance for cloud and digital-lending partners
  • Incomplete logging and monitoring, and untested incident response
  • Access reviews and privileged-access controls not evidenced
  • BCP/DR documented but not tested against real recovery objectives
Proof

See how we’ve done it before

Relevant case study
How an NBFC closed RBI IT-audit gaps and evidenced Board-level assurance. Read case studies →
Redacted sample deliverable
Inspect a redacted audit report first. Request a redacted sample →

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Verified facts

Drawn from the CyberSigma Compliance Registry (updated 5 October 2026). Every statement below is checked against the issuing body’s own publication, with the date it was last verified.

  • IT Governance, Risk, Controls and Assurance Practices Directions (2023) - repealed 2026Effective 1 April 2024

    The Reserve Bank of India (Information Technology Governance, Risk, Controls and Assurance Practices) Directions, 2023 (RBI/2023-24/107), effective 1 April 2024, was a Master Direction that consolidated earlier RBI IT-governance and cyber-risk instructions and required a board-level IT governance framework, an IT and information-security risk management framework and periodic information systems audits. IMPORTANT - NO LONGER IN FORCE: this Master Direction was repealed on 31 July 2026 and replaced, together with the 2016 Cyber Security Framework and other circulars, by the entity-specific RBI (Cybersecurity, Technology: Risk, Resilience and Assurance Framework) Directions, 2026. Regulated entities must now comply with the applicable 2026 Directions (see 'rbi-cyber-tech-risk-framework-2026').

  • Cybersecurity, Technology: Risk, Resilience and Assurance Framework Directions (2026)Effective 31 July 2026

    The RBI (Cybersecurity, Technology: Risk, Resilience and Assurance Framework) Directions, 2026 are the current, in-force cyber and technology-risk directions for RBI-regulated entities. Issued on 31 July 2026 (Commercial Banks version: RBI/DoS/2026-27/410, DoS.CO.CSITEG.4/31.01.015/2026-27) and effective immediately with no transition window, they repealed and consolidated the 2016 Cyber Security Framework in Banks, the November 2023 IT Governance, Risk, Controls and Assurance Practices Master Direction and around 626 other circulars into a single framework. RBI issued separate, entity-specific Directions under this common title for commercial banks, small finance banks, payments banks, urban co-operative banks, all-India financial institutions, NBFCs and credit information companies. Core requirements include board oversight and an IT Strategy Committee, an independent CISO (GM rank), baseline cybersecurity controls, a 24x7 Cyber Security Operations Centre (C-SOC) with SIEM, risk-based information systems audit, VA at least every six months and penetration testing at least annually for critical and internet-facing systems, and reporting of cyber incidents to the RBI on the DAKSH platform within six hours of detection.

  • Cyber Security Framework in Banks (2016) - repealed 2026Effective 2 June 2016

    The RBI circular Cyber Security Framework in Banks (RBI/2015-16/418, DBS.CO/CSITE/BC.11/33.01.001/2015-16), dated 2 June 2016, required scheduled commercial banks to put in place a board-approved cyber-security policy distinct from their IT or IS-security policy, a baseline cyber-security and resilience framework, continuous surveillance (for example through a Security Operations Centre), a Cyber Crisis Management Plan and incident reporting to the RBI. IMPORTANT - NO LONGER IN FORCE: this circular was repealed on 31 July 2026 and replaced, together with the November 2023 IT Governance Master Direction and other circulars, by the entity-specific RBI (Cybersecurity, Technology: Risk, Resilience and Assurance Framework) Directions, 2026 (see 'rbi-cyber-tech-risk-framework-2026').

  • Master Direction on Digital Payment Security Controls (2021)Effective 18 February 2021

    The RBI Master Direction on Digital Payment Security Controls (RBI/2020-21/74, DoS.CO.CSITE.SEC.No.1852/31.01.015/2020-21), dated 18 February 2021, sets out a robust governance structure and common minimum standards of security controls for digital payment products and services. It covers areas such as internet banking, mobile banking and card payments, along with customer protection and grievance redressal. It applies to Scheduled Commercial Banks (excluding Regional Rural Banks), Small Finance Banks, Payments Banks and credit-card-issuing NBFCs, and took effect within six months of being placed on the RBI website.

