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CIRCULAR
IFSCA-CSD/MSC/2/2026-DCS April 20, 2026
To,
All the Stock Exchanges, including Bullion Exchange, in the International Financial
Services Centres (IFSC)
All the Clearing Corporations in the International Financial Services Centres (IFSC)
All the Depositories in the International Financial Services Centres (IFSC)
Dear Madam/Sir,
Sub: Guidelines on Cyber Security and Cyber Resilience for Market Infrastructure
Institutions (MIIs) in IFSC
1. IFSCA vide circular dated March 10, 2025 had issued the ‘Guidelines on Cyber
Security and Cyber Resilience for Regulated Entities in IFSCs’, prescribing a
minimum baseline framework for cyber security applicable to all Regulated
Entities (REs) operating within GIFT IFSC. The said framework adopts a principles-
based approach to ensure proportional applicability, taking into account the
heterogeneity of REs in terms of size, structure, complexity and risk profile.
2. The Market Infrastructure Institutions (MIIs) comprising Stock Exchanges, Clearing
Corporations, Depository and the Bullion Exchange are systemically critical to the
stability, integrity and continuity of the capital market in IFSC. In view of their
central role and heightened risk exposure, a more robust, granular and prescriptive
cyber security framework is warranted.
3. Accordingly, with a view to enhancing cyber resilience, mitigating systemic cyber
risks and ensuring preparedness against evolving threat vectors, IFSCA has
formulated the “Guidelines on Cyber Security and Cyber Resilience for Market
Infrastructure Institutions (MIIs) in IFSC” as set out in Annexure A.
4. The key objective of these Guidelines is to establish a comprehensive cyber
security and cyber resilience framework for the MIIs operating in IFSC. The
Guidelines seek to:
ia. strengthen governance and reinforce accountability for cyber security at
the Board and Senior Management level
b. address evolving cyber threat landscape, including emerging risks such as
those arising from developments in quantum computing
c. align MII cyber security practices with national and international standards
and
d. ensure robust incident detection, response, reporting and recovery
mechanisms.
5. These Guidelines are structured around the following cyber security functions:
a. Govern
b. Identify
c. Protect
d. Detect
e. Respond
f. Recover
g. Resilience.
6. These Guidelines shall come into effect from April 01, 2026. The MIIs shall ensure
full compliance within the timelines specified in the respective provisions of these
Guidelines.
7. This Circular is issued in exercise of powers conferred by Sections 12 and 13 of the
International Financial Services Centres Authority Act, 2019, to develop and
regulate the financial services market in the International Financial Services
Centre.
A copy of this circular is available on the website at www.ifsca.gov.in
Yours Faithfully,
Praveen Kamat
General Manager & Chief Information Security Officer
Division of Cyber Security
Email: praveen.kamat@ifsca.gov.in
Tel : +91- 079 - 61809820
iiAnnexure A
Guidelines on Cyber Security and Cyber Resilience for
Market Infrastructure Institutions (MIIs) in IFSC
Financial institutions today face a constant barrage of threats that attempt to
compromise the Confidentiality, Integrity and Availability (CIA) of their computer systems,
networks and databases. To counter this, it is imperative that a financial institution have
a robust Cyber security framework in place that includes measures, tools and processes
that are intended to prevent cyber-attacks and improve cyber resilience i.e. the capacity
to maintain operations during a cyberattack and recover swiftly after a breach.
I. Govern
1. The Market Infrastructure Institutions (MIIs), as part of their operational risk
management framework, shall formulate a comprehensive Cyber Security and
Cyber Resilience Policy (“Policy”) to manage risks to their systems, networks, and
databases posed by cyber-attacks and threats. This Policy document shall
encompass the guidelines specified within this framework.
2. The Policy document must be approved by the Governing Board (Board) of the MIIs.
The said policy shall also cover the mechanism for handling exceptions to the
proposed framework. Furthermore, the Board shall periodically review the Policy
document to ensure that the framework remains adaptive to emerging threats, in
order to strengthen and improve the MII's cyber security and cyber resilience
posture.
