SEBI Compliance Audit | CSCRF Audit Services
Securexocean delivers SEBI Cybersecurity and Cyber Resilience Framework audit services for stock brokers, mutual funds, asset management companies, depositories, and all other SEBI-regulated entities — covering gap assessment, annual cyber audit, and VAPT obligations under SEBI's 2024 framework.
Service Introduction
SEBI introduced the Cybersecurity and Cyber Resilience Framework in August 2024, replacing earlier circulars with a consolidated, risk-tiered mandatory framework applicable to all SEBI-regulated entities. CSCRF requires structured cybersecurity programs, periodic VAPT, cyber resilience capabilities, and annual cyber audits by qualified external auditors.
The framework is organized around five core objectives: anticipate, withstand, contain, recover from, and adapt to cyber threats. CSCRF classifies regulated entities into five categories based on asset size, trading volume, and client base — from Market Infrastructure Institutions to Self-Certification REs — with obligations scaled proportionally to systemic significance.

Threat Landscape
Organizations without formal asset inventories cannot demonstrate the foundational control CSCRF requires. Without security monitoring and documented incident response procedures, both audit findings and operational vulnerability accumulate.
SEBI holds regulated entities fully accountable for third-party service provider cybersecurity posture — vendor security gaps are the regulated entity's regulatory liability. VAPT conducted infrequently or narrowly scoped creates non compliance regardless of other controls in place.

CSCRF Control Gaps We Identify and Address
Absence of a classified asset inventory and critical asset protection program
Inadequate incident detection and response capabilities against defined timelines
Unmanaged third-party and vendor cyber risk without contractual security obligations
VAPT not conducted at required frequency or with critical findings remediated in time
Security governance structures disconnected from board-level oversight
Insufficient business continuity and recovery capabilities for critical trading systems
Absent or incomplete audit and accountability controls across IT infrastructure
In-scope systems, departments, and CSCRF entity category established. Scope documentation references applicable SEBI circular and defines audit boundaries agreed before fieldwork.
Audit plan developed covering nature, timing, and extent of controls assessment across each CSCRF domain. Schedule finalized with board and management covering all departments and systems.
Each CSCRF domain evaluated — governance, asset management, access control, network security, incident management, BCP, vendor management, and audit accountability. Discrepancies and non conformities documented as fieldwork progresses.
Annual VAPT conducted across critical systems. Findings risk-rated with remediation timelines assigned. VAPT evidence documented for audit report and regulatory submission.
Audit observations compiled against CSCRF checklist. Report prepared for SEBI submission through the relevant exchange or depository following satisfactory findings closure.

Audit Toolset
Our team uses SEBI CSCRF checklist-based assessment frameworks, network and application security testing tools for mandated VAPT, asset discovery and classification tools, third-party risk assessment frameworks, access control review methodologies, and business continuity plan assessment tools.
Documented audit scope defining in-scope systems and CSCRF entity category
Audit plan and finalized schedule agreed with board and management
CSCRF checklist-based audit findings report covering all applicable domains
VAPT report with risk-rated findings and remediation evidence
Summary audit report with observations, non-conformities, and improvement recommendations
Regulatory submission package formatted for SEBI reporting requirements
Post-audit support for SEBI queries and corrective action closure
Regulatory Alignment
Primary regulatory instrument. Audit scope, methodology, and report format follow SEBI's 2024 CSCRF circular and entity category requirements directly.
CSCRF audits incorporate CERT-In mandatory incident reporting, log retention, and security control requirements applicable to SEBI-regulated entities.
Required for MIIs and Qualified REs under CSCRF. Securexocean provides both CSCRF audit and ISO 27001 implementation through coordinated engagements.
For entities regulated by both SEBI and RBI, audit engagements are structured to satisfy requirements across both frameworks simultaneously.
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