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SEBI CSCRF · Programme context, not legal advice · Reviewed August 2026

A CSCRF file is built from dated evidence, not assertions.

ShadowMap does not tell you which tier you fall into and does not sign your audit. What it produces is the record underneath: continuous external-monitoring evidence, a remediation timeline trail, accepted-risk entries that survive the decision that created them, and an action log per finding.

Said here rather than in a footer: this is programme context, not legal advice. Nothing on this page interprets the framework for your entity, states which obligations attach to your tier, or asserts that any artefact will satisfy your auditor. That assessment work belongs to your compliance function and to Security Brigade.

Boundary

This is not the page that tells you what CSCRF requires of you

Which tier you fall into depends on your registration category and on your client count, assets under management or trading volume — and those tables have been rewritten twice since the framework was issued.

Security Brigade publishes the assessment side of this: the classification wizard, the obligation calendar and the per-tier cards. Taking your classification from a monitoring vendor's marketing page is the wrong way round, and duplicating it here would mean two pages that disagree the next time SEBI issues a clarification.

What follows covers one narrow thing instead. A CSCRF review asks an organisation to demonstrate that certain things were happening continuously, not that they were true on the day someone looked. Continuous external monitoring leaves artefacts behind that speak to some of those expectations and are silent on most of them. The table below states which are which, and every row carries what it does not cover.

Evidence mapping

What is asked for, and what actually demonstrates it

One row per evidence expectation. The note beneath each row is the limit of that artefact, placed on the claim rather than in a footnote — including the row where the honest answer is that the framework does not ask for this at all.

CSCRF evidence expectations mapped to external-monitoring artefacts
What a CSCRF review asks you to showThe artefact that shows itProduced by
A current inventory of assets A dated external asset inventory — domains, subdomains, reachable services, exposed panels — with the attribution evidence that ties each entry to your organisation rather than to a similar name. Attack Surface Management
CSCRF asset inventory covers the whole estate, including internal systems. Outside-in discovery covers the internet-facing part of it and nothing else — the internal register stays yours to maintain.
Monitoring that is continuous rather than point-in-time A change record rather than a report: what appeared, what changed, when it was first observed, and when it stopped being observed. The record is the evidence, not a PDF generated from it. Attack Surface Management
This is a record of external exposure. It is not a SOC, and it does not discharge whatever SOC or M-SOC obligation attaches to your tier. Which one attaches, and on what terms, is a classification question this page does not answer — Security Brigade publishes the tier cards that do.
Closure of findings inside a defined remediation timeline Per-finding timestamps — first observed, acknowledged, owner assigned, closed — measured against the remediation window your own policy sets, so adherence is a query rather than a reconstruction. The platform
The window is yours, not ours. CSCRF does not publish one universal remediation SLA, so the trail records adherence to whatever timeline your policy and IT Committee have defined.
Risks knowingly carried rather than remediated An accepted-risk record holding the finding, the approver, the rationale and the review date — kept alongside the open queue rather than deleted out of it, so an accepted risk resurfaces when its review date arrives. The platform
Acceptance is a decision your IT Committee or its delegate makes. The platform records the decision and keeps the finding visible; it does not make the decision, approve it, or judge whether it was reasonable.
Third-party and supply-chain exposure Vendor-side external findings scored with the identical categories, the same maths and the same bands used on your own estate — so an internal target and a vendor threshold are directly comparable. Third-Party Risk Management
The August 2025 clarifications place supply-chain risk assessment in consultation with the IT Committee. Outside-in vendor findings are an input to that assessment. They are not the assessment, and they do not see anything inside a vendor perimeter.
Exposure that has been tested, not only observed — which CSCRF does not ask for Where it is safe and authorised, a validation record naming what was tested, the scope it was bounded to, the time it ran and the audit identifier for the run. Continuous Automated Red-Teaming
CSCRF does not require this. SEBI made BAS and Continuous Automated Red-Teaming recommendatory on 28 August 2025 — see the section below before treating it as an obligation. Validation is also never universal: what was not tested says so.
Awareness of directives issued against you A dated log of advisories and directives from the regulators in scope for you, matched against the technology actually discovered on your estate — so the question becomes whether a directive applies to you rather than whether it exists. Regulatory Intelligence
Programme context, never legal advice. Tracking covers 31 regulators across 12 jurisdictions, which is useful precisely because SEBI amends this framework often — but a feed cannot tell you whether an amendment binds you.
An audit trail of who did what An action log per finding: who changed its state, what they changed it to, and when. Nothing is deleted from the queue, so a closed or accepted finding is still there to be produced. The platform
This is the platform’s own log and covers activity inside ShadowMap. It is one source among the several a CSCRF review will ask for, not the whole audit trail.