3. The MIIs shall prepare a risk appetite and risk tolerance statement as part of the
Policy that articulates the nature and extent of cyber security risks that the MIIs are
willing and able to assume. The Board and Senior Management shall ensure that
key IT decisions are made in accordance with the MII’s risk appetite and risk
tolerance statement.
4. The Policy shall establish a structured framework to identify, assess, and manage
cyber security risks associated with the organization’s processes, information,
networks, and systems. This framework shall comprise the following key
processes:
i. 'Identify' critical IT assets and risks associated with such assets.
1ii. 'Protect' assets by deploying suitable controls, tools, and measures.
iii. ‘Detect’ incidents, anomalies, and attacks through appropriate
monitoring tools/processes.
iv. 'Respond' by taking immediate steps after identification of the incident,
anomaly, or attack.
v. ‘Recover’ from incident through incident management, disaster
recovery, and business continuity framework.
5. The Standing Committee on Technology (SCOT) of the MIIs shall review the
implementation of the Policy on a bi-annual basis.
6. For MIIs that have been identified as Critical Information Infrastructure (CII) by the
National Critical Information Infrastructure Protection Centre (NCIIPC), the policy
shall encompass the principles prescribed by NCIIPC of the National Technical
Research Organisation (NTRO), Government of India, in the report titled
'Guidelines for Protection of National Critical Information Infrastructure' and
subsequent revisions, if any, from time to time.
7. The MIIs shall appoint a dedicated Chief Information Security Officer (CISO) who
will be responsible for:
i. Assessing, identifying, and mitigating cyber security risks;
ii. Responding to cyber security incidents;
iii. Establishing cyber security standards and controls;
iv. Implementing the necessary processes as per the Board-approved cyber
security and resilience policy.
The CISO shall report directly to the Managing Director (MD)/Chief Executive
Officer (CEO).
8. For the MIIs designated as CII by NCIIPC, the roles and responsibilities of the CISO
shall also adhere to the aforesaid NCIIPC guidelines.
9. The Board and the Senior Management shall have members with the requisite
knowledge to understand and manage risks posed by cyber threats.
210. The MIIs shall establish a reporting procedure to facilitate communication of
unusual activities and events to the CISO or to the Senior Management in a timely
manner.
11. The MIIs shall formally define and document the cyber security obligations for all
individuals, who possess authorized access to the systems or networks of the MII,
inter alia, including its:
a. internal employees,
b. outsourced personnel,
c. third-party vendors,
d. market participants.
II. Identify
12. The MIIs shall identify and maintain an up-to-date inventory of information assets,
including data, applications and third-party dependencies. This may also include
a list of:
a. digital assets (such as URLs, domain names, applications, APIs, etc.),
b. shared resources (including cloud assets),
c. interfacing systems (internal and external),
d. details of its network resources,
e. connections to its network and data flows.
13. Any additions/ deletions or changes in existing assets shall be reflected in the
asset inventory in a timely manner.
14. The MIIs shall identify and classify critical assets based on their sensitivity and
criticality for business operations, services and data management. The critical
assets shall, inter alia, include:
a. business-critical systems,
b. internet-facing applications /systems,
c. systems that contain sensitive data,
d. sensitive personal data,
e. sensitive financial data,
f. Personally Identifiable Information (PII)
All the ancillary systems used for accessing/communicating with critical assets,
either for operations or maintenance, shall also be classified as critical assets.
3Further, the Board of the MIIs shall approve the list of critical assets at least once
a year.
15. The MII shall identify, categorize and quantify cyber security threats and
vulnerabilities that it may face, along with the probability of occurrence and the
potential systemic impact on business continuity. The MII shall put in place
technical and administrative controls that are strictly commensurate with the
criticality of the identified risks and the sensitivity of the underlying assets.
16. The MIIs shall prepare and maintain an up-to-date network architecture diagram
at the organizational level that include both wired and wireless networks.
17. The MIIs shall conduct a risk assessment (including post-quantum risks) of the IT
environment of their organization on an annual basis to acquire visibility and a
reasonably accurate assessment of the overall cyber security risk posture.
III. Protect
Access Controls
18. No person by virtue of rank or position shall have any intrinsic right to access
confidential data, applications, system resources or facilities.
