
Circular No. SEBI/HO/ ITD-1/ITD_CSC_EXT/P/CIR/2025/119, Dated: 28.08.2025
1. Introduction
The Securities and Exchange Board of India (SEBI) has issued a circular providing technical clarifications to the Cybersecurity and Cyber Resilience Framework (CSCRF) applicable to regulated entities. The framework is aimed at strengthening the resilience of market intermediaries and ensuring consistency in implementation across various categories of participants. These clarifications are expected to bring greater transparency, alignment, and efficiency in compliance with cybersecurity requirements.
2. Key Clarifications Issued
The circular introduces the principles of exclusivity and equivalence to address cases where entities operate under the jurisdiction of multiple regulators. SEBI has also refined the definitions of critical and non-critical systems, ensuring that regulated entities can correctly categorise their IT infrastructure. Additionally, timelines for asset inventory updates have been prescribed to improve monitoring, while detailed guidance has been provided for Vulnerability Assessment and Penetration Testing (VAPT) and audit submissions to ensure consistent application of standards.
3. Operational Controls and SOC Onboarding
Another important aspect of the clarification is the emphasis on Security Operations Centre (SOC) onboarding, which must be carried out in a timely manner by regulated entities. The circular highlights the need for robust incident detection, reporting, and resolution mechanisms. It also reiterates the importance of implementing adequate controls across various systems, thereby strengthening operational resilience and safeguarding sensitive investor data from cyber threats.
4. Revised Categorisation Thresholds
In addition to the technical updates, SEBI has revised the categorisation thresholds for Portfolio Managers and Merchant Bankers, ensuring that the cybersecurity framework remains proportionate to the scale and complexity of operations. This risk-based categorisation will help in allocating compliance responsibilities appropriately, while also providing smaller entities with practical and implementable cybersecurity measures. Overall, these clarifications reaffirm SEBI’s commitment to enhancing the security, stability, and trustworthiness of India’s capital markets.
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