CSCRF evidence expectations mapped to external-monitoring artefacts

A current inventory of assets

The artefact that shows it
A dated external asset inventory — domains, subdomains, reachable services, exposed panels — with the attribution evidence that ties each entry to your organisation rather than to a similar name.

CSCRF asset inventory covers the whole estate, including internal systems. Outside-in discovery covers the internet-facing part of it and nothing else — the internal register stays yours to maintain.

Monitoring that is continuous rather than point-in-time

The artefact that shows it
A change record rather than a report: what appeared, what changed, when it was first observed, and when it stopped being observed. The record is the evidence, not a PDF generated from it.

This is a record of external exposure. It is not a SOC, and it does not discharge whatever SOC or M-SOC obligation attaches to your tier. Which one attaches, and on what terms, is a classification question this page does not answer — Security Brigade publishes the tier cards that do.

Closure of findings inside a defined remediation timeline

The artefact that shows it
Per-finding timestamps — first observed, acknowledged, owner assigned, closed — measured against the remediation window your own policy sets, so adherence is a query rather than a reconstruction.
Produced by
The platform

The window is yours, not ours. CSCRF does not publish one universal remediation SLA, so the trail records adherence to whatever timeline your policy and IT Committee have defined.

Risks knowingly carried rather than remediated

The artefact that shows it
An accepted-risk record holding the finding, the approver, the rationale and the review date — kept alongside the open queue rather than deleted out of it, so an accepted risk resurfaces when its review date arrives.
Produced by
The platform

Acceptance is a decision your IT Committee or its delegate makes. The platform records the decision and keeps the finding visible; it does not make the decision, approve it, or judge whether it was reasonable.

Third-party and supply-chain exposure

The artefact that shows it
Vendor-side external findings scored with the identical categories, the same maths and the same bands used on your own estate — so an internal target and a vendor threshold are directly comparable.

The August 2025 clarifications place supply-chain risk assessment in consultation with the IT Committee. Outside-in vendor findings are an input to that assessment. They are not the assessment, and they do not see anything inside a vendor perimeter.

Exposure that has been tested, not only observed — which CSCRF does not ask for

The artefact that shows it
Where it is safe and authorised, a validation record naming what was tested, the scope it was bounded to, the time it ran and the audit identifier for the run.

CSCRF does not require this. SEBI made BAS and Continuous Automated Red-Teaming recommendatory on 28 August 2025 — see the section below before treating it as an obligation. Validation is also never universal: what was not tested says so.

Awareness of directives issued against you

The artefact that shows it
A dated log of advisories and directives from the regulators in scope for you, matched against the technology actually discovered on your estate — so the question becomes whether a directive applies to you rather than whether it exists.

Programme context, never legal advice. Tracking covers 31 regulators across 12 jurisdictions, which is useful precisely because SEBI amends this framework often — but a feed cannot tell you whether an amendment binds you.

An audit trail of who did what

The artefact that shows it
An action log per finding: who changed its state, what they changed it to, and when. Nothing is deleted from the queue, so a closed or accepted finding is still there to be produced.
Produced by
The platform

This is the platform’s own log and covers activity inside ShadowMap. It is one source among the several a CSCRF review will ask for, not the whole audit trail.

The one thing to get right

CSCRF does not mandate Continuous Automated Red-Teaming

It read that way once. It has not since August 2025, and any vendor page still selling on that requirement is selling on one that no longer exists.