19. Access to all systems, applications, networks, databases, etc., shall be for a
defined purpose and for a defined period. The MIIs shall grant access to their IT
systems, applications, databases and networks on a need-to-use basis and on the
Principle of Least Privilege (PoLP). Such access shall be authorized using strong
authentication mechanisms and shall be immediately revoked upon expiration of
the required period.
20. The MIIs shall implement strong password controls for users' access to systems,
applications, networks and databases. Password controls shall include:
a. a change of password upon first log-on,
b. minimum password length and history,
c. password complexity and
d. maximum validity period.
The stored user credential data shall be protected using industry-standard,
collision-resistant cryptographic hashing algorithms.
421. The User access rights, delegated access, unused tokens, and privileged user
activities shall be reviewed on a quarterly basis for critical systems and bi-annually
for non-critical systems.
22. The MIIs shall ensure that records of user access to critical systems, wherever
possible, are uniquely identified and logged for audit and review purposes. Such
logs shall be maintained and stored in a secure location for a period not less than
two (2) years. The MIIs also need to maintain records of users with access to shared
accounts.
23. The MIIs shall ensure that all critical systems accessible over the internet are
shielded by a Defense-in-Depth (DiD) architecture.
24. The MIIs shall deploy additional controls and security measures to supervise staff
who have elevated system access (such as admin or privileged users) and access
to critical assets.
25. To mitigate the risk of internal compromise and unauthorized system changes, the
MIIs shall implement a robust dual authorization mechanism (maker-checker
principle) for all access to critical information systems. The MII shall ensure that
no single individual possesses unilateral authority to execute changes to access
controls or alter security configurations.
26. The MIIs shall formulate an internet access policy to monitor and regulate the use
of internet and internet-based services such as social media sites, cloud-based
internet storage sites, etc.
27. A proper 'end of life' protocol shall be adopted to deactivate access privileges of
users:
i. upon their cessation of employment or
ii. upon formal withdrawal of access privileges
28. The MIIs shall implement a rigorous oversight framework for all personnel
(including permanent staff, outsourced staff, and third-party service providers)
possessing authorized access to critical IT assets. Such access shall be governed
by PoLP and shall be subject to real time session monitoring and automated
alerting.
5Security of Domain Controllers (DCs)
29. Given that threat actors often target and use Domain Controllers (DCs) for staging
network-wide attacks, the MIIs shall implement the following structural
safeguards.
a. The MII shall ensure application of all released security patches to DCs in a
timely manner.
b. The MII shall ensure that no non-essential software is installed on DCs.
c. The MII shall ensure that access to DC is restricted and controlled.
30. The MII shall undertake rigorous internal and external Red Team simulations
specifically targeting known Active Directory Domain Controller abuse attacks.
Any identified vulnerabilities or misconfigurations shall be classified by risk
severity and shall be remediated on a priority basis.
Insider Threat
31. An Insider threat shall, inter alia, include acts such as:
a. theft of confidential data and intellectual property,
b. sabotage of IT systems, and
c. fraud committed by internal staff, contractors or service providers
32. As the human element plays an important role in managing IT systems and
processes in an IT environment, the MII shall ensure that all personnel, including
contractors and service providers, have the requisite level of cyber and information
security awareness and training to perform their tasks while considering cyber
security risks.
Physical security
33. Physical access to the critical systems shall be restricted and access shall be
supervised by ensuring that visitors remain under the direct supervision of an
authorized official at all times.
34. The MIIs shall implement a Role-Based Access Control (RBAC) framework for all
physical access to critical systems.
635. The MIIs shall ensure that the perimeter of the critical equipment room is
physically secured and monitored by employing physical, human, and procedural
controls (for example, security guards, CCTVs, card access systems, mantraps,
bollards, etc.) where appropriate. The MIIs shall establish a Data Retention Policy
for all surveillance and access logs (CCTV, card swipes), to ensure that such
records are preserved for a period sufficient to support forensic investigations and
regulatory audits.