  • Storage of Payment System Data (data localisation)Effective 6 April 2018

    The RBI circular on Storage of Payment System Data (RBI/2017-18/153, DPSS.CO.OD No.2785/06.08.005/2017-2018), dated 6 April 2018, requires all system providers to ensure that the entire data relating to the payment systems they operate is stored in a system only in India. This includes the full end-to-end transaction details and any information collected, carried or processed as part of the payment message or instruction. Providers were given six months to comply and to submit a System Audit Report conducted by a CERT-In empanelled auditor. It applies to all Payment System Providers authorised under the Payment and Settlement Systems Act, 2007.

  • Regulation of Payment Aggregators Directions, 2025Effective 31 December 2025

    The Reserve Bank of India (Regulation of Payment Aggregators) Directions, 2025 (RBI/DPSS/2025-26/141), issued 15 September 2025 and in force from 31 December 2025, consolidate the earlier 2020, 2021 and 2023 payment-aggregator guidelines into a single framework covering online and face-to-face (proximity) payment aggregators. A non-bank entity carrying on payment-aggregator business must obtain RBI authorisation, and must have a minimum net worth of INR 15 crore at the time of application, rising to a minimum net worth of INR 25 crore by the end of the third financial year after authorisation, maintained thereafter. The directions also cover governance, KYC of merchants, escrow-account operation, security and reporting.

  • Payment system data storage in IndiaEffective 6 October 2018

    RBI circular DPSS.CO.OD No.2785/06.08.005/2017-2018 (6 April 2018) requires payment system providers to store the entire data relating to their payment systems only in India, with compliance within six months (by October 2018). End-to-end transaction data is covered.

    Circular number cited for retrieval via RBI's notification search; we deliberately avoid deep-linking RBI's session-bound URLs.

  • IT Governance Master Direction (repealed 2026)Effective 1 April 2024

    Master Direction on Information Technology Governance, Risk, Controls and Assurance Practices (RBI/DoS/2023-24/107) issued 7 November 2023; effective 1 April 2024. NO LONGER IN FORCE: repealed on 31 July 2026 and replaced, with the 2016 Cyber Security Framework and other circulars, by the entity-specific RBI (Cybersecurity, Technology: Risk, Resilience and Assurance Framework) Directions, 2026.

    Direction number cited for retrieval via RBI notification search; RBI deep links are session-bound.

  • IT Outsourcing Master DirectionEffective 1 October 2023

    Master Direction on Outsourcing of Information Technology Services (RBI/2023-24/102) issued 10 April 2023; effective 1 October 2023. Governs material IT outsourcing by regulated entities, including vendor risk, audit rights and concentration risk.

    Direction number cited for retrieval via RBI notification search.

  • Digital Payment Security Controls Master DirectionEffective 18 February 2021

    Issued 18 February 2021: minimum security standards for digital payment channels — internet banking, mobile payments and card payments — binding scheduled commercial banks, small finance banks, payments banks and card-issuing NBFCs.

    Direction cited by title and date for retrieval via RBI notification search.

  • Cyber Security Framework in BanksEffective 2 June 2016

    RBI’s Cyber Security Framework in Banks (2 June 2016) requires scheduled commercial banks to report cyber incidents to RBI within 2 to 6 hours of detection, alongside board-approved cyber security policy, SOC capability and cyber crisis management plans.

Related in this cluster

RBI cyber-security audit for NBFCs — FAQs

Which RBI direction applies to our NBFC?

It depends on your NBFC layer and activities. Middle- and upper-layer NBFCs face the fullest IT-governance and assurance requirements; base-layer entities need proportionate controls. We confirm the exact applicable direction during scoping.

Do you cover digital-lending partners?

Yes. We assess outsourcing and digital-lending arrangements against RBI’s outsourcing and Digital Lending Directions (2025), including your due diligence and monitoring of Lending Service Providers.

Is VAPT included?

It can be bundled. As a CERT-In empanelled auditor we can combine the governance audit with application and infrastructure VAPT for a single, coherent report.

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