Aug 2024 → Aug 2025

BAS and CART under CSCRF, before and after

What the master circular said
The Cyber Security and Cyber Resilience Framework issued on 20 August 2024 used mandatory language for Breach and Attack Simulation and for Continuous Automated Red-Teaming: regulated entities shall deploy them.
What the 28 August 2025 technical clarifications changed
SEBI replaced that with a recommendation, to be taken in consultation with the IT Committee. The same circular moved other controls in the same direction — ISO 27001 and the mobile application security guidelines both went from mandatory to recommended for part of the population. Which part, and whether your entity is in it, is a classification question Security Brigade answers.
What is still mandatory, and what that leaves
A half-yearly red teaming exercise remains mandatory under the framework for the top two tiers, and automated testing does not substitute for it — it is a scoped manual engagement and a different instrument. Whether your entity sits in one of those tiers is, again, a classification question. Continuous Automated Red-Teaming is worth deploying if your IT Committee decides it is, because it keeps the estate tested between those engagements — not because a circular compels you.

The trail

An evidence file accumulates. It is not assembled the week before the review.

The order is the point: every step is only defensible because the one before it carries a date nobody could have supplied afterwards.

Sourcing

What this page was reviewed against

If you are reading this long after the date below, check it against the current circular before you rely on any line of it.

Circulars this page was read againstCaution As of August 2026
  • Master framework: SEBI/HO/ITD-1/ITD_CSC_EXT/P/CIR/2024/113, the Cyber Security and Cyber Resilience Framework, dated 20 August 2024.
  • Read with the clarifications of 30 April 2025 (CIR/2025/60) and the technical clarifications of 28 August 2025 (CIR/2025/119), and alongside SEBI’s AI vulnerability detection advisory of 5 May 2026.
  • SEBI issued six further circulars and clarifications against this framework between December 2024 and August 2025. Several of them changed whether a control is mandatory at all, which is why this page carries a review date and why an undated CSCRF page should not be trusted.
  • The compliance dates have passed — the last extension ran to 31 August 2025 — so this page is written against a framework already in force rather than one being prepared for.

Deliberately excluded

  • Tier classification. It turns on your registration category and on your client count, assets under management or trading volume, and Security Brigade publishes the tool for it.
  • Any mapping to control identifiers. A published clause mapping is a claim about what the regulator requires of you, it goes stale on the next amendment, and it is advisory work rather than product documentation.
  • Data localisation, in abeyance since December 2024 and therefore not cited here as a current obligation.
  • Everything internal. Every artefact above is produced from outside your perimeter, so no internal control, no SOC obligation and no policy or governance artefact is covered.
  • Legal reading. Nothing here interprets the framework for your entity or asserts that any artefact will satisfy your auditor.

Questions this page gets asked

Before any of this goes into a compliance file

Does CSCRF require Continuous Automated Red-Teaming?

No. SEBI made Breach and Attack Simulation and Continuous Automated Red-Teaming recommendatory on 28 August 2025, to be taken in consultation with the IT Committee. The master circular of August 2024 did read as mandatory, which is why the claim persists — but any vendor still selling CART as a CSCRF requirement is selling a requirement that no longer exists. It is worth deploying on its own merits, because it keeps the estate tested between the scoped manual engagements — not because a circular compels you, and that is the case we make for it.

Does using ShadowMap make us CSCRF compliant?

No, and a platform that claims otherwise is claiming something it cannot deliver. Compliance is a determination made about your organisation by your auditor and ultimately by SEBI. What ShadowMap produces is evidence that an external monitoring control was operating — dated, scoped and attributable to specific assets. What that evidence is worth against a particular obligation is assessment work, and assessment is a Security Brigade engagement rather than a product feature.

Can you map ShadowMap to specific CSCRF control identifiers?

Not on this page, and the omission is deliberate. A published clause mapping is a claim about what the regulator requires of you. It goes stale the moment SEBI issues another clarification — six have landed since the master circular, several of them changing whether a control is mandatory at all — and it is advisory work rather than product documentation. In an engagement an adviser does that mapping against the circulars that actually bind you and against your own control set, which is the only version of it worth having.

Which tier do we fall into?

Tier turns on your registration category and on your client count, assets under management or trading volume, and those tables have been rewritten twice since the framework was issued. Taking that answer from a monitoring vendor is the wrong way round: Security Brigade publishes the classification wizard and the per-tier cards, and they are maintained against the current circulars.

Our auditor wants proof the monitoring ran, not a walkthrough. What do we hand over?

The external inventory as it stood on the dates under review, the change record covering the period, each finding with the state it was given and the timestamps around it, the accepted-risk entries with their approvers and review dates, and the action log showing who did what. It is the ordinary operating record of the platform, exported for the period as it stood — nothing is assembled specially for the review, which is the part that makes it worth reading.

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