Network Security Management
36. The MIIs shall establish baseline standards to facilitate consistent application of
security configurations to operating systems, databases, network devices, and
enterprise mobile devices within the IT environment. The MIIs shall conduct
regular enforcement checks to ensure that the baseline standards are applied
uniformly.
37. The MIIs shall install network security devices, such as firewalls as well as
intrusion detection and prevention systems, to protect its IT infrastructure from
security exposures originating from internal and external sources.
38. The MIIs shall ensure that all IT systems are protected by antivirus, anti-malware
and Endpoint Detection and Response (EDR) / Endpoint Protection Platforms (EPP)
solutions. In the case of Linux or other non-Windows Operating Systems where
such solutions pose documented compatibility or performance constraints, the
MIIs shall implement compensatory controls to ensure that there is no degradation
in the institutional security posture. The MIIs shall ensure that the EDR/EPP,
antivirus and anti-malware solutions and signatures are up to date on all IT
systems.
39. The MIIs shall implement an enterprise-wide Application Whitelisting (AWL)
mandate. Appropriate mechanisms shall be implemented to proactively block the
installation or execution of unauthorized software.
40. The MIIs shall build effective network segregation for containing cyber incidents
and minimizing disruption to business operations. Internet web browsing provides
a conduit for cyber criminals to access the IT systems. In this regard, the MIIs shall
consider isolating internet web browsing activities from its endpoint devices using
physical or logical controls, or implement equivalent controls, so as to reduce
exposure of its IT systems to cyber-attacks.
741. The MIIs shall apply appropriate network segmentation / isolation techniques to
restrict access to sensitive information, hosts, and services. Segment-to-segment
access shall be based on a strong access control policy and the PoLP.
42. The MIIs shall implement Secure Web Gateways (SWG) and Email Security
Appliances (ESA) to regulate all inbound and outbound traffic.
43. The network devices of the MIIs shall be configured in line with the whitelist
approach of IPs, ports, and services for inbound and outbound communication
with proper Access Control List (ACL) implementation.
44. The MIIs shall implement DNS filtering services to ensure clean DNS traffic is
allowed in the environment. DNS security extension for secure communication
shall be used.
45. The management of critical servers/ applications/ services/ network elements
shall be restricted through enterprise-identified intranet systems.
46. The MIIs shall implement an enterprise-wide email security measures to eliminate
the risk of spoofing, phishing, and Business Email Compromise (BEC).
47. The MIIs shall maintain a definitive inventory of all log generating assets. An
indicative list of types of logs to be collected is as follows:
i. System logs
ii. Application logs
iii. Network logs
iv. Database logs
v. Security logs
vi. Performance logs
vii. Audit trail logs
viii. Event logs
The MIIs shall put in place necessary systems for automated monitoring of all
aggregated logs and security telemetry. This monitoring system must be capable
of performing User and Entity Behaviour Analytics (UEBA) to identify deviations
from established baselines and detect sophisticated, unusual patterns and
behaviours, that evade traditional threshold-based alerts.
48. To fulfil institutional accountability, MIIs shall establish strong log retention policy
that is in alignment with the extant applicable guidelines/ policies/ laws/ circulars/
regulations, etc. issued by the Government of India (GoI) / IFSCA such as:
8a. The Information Technology Act 2000,
b. The Digital Personal Data Protection Act (DPDP) 2023,
c. Guidelines issued by CERT-In, NCIIPC or any other government agency,
d. Guidelines issued by IFSCA
Awareness and Training
49. The MIIs shall complete their onboarding with the National Cyber
Coordination Centre (NCCC).
50. The MIIs shall conduct periodic training programs to enhance awareness levels
among the employees, outsourced staff, vendors, etc. on IT / Cyber security policy
and standards.
51. The training program shall be reviewed and updated at regular intervals to ensure
that the contents of the program remain current and relevant. The review shall take
into consideration changes in MII’s cyber security policies, prevalent and emerging
risks, and the evolving cyber threat landscape.
52. The MIIs shall implement a specialized training and awareness program focused
on Post Quantum Cryptography (PQC). This program shall ensure that the
technical personnel and risk officers are proficient in identifying quantum-
vulnerable algorithms and are prepared to execute the transition to PQC standards
as defined by international and national bodies (e.g., MeitY, CERT-In, NQM, NIST).
