If your organisation falls under the scope of Securities and Exchange Board of India’s Cybersecurity and Cyber Resilience Framework (CSCRF), you’re facing more than just a regulatory tick-box. You’re facing a challenge of aligning governance, processes, technology and culture in one integrated cycle.
A well-executed SEBI CSCRF Gap Assessment Checklist helps you identify where you stand today, what needs fixing, and how to prioritise actions so that your cyber-resilience journey is structured, measurable and audit-ready.
Understanding the SEBI CSCRF framework
Before diving into the checklist, we need a quick refresher on what SEBI CSCRF covers.
The CSCRF issued by SEBI sets out baseline standards for cybersecurity and operational resilience for regulated entities (REs) in the Indian securities market.
It uses a graded approach according to the size and function of the RE.
It emphasises domains such as governance, risk management, protection, detection, response and recovery.
Why is a gap assessment important?
A gap assessment is the first key step: you cannot fix what you have not measured. By mapping current controls against CSCRF expectations you’ll uncover:
- Which controls are missing.
- Where existing controls are weak or mis-aligned.
- What remediation priority you must chase.
This, in turn, will help you make your business audit ready and ultimately achieve SEBI CSCRF compliance.
Building your SEBI CSCRF gap assessment checklist
Here’s how you structure a checklist that drives clarity, prioritises actions and prepares you for audits.
Step 1: Define scope and classification
- Confirm your RE category (Market Infrastructure Institutions, Qualified REs, Mid-size, Small-size, Self‐certification) because obligations differ.
- Identify critical systems vs non-critical systems – the audit under CSCRF covers 100% of critical systems and 25% sample of non-critical systems.
- Establish asset inventory, data flows, third-party dependencies and organisational boundaries.
Step 2: Map your current state
For each domain defined in CSCRF (governance, protection, detection, etc), map existing controls. Typical checklist items include:
- Board or senior management oversight of cyber risk.
- Documented cybersecurity policy, roles (CISO), risk management process.
- Identity and access management: MFA, least privilege, privileged account control.
- Network and system protections: firewalls, segmentation, encryption, endpoint security.
- Monitoring and detection: SOC, SIEM, threat-hunting, log retention.
- Incident response and recovery: playbooks, BCP/DR, post-incident review.
- Vendor/third-party risk management: due diligence, contracts, SLAs.
- Audit, testing and continuous improvement: VAPT, red-teaming, cyber-audit, gap closure monitoring.
These items should align with core checklist points.
Step 3: Identify the gap
For each control you mapped, ask:
- Do we have the policy/process/technology in place?
- Is it operating effectively?
- Does it meet the CSCRF standard or higher?
Assign a rating (e.g., Compliant / Partial / Not Implemented) or a numeric scale to help prioritise.
Step 4: Prioritise remediation actions
Once gaps are known, prioritise by risk (impact and likelihood), regulatory urgency, resource availability. Focus first on:
- Gaps that expose critical systems or investor interests.
- Controls mandated with hard deadlines under CSCRF.
- Weaknesses that could trigger audit findings or regulatory scrutiny.
Step 5: Execute and track closure
Create an action plan with:
- Remediation tasks
- Ownership (who does it)
- Timeline
- Evidence required (documentation, test results)
Track status, escalate unresolved items, prepare for audit.
Step 6: Review and repeat
The CSCRF emphasises not a one-time compliance but continuous resilience. Periodically refresh your gap assessment, update the checklist, test controls and embed a culture of improvement.
What a solid checklist should include
Here’s a more concrete breakdown of key checklist sections you should include:
1. Governance and risk management
- Is there a board-approved cybersecurity policy?
- Are cybersecurity roles, responsibilities formalised (CISO, IT Committee)?
- Is there a risk-register for cyber threats, including emerging ones (e.g., post-quantum)?
- Has senior management received regular cyber-risk reports?
- Are third-party and supply-chain risks integrated into risk management?
2. Protection (Preventive controls)
- Is MFA implemented for critical systems?
- Is data classification and encryption in place (particularly for investor/financial data)?
- Secure SDLC and SBOM processes for software supply-chain security?
- Network segmentation, secure remote access controls, zero-trust architecture where applicable?
3. Detection and monitoring
- Is there a SOC (in-house or managed) with continuous monitoring?
- Are logs aggregated, retained as per CSCRF requirement?
- Are threat-hunting or anomaly-detection programmes in place (especially for MIIs / Qualified REs)?
4. Response and recovery
- Is there a tested incident-response plan and a cyber-crisis management plan?
- Are BCP/DR plans aligned with cyber resilience goals?
- Are DR drills and scenario-based tests conducted (including for emerging threats)?
5. Audit, testing and continuous improvement
- Are there scheduled VAPT and internal/external audits per CSCRF timelines?
- Has a gap-assessment been done recently and gap-closure tracked?
- Is there a mechanism in place to review findings, close them within the prescribed timeframe?
6. Compliance reporting and documentation
- Are standard formats as per CSCRF annexures used for reporting?
- Is evidence prepared – policies, logs, test reports, audit findings?
- Are submission timelines met (MD/CEO declarations, audit reports) as required by CSCRF?
Key benefits of using a robust checklist
Regulated Entities can benefit a lot from having a robust checklist.
- Clarity: You gain visibility of where you stand and where you need to go.
- Prioritisation: Helps your leadership invest time and budget where it matters most.
- Audit readiness: Streamlines the path to submission and helps avoid regulatory penalties.
- Continuous improvement: Embeds cyber-resilience in your culture rather than one-off compliance.
- Stakeholder confidence: Shows your board, investors and regulator that you are systematic and committed.
Conclusion
Running a SEBI CSCRF gap assessment checklist is not just a compliance activity. We believe it is a strategic opportunity. When done properly, it helps you sharpen your cyber resilience, align with regulation and build stronger confidence among investors and stakeholders.
We’ve seen that the entities that treat this as a one-time check finish with gaps. The ones that treat it as a journey build real resilience. At CyberNX, we work alongside your team to simplify this journey. If you’re ready to map your gaps, prioritise actions and prepare for the audit-ready state we’d be glad to partner with you.
Call us today to schedule your CSCRF readiness assessment and get your checklist built into your roadmap.
SEBI CSCRF gap assessment checklist FAQs
Who needs to perform a SEBI CSCRF gap assessment?
Any entity regulated by SEBI (stocks, brokers, AMCs, RTAs etc) needs to assess their cyber-resilience posture as per CSCRF.
How often should the gap assessment be repeated?
While CSCRF doesn’t prescribe a fixed gap-assessment interval, best practice is annual or after major business/tech changes to stay audit-ready and resilient.
What happens if we miss the CSCRF audit/reporting deadline?
Delayed or incomplete audits/reporting expose you to regulatory penalties, heightened risk and potential reputational damage.
Can smaller REs (self-certification category) use a simplified checklist?
Yes. The graded approach means smaller REs have fewer controls or relaxed timelines – but they still need a tailored checklist aligned to their category.
