RBI Cybersecurity Framework Evidence Checklist
RBI inspections fail entities on missing evidence far more often than on missing controls. This checklist documents the exact evidence inspectors look for under the RBI Cyber Security Framework for banks, the Master Direction on IT Governance for NBFCs, and the RBI Digital Lending Guidelines (DLG) — including what an upper-layer NBFC needs versus a base/middle-layer entity.
The Checklist
Governance evidence
- IT Strategy Committee charter, minutes for last 4 meetings, attendance signed
- CISO appointment letter, reporting line documented, KPIs
- Risk Management Committee minutes including cyber-risk discussions
- Board-approved Information Security Policy with last review date < 12 months
- Cyber-crisis management plan signed by board
IT general controls (ITGC)
- Change management — ticket sample, approval evidence, segregation of dev/test/prod
- Access management — joiners-movers-leavers process, quarterly access reviews, privileged-access logs
- Backup-restore evidence (last quarter)
- Patch management — scanner reports + remediation tickets, SLA adherence
- Logging: centralised logging with min 6-month retention for critical systems
Application & data security
- VAPT report from CERT-In Empanelled auditor, dated < 12 months, with closure evidence
- Secure code review evidence for major releases
- Encryption inventory + key management evidence
- Data classification policy + sample classification labels in production
- Customer data localisation evidence (PA/PG and DPSS-listed entities)
Network & infrastructure
- Network architecture diagram with security zones marked, dated
- Firewall rule-base review (quarterly) with sample approvals
- DDoS protection — vendor, capacity, last test report
- Wireless security policy + segregation from production
- Endpoint protection rollout report (>98% coverage typically expected)
Incident management
- Incident register with classification, timeline, root cause and remediation per incident
- CERT-In incident reporting evidence (6-hour clock) — at least sample logged events
- SIEM / SOC arrangement (in-house, MSSP, hybrid) with named contacts and runbooks
- Phishing simulation evidence (at least quarterly)
- Tabletop exercise report (at least bi-annual)
Digital Lending Guidelines (DLG) — for digital lenders
- LSP (Lending Service Provider) onboarding due-diligence report per partner
- Key Fact Statement (KFS) sample, with all DLG-mandated fields
- Cooling-off period evidence
- Customer-data flow diagram showing where data goes outside the regulated entity
- Grievance redressal SLA evidence + monthly reports
- Recovery / collection process audit — privacy, working hours, recording, escalation
Upper-layer NBFC additional
- Independent Compliance Function report
- ICAAP (Internal Capital Adequacy Assessment) cyber-risk component
- Quarterly cyber-risk dashboard to board
- Independent IS Audit report (separate from internal audit)
Frequently asked questions
What's the difference between the RBI IT Framework and the Cyber Security Framework for banks?
The IT Framework (Master Direction, 2023) applies to NBFCs, ARCs and credit institutions. The Cyber Security Framework (2016) applies to scheduled commercial banks. They overlap significantly but the bank framework has additional requirements around critical-IT vendor management, SOC capability and red-teaming.
How does the RBI Digital Lending Guidelines (DLG) framework fit in?
DLG layers on top of the IT Framework. If you're a digital-lending NBFC or your bank operates through an LSP, you must evidence DLG-specific items (LSP due diligence, KFS, cooling-off, grievance, recovery audit) on top of the standard cybersecurity controls.
Does the audit cover Account Aggregator (AA) integrations?
Yes. AA-connected lenders, FIPs and FIUs are reviewed for consent-management evidence, data-flow integrity, retention/erasure compliance and integration security.
Do you cover RBI Payment Aggregator audits separately?
Yes — RBI's Payment Aggregator / Payment Gateway audit has a distinct scope. Our `/services/cert-in-audit/rbi-pa-pg` and SAR audit pages cover that scope.
How long should we keep this evidence?
Minimum 6 years for audit evidence, longer for customer transaction records (15 years under PMLA for relevant cases). Always check the latest RBI circular for your category.
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