Data Security
53. The data in motion and data at rest shall be encrypted using strong cryptographic
algorithms.
54. To safeguard against internal and external data breaches, the MIIs shall enforce
Data Loss Prevention (DLP) controls across data in use, data in motion and data at
rest.
55. The MIIs shall implement necessary measures to prevent unauthorized access,
copying, or transmission of data / information held in a contractual or fiduciary
capacity. It shall be ensured that confidentiality of information is not compromised
during the process of exchanging and transferring information with external
parties.
956. The information security policy shall also cover the use of devices that can be used
for capturing and transmission of sensitive data within their IT infrastructure.
57. The MIIs shall permit only authorized data storage devices through appropriate
validation processes.
58. The use of sensitive production data in non-production environments shall be
restricted. In exceptional situations where such data needs to be used in non-
production environments, appropriate approval shall be obtained.
59. The MIIs shall maintain offline, encrypted backups of data and shall test these
backups periodically to ensure confidentiality, integrity, and availability.
60. The MIIs shall ensure all cryptographic algorithms used have been subject to
rigorous testing or vetting to meet the identified security objectives and
requirements.
61. The MIIs shall establish cryptographic key management policy, standards, and
procedures covering key generation, distribution, installation, renewal, revocation,
recovery, and expiry.
62. The MIIs shall conduct an annual Cryptographic Risk Assessment to evaluate the
continued efficacy of their encryption algorithms against advancements in
cryptanalysis and Quantum Computing / High Performance Computing.
The MIIs shall establish a roadmap for the adoption of PQC standards (e.g. NIST
FIPS 203, 204 and 205) to ensure seamless migration of critical systems before
existing asymmetric standards are rendered obsolete by advancements in
Quantum Computing / High Performance Computing.
63. The MIIs shall implement DLP measures on personal computing or mobile devices
that are used to access MII’s IT systems and networks. Two common ways to
address this are the use of Mobile Device Management (MDM) or Mobile
Application Management (MAM), as well as virtualization solutions. These
solutions can be augmented with other security measures for personal devices to
provide enhanced functionalities.
Hardening of Hardware and Software
64. The MIIs shall deploy hardware and software assets that have undergone a formal
security vetting and hardening process. The MIIs shall maintain a log of hardening
10activities, verifying that no IT system retains default administrative credentials or
active, unmonitored backdoors.
65. For running services, non-default ports shall be used wherever applicable. Open
ports on networks and systems, that are not in use or can be potentially used for
the exploitation of data, shall be blocked. All open ports shall be monitored, and
appropriate measures shall be taken to secure them.
66. The practice of whitelisting ports based (at the firewall level) on business usage
shall be implemented rather than blacklisting certain ports. Traffic on all other
ports which have not been whitelisted shall be blocked by default.
67. The MIIs shall perform Vulnerability Assessment and Penetration Testing (VAPT)
before the commissioning of new systems and/or any production release,
especially those that are part of critical systems or connected to critical systems.
68. Revalidation of VAPT post closure of observations shall be done in a time-bound
manner to ensure that all the open vulnerabilities have been fixed.
Change Management Process
69. The change management process shall include (but not be limited to) submission,
planning (impact analysis, rollout plan), approval, and implementation, review
(post-implementation), closure, etc.
70. The MIIs shall have a clearly defined framework for change management including
requirements justifying exception(s), duration of exception(s), process of granting
exception(s), and authority for approving and for periodic review of exception(s)
given.
71. The change management process shall also be part of all agreements with third-
party service providers to ensure that changes to the system are implemented in a
controlled and coordinated manner.
Application testing and Secure Software Development
72. The MIIs shall ensure that regression testing is undertaken before new or modified
systems are implemented. The scope of tests shall cover business logic, security
controls, and system performance under various stress-load scenarios, and
recovery conditions.
1173. To ensure the secure rollout of software and applications, the MIIs shall conduct
threat modelling and application security testing during development,
incorporating relevant security requirements from established standards and
guidelines such as OWASP Application Security Verification Standard (OWASP-
ASVS).
