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SEBI Circular HO/13/19/12(1)2026-ITD-1_CIMGI/10873/2026 · 05.05.2026

SEBI advisory on AI vulnerability detection tools.
Compliance, decoded.

SEBI's May 2026 directive on AI tools like Claude Mythos addresses 19 categories of regulated entities with 10 specific Annexure-A controls — AI-based VA, M-SOC onboarding, ZTNA, SBOM, and a long-term agentic-defence plan. We help you map every control, close every gap, and submit IT-committee-ready evidence.

10/10
Annexure-A Directives
19
Regulated Entity Categories
370+
BFSI Engagements
Since 2008
CERT-In Empanelled

What SEBI said

A new class of AI tools just changed your threat model.

"The rapid evolution of emerging technologies including AI-driven vulnerability identification tools (e.g., Claude Mythos) has introduced new dimensions of risks for Regulated Entities. Such tools may give rise to heightened risk exposure by enabling identification and potential exploitation of existing vulnerabilities using speed and scale."

— SEBI Circular HO/13/19/12(1)2026-ITD-1_CIMGI/10873/2026, Section A

Why every RE is in scope

Cascading risk in an interconnected market.

"Due to the interconnectedness and interdependency of market participants in the Securities Market Ecosystem, a periodic coordinated approach for vulnerability management, information sharing and monitoring/assessment is required to prevent a cascading impact."

— SEBI Circular, Section B

Who must comply

All 19 categories of regulated entities.

The advisory is not MII-only. It covers the entire market participant chain — from stock exchanges and depositories to investment advisors, KYC registration agencies, and venture capital funds.

Alternative Investment Funds (AIFs)
Bankers to an Issue (BTI) and Self-Certified Syndicate Banks (SCSBs)
Clearing Corporations
Collective Investment Schemes (CIS)
Credit Rating Agencies (CRAs)
Custodians
Debenture Trustees (DTs)
Depositories
Designated Depository Participants (DDPs)
Depository Participants
Investment Advisors (IAs) / Research Analysts (RAs)
KYC Registration Agencies (KRAs)
Merchant Bankers (MBs)
Mutual Funds (MFs) / Asset Management Companies (AMCs)
Portfolio Managers
Registrar to an Issue and Share Transfer Agents (RTAs)
Stock Brokers
Stock Exchanges
Venture Capital Funds (VCFs)

Annexure-A · Directives

The 10 controls SEBI has prescribed.

Each directive in plain English, the advisory's exact intent, and what Security Brigade delivers to close it.

01

Patch immediately + virtual patching where unavailable

"Update all operating systems and applications with the latest patches on immediate basis. As an interim measure for vulnerabilities where patches are not available, virtual patching can be considered."

How Security Brigade covers it

B-52 platform tracks every CVE applicable to your stack across engagements. Our VAPT report ships with a prioritised patch matrix mapped to CVSS severity and exploitability — plus virtual-patching recommendations (WAF rules, ModSecurity signatures, network ACLs) where vendor patches are pending.

02

Vulnerability Assessment using conventional and AI-based tools

"Conduct Vulnerability Assessment (using conventional and suitable AI based Vulnerability Assessment Tools where possible) and security audits on a regular/continuous basis in accordance with CSCRF."

How Security Brigade covers it

The advisory endorses AI-based VA tools as part of a broader VA-and-audit cadence ("where possible"). B-52 — our AI-augmented testing platform — is the engine inside every Security Brigade VA and pentest engagement. It combines structured test-case generation, attack-chain analysis, and verified-exploitable reporting with senior human auditors, and exceeds what the advisory describes. Already deployed across 370+ BFSI engagements.

03

Third-party vendors and COTS application risk assessment

"Engage with respective REs third-party vendors to release timely patches. Exchanges and Depositories shall direct their empaneled application vendors (providing COTS solution) to undertake comprehensive assessment of risks arising from AI-led vulnerability detection models — and implement safeguards including patch updates, VAPT, continuous monitoring, hardening."

How Security Brigade covers it

Our Vendor Risk Assessment service maps third-party exposure for RBI, SEBI, DPDP, NPCI, and customer-questionnaire mandates. Coupled with ShadowMap continuous attack-surface monitoring, we surface vendor and COTS application risks before AI-driven attackers do.

