The financial sector’s digital evolution has enhanced efficiency and connectivity while simultaneously creating new vulnerabilities to cyber-attacks. In response to these emerging risks, the Securities and Exchange Board of India (SEBI) developed a comprehensive Cybersecurity and Cyber Resilience Framework (CSCRF). This framework is more than a regulatory checklist; it is designed to safeguard the critical IT infrastructure and sensitive data of Regulated Entities (REs). The governance emphasizes on measurable Cybersecurity controls that map directly to board-level risk objectives. The framework’s attention to Access Control, Privileged Access Management, Role-Based Access Control, Multi-Factor Authentication, and indispensable Audit Trails are foundational cybersecurity controls and audit controls for cyber resilient posture supported.  

SEBI, being a financial regulator understands how security breach within a single RE can trigger systemic ripple effects, erode investor confidence and potentially destabilize the national economy. The financial sector has always been a prime target for cyber-attacks considering the amount of personal and financial data it manages.  Organizations that align with SEBI’s CSCRF not only enhance their security posture but also improve audit controls and compliance outcomes.In this blog, we look at the fundamentals of CSCRF to embed defensible audit controls related to Privileged Access Management, Granular Control, Audit Trails.   

What are Access Controls and their Privileges?

Access controls function as security mechanisms that restrict and monitor entry, similar to security measures in physical spaces like shopping centers, restaurants, or banks. While visitors are limited to designated areas, security personnel and monitoring systems enforce these restrictions. The staff or admin people may have more elevated access based on roles and duties to perform their responsibilities. Similarly in the IT infrastructure, access controls must translate into precise access rights tied to roles and duties, strengthening identity security while reducing business risk through effective cybersecurity controls. The access controls in an IT environment can be as simple as the usage of passwords, multi-factor authentications, selective access rights to the systems. IT and Cybersecurity frameworks as a foundational pillar, specifies the principles of access controls and guidelines to enforce it effectively.   

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The SEBI’s CSCRF covers the principles including principle of least privilege, zero-trust model, maker-checker framework, and periodic reviews of the logs generated, timely termination procedures and application and user whitelisting as a part of the standards and guidelines. Briefing about the principles, zero trust model originates from the idea that ‘never trust, always verify’ rather than ‘trust by default within the perimeter’. To effectively implement ‘denied by default’, broad and unrestricted permissions are counterproductive. Principle of Separation of Duties requires two individuals for critical actions, one to initiate and another to approve thereby creating enhanced accountability and transparency. This approach improves authorizations for Privileged Users without expanding the risk surface.  

Access control intensity varies based on organizational classification. Organizations classified as MIIs and Qualified REs are mandated to enforce complex mechanisms like zero-trust models and just-in-time access. Incorporating just-in-time access limits standing privileges and tightens audit controls. These are not just technical controls but a procedural one, addressing human-centric risks like insider threats, fraud, and errors.  

Elevating Security through Privileged Access Management

Cyber criminals frequently target the privileged accounts used by the administrators and other super users or privileged users who have access to all the files, directories, resources and privileged rights such as software installation, configuration modifications, and user data editing capabilities, which implies the need of PAM solutions to mitigate risks. When unauthorized individuals gain access to these privileged accounts, organizations face severe business threats including data breaches, sensitive data loss, and operational disruptions.  

To mitigate these risks, vectors of the privileged accounts, every organization shall implement pragmatic privileged access management practices and solutions considering the size and nature of the organization. CSCRF as a part of its framework provides a graded approach on the controls and requirements of Privileged Access management based on the type of the organization’s classification. To the core, it mandates practices such as identifying the privileged accounts with elevated rights and access, continuous monitoring of the privileged accounts, implementing PAM solutions, periodical reviews of the logs and access of the privileged accounts, limited access provisioning and therefore having a consistent privileged access management process or a solution in place.  

Privileged Access Management plays an important role in ensuring the grip over the cybersecurity defense. As a part of the strategy, implementing practices like just-in-time access and strong Endpoint Privilege Management with session recording, can eliminate threats arising from persistent privileges. Furthermore, session management and recording capabilities shall provide essential accountability and invaluable data for forensic analysis. Usage of Multi Factor Authentication and automated credential management leads to effective privileged access management. This mitigates risks associated with hardcoded credentials and enhances security in dynamic environments which collectively strengthen cybersecurity controls across privileged accounts related workflows.   

Granular Control through Role-Based Access Control (RBAC)

The underlying idea behind the Role-based Access Controls is to identify and segregate the different roles of the organization and thereby identifying the associated granular access rights of each role to perform their respective roles and responsibilities.  Large organizations with many employees often use RBAC to simplify access management and maintain information security for digital resources thereby protecting the identity security and reducing insider risks. By restricting users’ access to the resources needed for their roles, RBAC can help defend against malicious insiders, negligent employees and external threat actors.  