74. To safeguard institutional data, the MIIs shall implement necessary technical
controls to ensure that all Application Programming Interfaces (APIs) adhere to
secure by design principles. The MIIs shall ensure that all API connectivity is
restricted to authorized entities. Furthermore, all API development shall factor in
the mitigation of the Open Worldwide Application Security Project (OWASP) API
Security Top 10 vulnerabilities, prior to deployment in production environment.
Vulnerability Assessment and Penetration Testing (VAPT)
75. The MIIs shall regularly conduct vulnerability assessments to detect security
vulnerabilities in the IT environment. The MIIs shall also carry out periodic
penetration tests, at least once in a year, to conduct an in-depth evaluation of the
security posture of the system through simulations of actual attacks on its systems
and networks.
76. As part of the VAPT, the MIIs shall review the Active Directory (AD) to locate and
close existing backdoors such as compromised service accounts, which often
have administrative privileges and are a potential target for attacks.
77. For those MIIs, whose systems have been identified as "protected systems" by
NCIIPC, the VAPT exercise shall be conducted on a bi-annual basis. All testing
must align with the guidelines prescribed by NCIIPC and CERT-In.
78. The MIIs shall take remedial actions to address the gaps identified during the VAPT,
within defined timelines. The remediation process shall be prioritized on the basis
of business criticality and threat severity.
Remote Access Management
79. The MIIs shall ensure a proper remote access policy framework incorporating the
specific requirements of accessing the enterprise resources securely from outside
the physical premises of the MIIs using an internet connection.
80. The MIIs shall ensure that only trusted client machines shall be permitted to
access enterprise IT resources remotely. The MIIs shall put in place appropriate
security control measures for remote access and telecommuting.
1281. The MIIs shall ensure that appropriate risk mitigation mechanisms are put in place
whenever remote access to IT resources is permitted for third-party service
providers.
82. The MIIs shall ensure that remote access is monitored continuously for any
abnormal/ unauthorized access, and appropriate alerts and alarms shall be
generated to address this breach before any damage is done.
Patch Management
83. The MIIs shall establish a patch management policy to ensure that all applicable
patches (at both PDC and DR Site) are identified, assessed, prioritized, tested, and
applied to all IT systems/applications within defined timelines. However, for
emergency patching, patches shall be deployed within timelines as stipulated by
the OEMs.
84. The patch management policy shall be approved by SCOT of the MIIs and shall be
reviewed by SCOT for the MIIs at least on an annual basis.
85. All operating systems and applications shall be updated with the latest patches on
a regular basis. As an interim measure for zero-day vulnerabilities, and where
patches are not available, virtual patching may be considered for protecting
systems and networks. Patches shall be sourced only from the authorized sites of
the OEM.
86. The MIIs may choose to adopt appropriate periodicity commensurate with their
cyber risks and the criticality of their systems for implementing Compensatory
controls for legacy systems.
Disposal of systems and storage devices
87. The MIIs shall frame suitable policies for disposals of the storage media and
systems. The data / information on such devices and systems shall be erased by
using methods viz. wiping / shredding/ cleaning / overwrite, degauss and physical
destruction, as applicable.
Management of Third-party Risks
88. The MIIs shall implement a risk-based approach to manage its cyber security risk
with respect to outsourcing and third-party risk management.
1389. The MIIs shall have an effective process for managing third-party cyber security
risks through the entire third-party risk management life cycle.
90. The MIIs shall take appropriate steps to ensure that third parties have in place a
comprehensive cyber security and cyber resilience program.
91. Prior to entering into new third-party relationships and during the lifespan of the
engagement, the MIIs shall conduct cyber security risk assessments and due
diligence to consider whether these relationships are consistent with their cyber
security and cyber resilience strategy.
92. The MIIs’ contracts with third party entities shall include the necessary terms and
conditions to support the management of cyber security risks. These contracts
shall prohibit the subcontracting of critical functions without the explicit written
consent of the MIIs.
93. In situations where the MIIs are dependent on a single service provider for material
or critical outsourced tasks, the risks arising therein shall be identified and
managed effectively. The MIIs are required to take into account concentration risk
while outsourcing multiple critical services to the same third-party service
provider. Accordingly, the MIIs shall prescribe specific cyber security controls,
including audits of their systems and protocols from independent auditors, to
mitigate such concentration risk.