04

Change Management for every change (including minor)

"Any change in the systems (including minor changes) should encompass full documentation, thorough impact analysis, structured review, rigorous testing and secure deployment to ensure operational resilience and system stability."

How Security Brigade covers it

The advisory uses "should" rather than "shall" here — directional, not mandatory — but the scope expansion to "including minor changes" is significant. Pre-prod regression testing, change-driven retests, and impact analysis are built into our Lemon delivery platform. Every change-driven engagement gets the same B-52 6-phase audit — discovery, planning, scanning, exploitation, reporting, QA — without re-scoping overhead.

05

API Security: inventory, authN/Z, rate limiting, whitelisting

"API inventory updated regularly. Strong authentication and authorization with least privilege. API rate limiting and throttling. Connections strictly on a whitelist-based approach."

How Security Brigade covers it

Our API Security Testing service covers REST, GraphQL, WebSocket, and gRPC against OWASP API Top 10 — including BOLA, BFLA, mass assignment, and rate-limit abuse. Output includes an API inventory with per-endpoint risk classification.

06

SOC monitoring + SOAR/SIEM + M-SOC onboarding

"Day-to-day monitoring of systems and networks. Examine all SOC alerts including low-priority. Implement SOAR playbooks integrated with SIEM. The Market SOC (M-SOC) by NSE and BSE provides 24x7 monitoring — all eligible REs not yet onboarded shall expedite the onboarding."

How Security Brigade covers it

We help REs prepare for M-SOC onboarding through gap-assessment, log-source readiness, SOAR playbook design, and red-team validation against incident-response capacity. Detection-in-depth scenarios are tested with Mythos-class adversary simulation.

M-SOC eligibility unclear? We map it in week 1 of the gap assessment.

Onboarding paperwork, log-source readiness, SOAR playbook design — packaged for your IT-committee submission.

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07

CSCRF Risk Assessment with AI-based threat scenarios

"CSCRF mandates periodic risk assessment of REs and Third Party Service Providers. Risk assessment shall include comprehensive scenario-based testing for both internal and external risks. The capability of AI-based models may also be considered as one of the risk scenarios."

How Security Brigade covers it

Our CSCRF readiness engagement now ships with an AI-threat-model addendum: scenario-based testing for AI-augmented attacker capabilities (Mythos-class speed-and-scale exploitation, agentic chain abuse, prompt-injection across customer-facing AI features).

08

Zero Trust Network Access + system hardening

"Implement system hardening by adopting secure configurations, disabling unnecessary services and default accounts, and enforcing solutions like least privilege and Zero Trust Network (ZTNA) to minimize the attack surface."

How Security Brigade covers it

Network and infrastructure hardening reviews against CIS benchmarks, ZTNA architecture validation, and identity-perimeter testing. Our Network Penetration Testing service explicitly tests least-privilege enforcement and lateral-movement boundaries.

09

Asset Inventory + Software Bill of Materials (SBOM)

"Periodically update Asset Inventory and Software Bill of Materials for all critical applications including open source stack."

How Security Brigade covers it

B-52 phase-1 fingerprinting builds a per-application SBOM (with CVE applicability mapping for each component) on every engagement. ShadowMap maintains a continuously-updated asset inventory across your external attack surface.

10

IT-committee guidance + long-term plan for AI in detection and agentic mitigation

"MIIs and other Regulated Entities shall seek guidance from their respective IT committees for mitigating risks emanating from AI-led vulnerability detection models. Further, all REs need to prepare a long-term plan for usage of AI in detection and autonomous/agentic mitigation. Also, undertake other measures including recalibration of risks for AI accelerated threats, AI augmented SOC transformation, and continuous vulnerability management using AI tools."

How Security Brigade covers it

Item 10 has two distinct obligations: a binding "shall seek guidance" from your IT committee, and a directory "need to prepare" a long-term AI defence plan. The plan itself is the RE's deliverable — it must be ratified by the IT committee, not authored by an external auditor. Security Brigade supports the plan-drafting effort with a structured input package: AI VA tooling selection criteria, agentic-detection guardrails, SOC AI integration patterns (alert triage, threat-intel enrichment, automated containment), and a risk-recalibration framework for AI-accelerated threats. The IT committee owns ratification.

