SEBI Cybersecurity Audit Checklist
SEBI's Cyber Security and Cyber Resilience Framework (CSCRF) is graded on evidence, not intent. Most failed CSCRF audits are not about missing controls — they're about controls that exist but can't be evidenced. This checklist is the exact one our auditors use when scoping a SEBI engagement, organised by CSCRF's IPDRR pillars and the additional resilience obligations for QSBs and MIIs.
The Checklist
Identify (CSCRF IPDRR — Identify)
- Asset inventory of all IT/OT systems, mapped to data classification (critical / sensitive / supporting)
- Threat-model document per critical system (OMS, RMS, surveillance, mobile/web trading)
- Risk register updated within last 6 months, signed by CISO + management
- Vendor / third-party risk register including data-processing relationships
- Business Impact Analysis (BIA) with RTO/RPO for each critical asset
Protect
- Network segmentation between trading / surveillance / general IT — documented + tested
- Identity & access management with MFA, JIT and quarterly access reviews
- Encryption inventory: data-at-rest (DB-level + storage), data-in-transit (TLS 1.2+), key management evidence
- Endpoint protection (EDR) deployment evidence across 100% of in-scope endpoints
- Patch management evidence (scanner results, remediation tickets, SLA adherence)
- Email security (SPF, DKIM, DMARC enforced; advanced threat-protection in place)
- Mobile device management (MDM) for dealer terminals + executive devices
Detect
- SIEM in place with at least 90-day log retention for in-scope systems
- Use-case catalogue: critical detections written, tested, and tuned (top 30)
- Threat intelligence feed integrated and consumed
- User & entity behaviour analytics (UEBA) for trading desk anomaly detection
- File integrity monitoring on critical configuration / trading-engine files
Respond
- Incident response playbook (current version, dated within last 12 months)
- SEBI CSIRT reporting templates ready and rehearsed (6-hour material-incident clock)
- Tabletop exercise log — at least 2 in last 12 months, including market-abuse scenarios
- Forensic readiness: log preservation, chain-of-custody procedures documented
- External IR retainer in place (named provider + 24×7 contact)
Recover
- Backup strategy with 3-2-1-1-0 rule (3 copies, 2 media, 1 offsite, 1 immutable, 0 errors)
- Quarterly backup-restore test evidence
- DR fire-drill report within last 12 months — full failover, timed against RTO/RPO
- Business continuity plan with named owners and call-tree updated quarterly
- Lessons-learned register from incidents and drills
QSB / MII additional obligations
- Enhanced segregation between dealer / RMS / surveillance environments
- Independent quarterly evidence reporting to SEBI
- Cyber-resilience drills aligned to SEBI's expectations
- Designated CISO + cyber-security committee with minute-of-meeting evidence
- Customer disclosures and data-protection statements aligned to SEBI requirements
Frequently asked questions
How often must SEBI-regulated entities run cybersecurity audits?
At least annual for all critical systems; semi-annual for high-risk systems. Qualified Stock Brokers (QSBs) and Market Infrastructure Institutions (MIIs) typically run quarterly continuous VAPT plus the annual statutory audit.
Who can sign a SEBI cybersecurity audit?
A CERT-In Empanelled Information Security Auditor. SEBI relies on CERT-In's empanelment list — audits signed by non-empanelled auditors are typically rejected.
What's different for Qualified Stock Brokers (QSBs)?
QSBs have enhanced segregation, cyber-resilience drills, quarterly evidence reporting and stricter CISO accountability. Our QSB checklist adds a 'QSB-additional' section that mid-size brokers don't need.
Does the audit cover algo-trading systems?
Yes — input validation, kill-switch effectiveness, rate-limit handling, audit-trail integrity, exchange-side compliance and the SEBI algo-rules-2018 alignment are all in scope.
Can our existing CERT-In audit double as the SEBI audit?
Often yes — if the scope was mapped against CSCRF's IPDRR pillars and the SEBI-specific obligations. We frequently scope a single engagement to satisfy both regulators.
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