94. The MIIs shall maintain a comprehensive inventory of all third-party service
providers. The MIIs shall categorize and designate Critical Service Providers (CSPs)
based on their operational impact. A CSP is a service provider that has a direct
contractual arrangement with an entity, to provide, on a continuous basis, services
to that entity (and potentially its participants), which are essential for ensuring
information confidentiality and integrity and service availability, as well as the
smooth functioning of its core operations.
95. The MIIs shall have appropriate contingency plans and exit strategies in place to
address situations where third parties fail to meet cyber-related performance
expectations or pose cyber security risks outside the MII’s risk appetite.
Cloud Security Control
96. The MIIs are required to create a comprehensive cloud security policy. While
framing cloud security controls, the MIIs are encouraged to use a layered approach
toward cloud security, covering all the layers, which are:
14i. Data
ii. Application
iii. Host/Compute
iv. Network
v. Identity and Access
vi. Physical and Perimeter
97. In the event the MIIs are utilizing the services from multiple cloud service
providers, it is required to have relevant personnel who possess the necessary
understanding of the corresponding cloud solutions. Further, the MIIs are required
to address the following challenges:
i. Ensuring data protection and privacy for each environment
ii. Understanding how different solutions fit together
iii. Understanding service integration options
iv. Loss of visibility and control
98. As cloud computing follows the shared responsibility model, cloud service
providers are responsible for maintaining the security and sanctity of the physical
data center along with IT infrastructure (compute, network, storage, security)
deployed for the cloud while the entities are responsible for framing and
institutionalizing proper security controls, while understanding the underlying
risks.
IV. Detect
99. To ensure high resilience, high availability, and timely detection of attacks on
systems and networks, the MIIs shall implement suitable mechanisms to monitor
the capacity utilization of critical systems and networks.
100. The MIIs shall establish appropriate security monitoring systems and processes
to facilitate continuous monitoring of security events/ alerts and timely detection
of unauthorized or malicious activities, unauthorized changes, unauthorized
access, and unauthorized copying and transmission of data/ information held in
a contractual or fiduciary capacity, by internal and external parties. The security
logs of systems, applications and network devices exposed to the internet shall
also be monitored for anomalies.
101. Suitable alerts shall be generated in the event of the detection of unauthorized or
abnormal system activities, transmission errors, or unusual online transactions.
15V. Respond
102. The MIIs are advised to formulate a Cyber Crisis Management Plan (CCMP) based
on the architecture deployed, threats faced and the nature of operations. The
CCMP shall define the various cyber events, incidents, and crises faced by the
MIIs, the extant cyber threat landscape, the cyber resilience envisaged, incident
prevention, cyber crisis recognition, mitigation, and management plan. The
CCMP shall be approved by the SCOT of the MIIs and the Board of the MIIs. The
CCMP shall also be reviewed and updated annually.
103. The MIIs shall develop an Incident Response Management Plan as part of their
CCMP. The response plan shall define responsibilities and actions to be
performed by its employees and support/ outsourced staff in the event of a cyber-
attack or cyber security incident.
104. Any cyber-attack, cyber security incident, and/ or breach shall be notified to
IFSCA and CERT-In within 6 hours of noticing/ detecting such incidents or being
brought to notice about such incidents. This information shall be shared with
IFSCA through cyber-incidents@ifsca.gov.in.
105. The MIIs shall submit the interim report within 3 days followed by a detailed root
cause analysis report within 30 days. The MIIs shall take mitigation measures for
the same within 7 days from detection of the incident.
106. The incident shall also be reported to CERT-In in accordance with the guidelines/
directions issued by CERT-In from time to time. Additionally, the MIIs, whose
systems have been identified as "Protected systems" by NCIIPC shall also report
the incident to NCIIPC.
107. The quarterly reports containing information on cyber-attacks, cyber security
incidents and breaches experienced by the MIIs and measures taken to mitigate
vulnerabilities and attacks including information on bugs/ vulnerabilities shall be
submitted to IFSCA within 15 days from the quarters ending June, September,
December and March of every year.