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RBAC systems enable organizations to adopt a granular approach to Identity Access Management, building foundations to assign rights and permissions precisely while providing limited access to organizational data. While RBAC is not named as a standard in the SEBI CSCRF, its underlying principles are deeply embedded within the framework’s emphasis on least privilege and segregation of duties. It complements the principle of least privilege, separation of duties, and audit and compliance evidence.  

Multi-Factor Authentication

Multi-Factor Authentication (MFA) serves as a security enhancement which strengthens the authenticity of system and information access for authorized users representing a core pillar of enterprise security. As the name suggests, it relies on more than one key to a gain access, rather than relying only on one key, for example. the password or the PINs. Combining passwords with additional authentication methods   such as a PIN, a code from a mobile app or SMS, or a biometric scan like a fingerprint, makes it significantly harder for unauthorized individuals to gain access.  

MFA is a mandatory security measure within the broader cybersecurity framework for strengthening authentication. SEBI specifies applicability of MFA for all critical systems and users accessing from both trusted and untrusted networks, all users with remote access provisioning through Virtual Private Networks and all internet-facing and customer-facing applications.   

This comprehensive MFA mandate reflects a recognition that passwords alone are insufficient, and that a layered, adaptive authentication approach is essential to protect financial entities from sophisticated cyber threats while improving threat detection when combined with behavioural signals. 

Audit Trails and Logs

Audit trails and logs are fundamental records that document activities within computer systems like a security camera capturing events in a building, ensuring effective audit controls. In simple terms, an audit trail is a chronological sequence of actions, such as who accessed a file, what changes were made, and when they occurred. Logs, on the other hand, are digital notes that capture system events, errors, or user interactions. For example, email systems would record unauthorized user’s login attempt, documenting the location, time and number of unauthorize attempts. An immutable audit trail accelerates the investigations and reduces the containment time. 

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These tools serve essential functions in cybersecurity frameworks, supporting threat detection, investigation of incidents, and ensuring audit and compliance requirements. The tools correlate patterns with previous logs and algorithms to detect unusual patterns such as repeated failed logins potentially signalling hacking attempts. Moreover, these activities are recorded as logs and would be subjected to periodical review to support the audit and compliance requirements to verify if the protocols and audit controls were followed.  

Regarding CSCRF mandatory requirements, organization shall manage logs by adhering to the log management policy to collect various types of logs such as system, application, security logs including remote access logs and analysing them for anomalies. These logs shall be collected, monitored and analysed by integrating with Security Information and Event Management Tools (SIEM) and Security Operations Centre (SOC) elevating the overall monitoring and enhancing the enterprise’s security through comprehensive audit trails. The retention policies shall be aligned with laws like the IT Act 2000 ensuring logs are maintained for a minimum period of 2 years. Periodic audits should be conducted to identify threats and anomalies, initiating steps to strengthen their logging systems against new threats, ultimately strengthening overall security. 

Real-World Impact: SEBI CSCRF at Work

In March 2025, SEBI penalised HDFC Securities 65 lakh for cybersecurity breaches, demonstrating gaps in threat detection and endpoint visibility. The analysis revealed that there was poor real-time alerting, slow detection of unauthorised activity, and inadequate endpoint monitoring and user behaviour analytics. These lapses delayed threat response and increased risk exposure. This example highlights the importance of SEBI-required cybersecurity controls like real-time monitoring, SIEM, Role-Based Access Control (RBAC), and continuous audit trails. The adoption of these measures is in line with the SEBI Cybersecurity and Cyber Resilience Framework (CSCRF) and is crucial not only to comply with regulations but also to safeguard sensitive data and keep investors confident.   

Conclusion

SEBI’s CSCRF integrates cybersecurity principles with solid governance practices and guidelines to cultivate a mindset to foster a proactive and an organization-wide security culture. By focusing on technology, process, and people, SEBI ensures that entities are equipped to handle, recover, and evolve after cyber incidents through effective audit controls.  For regulated entities, adherence to SEBI CSCRF goes beyond mere regulatory compliance, to encompass protecting sensitive data, preventing fraud, guarding against insider threats, strengthening identity security and maintaining public trust. Taking a proactive and comprehensive approach to Access Control and Audit Trails, strengthening the core cybersecurity controls while leveraging automation, transforming compliance into a genuine strategic advantage. This approach helps entities not only to meet the regulatory obligations, but also to operate with resilience, consequently in adapting to future cyber challenges while safeguarding the interests of investors and the broader economy. 

Why Choose InCorp Global?

At InCorp, we provide comprehensive services related to cybersecurity, information security, and data privacy. Our team specializes in governance that aligns risk and compliance objectives while designing customized access controls and audit-logging practices that are regulator-ready and operationally sustainable. To learn more about our services, you can write to us at info@incorpadvisory.in or reach out to us at (+91) 77380 66622. 

Authored by:
Nakul Pranav | Cybersecurity  

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