SEBI CSCRF Audit: New Circulars – Why You Must Be Ready Before FY25
SEBI CSCRF Audit: New Circulars – Why You Must Be Ready Before FY25 Cybersecurity has moved beyond being a technology concern in India’s financial ecosystem. With the full enforcement of SEBI’s Cybersecurity and Cyber Resilience Framework (CSCRF), cybersecurity is now a regulatory, governance, and audit obligation for all SEBI-regulated entities. In 2026, CSCRF compliance is no longer about intent or policy documentation. It is about evidence, execution, and accountability. This blog by Lumiverse Solutions explains what the SEBI CSCRF audit is, why it matters today, and how regulated entities should approach compliance in a practical, audit-ready manner. What Is the SEBI CSCRF Audit? The SEBI CSCRF audit is a mandatory, structured cybersecurity audit conducted to assess whether a SEBI-regulated entity has implemented the Cybersecurity and Cyber Resilience Framework as prescribed by SEBI. Follows SEBI-defined audit and reporting formats Assesses technical controls and governance effectiveness Requires verifiable implementation evidence Evaluates detection, response, and recovery capabilities In practice, the CSCRF audit determines whether cybersecurity controls are operationally embedded or exist only on paper. Why the SEBI CSCRF Audit Matters in 2026 1. Regulatory Accountability Has Increased Heightened supervisory scrutiny Mandatory remediation programs Increased regulatory engagement 2. Cybersecurity Is a Governance Responsibility Boards and senior management accountability CISO and compliance officer ownership Audit outcomes reflect governance maturity 3. Evidence-Based Compliance Is Mandatory Logs and monitoring records VAPT remediation proof Incident response testing evidence Management approvals and reviews 4. Focus on Resilience, Not Just Prevention Incident detection Response effectiveness Recovery and continuity validation How CSCRF Evolved into an Enforceable Audit Framework Standardised audit and reporting formats Defined compliance timelines Clear applicability across entity categories Strong emphasis on implementation evidence CSCRF is now designed for consistency, comparability, and enforcement across India’s financial ecosystem. Mandatory Services Under SEBI CSCRF Control Area What SEBI Expects Governance & Oversight Defined roles, board and senior management accountability Asset Inventory & Classification Identification and classification of critical systems VAPT & Cybersecurity Audit Testing with remediation and closure evidence Monitoring, Logs & Reporting Log collection, review, and retention Incident & Crisis Management Tested incident response and escalation mechanisms Backup & Disaster Recovery Secure backups and recovery validation Access & Identity Management Role-based access and privilege controls Third-Party Risk Management Vendor risk assessment and ongoing oversight Audit Insight: Absence of evidence for any mandatory control usually leads to direct non-compliance observations. Recommended (Risk-Based) CSCRF Services Control Area Typically Expected For SOC & Advanced Monitoring Mid-size and large entities Endpoint & Data Protection Risk-based environments Red / Purple Team Testing Systemically important entities Cloud & API Security Cloud-hosted and digital platforms Cyber Awareness & Training All entities (risk-based depth) Audit Expectation: When recommended controls are absent, auditors expect risk acceptance or compensating controls. Missing both usually results in findings. Common CSCRF Audit Gaps Observed Incomplete asset inventories VAPT findings without closure evidence Weak log monitoring and review Untested incident response plans Missing governance approvals and oversight records Most audit failures arise from documentation and governance gaps, not lack of technology. How to Prepare for SEBI CSCRF Audits in 2026 Conduct a CSCRF gap assessment Strengthen governance frameworks Maintain a central audit evidence repository Perform mock audits and incident drills Track remediation continuously How Lumiverse Solutions Supports CSCRF Compliance CSCRF gap assessments VAPT coordination and remediation tracking Independent CSCRF cybersecurity audits Incident response planning and drills Audit evidence preparation and executive reporting Preparing for CSCRF audits in 2026? Work with Lumiverse Solutions to move from policy-level compliance to audit-ready cybersecurity governance. Talk to a CSCRF Expert Conclusion In 2026, the SEBI CSCRF audit is a measure of governance maturity and operational resilience. Entities that embed CSCRF into daily operations will not only meet regulatory expectations but also strengthen long-term trust, stability, and resilience. Frequently Asked Questions (FAQs) – SEBI CSCRF Audit What is the SEBI CSCRF audit? The SEBI CSCRF audit is a mandatory cybersecurity audit conducted to assess whether a SEBI-regulated entity has implemented the Cybersecurity and Cyber Resilience Framework (CSCRF) as prescribed by SEBI. It evaluates governance, technical controls, incident readiness, and resilience using SEBI-defined audit formats. Is the CSCRF audit mandatory for all SEBI-regulated entities? Yes. CSCRF compliance and audit applicability extend to all SEBI-regulated entities, regardless of size. While the depth of controls may vary based on risk and scale, mandatory controls apply universally. How is the CSCRF audit different from earlier cybersecurity audits? Unlike earlier audits, the CSCRF audit: Uses standardised SEBI audit formats Requires implementation evidence, not just policies Evaluates incident response and recovery Emphasises board and senior management accountability What happens if mandatory CSCRF controls are missing? If mandatory controls are missing or lack evidence, auditors typically record direct non-compliance observations, which may lead to regulatory scrutiny and mandatory remediation. Are “recommended” CSCRF controls optional? Recommended controls are risk-based, but they are not optional in practice. If such controls apply to an entity’s size or complexity and are not implemented, auditors expect documented risk justification or compensating controls. What are the most common CSCRF audit gaps? Common gaps observed during CSCRF audits include: Incomplete asset inventory and classification VAPT findings without closure evidence Weak log monitoring and review practices Incident response plans that are not tested Missing governance approvals or oversight records Does CSCRF require a Security Operations Centre (SOC)? A SOC is not mandatory for all entities, but it is strongly expected for mid-size and large entities. If a SOC is not implemented, auditors typically ask for documented justification and alternative monitoring mechanisms. How often should VAPT be conducted under CSCRF? VAPT must be conducted periodically and after significant system changes. CSCRF audits focus on remediation and closure evidence, not just the VAPT report itself. Who is responsible for CSCRF compliance within an organisation? CSCRF assigns responsibility across multiple levels: Board of Directors Senior Management CISO / IT Head Compliance and Risk Teams Cybersecurity is treated as a governance responsibility, not only an IT function. How should organisations prepare for CSCRF audits in 2026? Organisations should: Conduct CSCRF gap assessments Strengthen governance and approvals Maintain
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