108. For the purpose of coordinating incident response, the MIIs shall regularly update
the contact details of service providers, intermediaries and other stakeholders.
109. The MIIs shall collect and preserve data related to the incident, such as system
logs, network traffic, forensic images, etc., of affected systems in a secure and
forensically sound manner.
16VI. Recover
110. A recovery plan shall be formulated by the MIIs and approved by their respective
SCOT for the MIIs. The backup and recovery plan shall include policies and
software solutions that work together to maintain business continuity in the event
of a security incident. Such a plan shall include guidance on the restoration of
data with the backup software used by the MIIs.
111. The recovery plan of the MIIs shall have plans for the timely restoration of systems
affected by cyber security incidents/ attacks or breaches. The recovery plan shall
be in line with the Recovery Time Objective (RTO) and Recovery Point Objective
(RPO) specified by IFSCA’s Guidelines for Business Continuity Plan (BCP) and
Disaster Recovery (DR) for Market Infrastructure Institutions (MIIs), amended
from time to time.
VII. Resilience
112. The MIIs shall perform cyber resilience testing by undertaking regular business
continuity drills and specific scenario exercises at least once in a financial year to
check the readiness of the organization and the effectiveness of existing security
controls at the ground level. This shall assess the effectiveness of people,
processes and technologies to deal with such attacks. The said scenarios may be
devised by the MIIs in consultation with their respective SCOTs. Critical third-
party service providers may also be included in the cyber resilience testing.
113. The MIIs shall place the results of the cyber resilience testing before their SCOT.
The lessons learned from conducting such cyber resilience testing shall be
shared with IFSCA within 3 months from the end of the financial year.
VIII. Cyber Security Operation Center (C-SOC)
114. The MIIs shall have a Cyber Security Operation Center (C-SOC) that would be a
24x7x365 set-up manned by dedicated security analysts.
115. The MIIs may choose any of the following models:
i. A standalone C-SOC,
ii. C-SOC shared by the MII with its group/ parent entities (that are also
recognised MIIs),
iii. C-SOC that may be shared by the MII with other recognised MII(s).
17116. The MIIs shall have a contingent C-SOC at their respective DR sites with identical
capabilities with respect to the primary C-SOC.
IX. Periodic Audit
117. The MIIs shall engage only CERT-In empanelled Information Security (IS) auditor
for conducting cyber security audit to audit the implementation of all provisions
mentioned in these guidelines.
118. A CERT-In empanelled IS auditing organization can audit the MIIs for a maximum
period of three consecutive years. Subsequently, the said IS auditing organisation
shall be eligible for auditing the MIIs again only after a cooling off period of two
years.
119. The auditor engaged by the MIIs shall not have any conflict of interest with the
MIIs. The audit shall be conducted annually and a report in this regard shall be
submitted to IFSCA by the MIIs within 120 days from the end of the financial year.
120. Though the minimum audit frequency prescribed is annual, the MIIs may choose
to adopt a higher frequency commensurate with their cyber risks and the
criticality of their systems.
121. Along with the cyber audit reports, the MIIs shall also submit a declaration from
the Managing Director (MD)/ Chief Executive Officer (CEO) in this regard.
122. All MIIs shall obtain ISO 27001 certification within 2 years of the issuance of these
guidelines. The evidence of certification shall be submitted to IFSCA.
123. To ensure that all the open vulnerabilities in the IT assets of the MIIs have been
fixed, revalidation cyber audit shall also be done in a time-bound manner.
124. The Audit Management process of the MIIs shall include (but not be limited to)
audit program/ calendar, planning, preparation, delivery, evaluation, reporting,
and follow-up, etc.
125. IFSCA shall at any time perform search and seizure of the IT resources of the MIIs
storing/ processing data and other relevant IT resources (including but not limited
to logs, user details, etc.) pertaining to the MIIs. In this process, IFSCA or IFSCA-
authorized personnel/ agency may access MII's IT infrastructure, applications,
data and documents, including other necessary information given to, stored or
processed by third-party service providers.
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