India’s financial regulators each set their own cyber and IT expectations, and many firms fall under more than one. Here is how the main instruments fit together.
| If you are… | Primary rules |
|---|---|
| A bank or NBFC | RBI IT Governance Master Direction, RBI Cyber Security Framework, IT Outsourcing Direction, KYC Direction, Fraud Risk Directions |
| A payment system operator | RBI cyber resilience directions for PSOs, payment data localisation, PCI DSS |
| A broker, depository participant, AMC or other SEBI entity | SEBI CSCRF, SEBI cloud framework |
| An insurer or intermediary | IRDAI Information and Cyber Security Guidelines |
| Everyone | CERT-In Directions, DPDP Act, PMLA where you are a reporting entity |
Build once, evidence many times
The overlap is large: governance and a CISO role, risk assessment, access control, logging and monitoring, incident response and reporting, vendor risk, business continuity and periodic audit. An ISO/IEC 27001 ISMS with ISO 22301 for continuity covers most of it. On top, add each regulator’s specifics, committee structures, reporting formats, audit frequency and timelines such as CERT-In’s six-hour incident reporting.
Where firms most often fall short
- Board and committee oversight that exists on paper but is not minuted
- Vendor and cloud contracts missing audit and data location clauses
- Logs not retained for 180 days in India
- Incident escalation too slow to meet reporting windows
- BCP/DR plans never tested end to end