The new coordination layer

cyber-suraksha.ai task force

Constituted with representatives from MIIs, QRTAs, all QREs, and other stakeholders, with the mandate to coordinate cyber response across the securities ecosystem.

Email: [email protected]

  • Closely examine the cybersecurity risks posed by AI-based models and devise a uniform mitigation strategy
  • Facilitate sharing of threat intelligence, best practices on vulnerability management, use cases and playbooks
  • Report on a priority basis cyber incidents, malicious activities, significant attack vectors, and information on vulnerabilities
  • Review the cyber security posture of third-party application service providers including empaneled vendors

Implementation roadmap

A pragmatic 90-day path to readiness.

Sequenced so each milestone produces evidence the IT committee can review.

Weeks 1–2

Gap assessment

Map current cyber posture against the 10 Annexure-A directives + CSCRF baseline. Inventory APIs, COTS vendors, AI/ML pipelines, and SOC log sources. Identify M-SOC onboarding gaps.

Weeks 3–6

AI-augmented VAPT cycle

Full B-52 powered VAPT covering AI-augmented attacker scenarios + AI-system-defender scenarios. API inventory delivered. Patch matrix and virtual-patching recommendations issued.

Weeks 7–9

SOAR / SIEM / M-SOC integration

SOAR playbooks designed and tested. SIEM detection-coverage validated against AI-led attack chains. M-SOC onboarding paperwork and log-source readiness completed where applicable.

Weeks 10–12

AI long-term plan + IT-committee submission

Annexure-A item 10 deliverable: long-term plan for AI in detection and autonomous/agentic mitigation. Risk register recalibrated for AI-accelerated threats. Submission package for the IT committee.

The capability

B-52 — the AI-augmented testing platform inside every engagement.

B-52 is Security Brigade's AI-augmented testing platform. It generates structured test plans, maps attack chains, and verifies exploitability before findings reach the report — across both VA discovery and pentest execution. In our experience across 6,700+ engagements, this approach delivers coverage well above what manual-only testing typically achieves, with every finding manually verified by a senior auditor before delivery.

Annexure-A item 2 endorses AI-based VA tools "where possible" inside the broader CSCRF VA-and-audit cadence. B-52 covers that ask and goes further — exceeding what the advisory describes, deployed across 370+ BFSI engagements.

  • 6,700+ engagements powered by B-52
  • 370+ BFSI engagements (banks, NBFCs, MIIs, brokers, AMCs)
  • Since 2008 CERT-In empanelled — required for the formal CSCRF VAPT cycle
  • Verified every finding manually validated before delivery
  • 5–15 attack chains mapped per typical engagement
  • 20+ years operating in cybersecurity

FAQs

What CISOs and IT committees keep asking.

Is this advisory binding?

The document is titled "Advisory" but several items use directive language. Item 3 (Exchanges and Depositories "shall direct" empaneled application vendors) and item 6c ("all eligible REs not yet onboarded shall expedite" M-SOC onboarding) are clear "shall" obligations. Item 10 mixes a "shall seek guidance from their respective IT committees" obligation with a "need to prepare" expectation around the long-term AI plan itself — the consultation is binding, the plan is directory. The advisory is issued under Section 11(1) of the SEBI Act, 1992 — the same statutory authority CSCRF was issued under. Treat the "shall" items as required; treat the "should" and "need to prepare" items as expected with audit-trail evidence.

How does this advisory relate to the CSCRF?

The advisory explicitly says it should be read in conjunction with the Cybersecurity and Cyber Resilience Framework. Where CSCRF mandated periodic VAPT and risk assessment, this advisory adds AI-based VA tools (Annexure-A item 2), AI-aware risk scenarios (item 7), M-SOC onboarding (item 6c), SBOM (item 9), and a long-term agentic-defence plan (item 10). This advisory does not change CSCRF's existing VAPT cadence (annual for MIIs, half-yearly for QREs, change-driven for all REs); it adds AI-aware controls inside that cadence. Treat the two as one continuous control set, not separate workstreams.

Are AI-based vulnerability assessment tools mandatory now?

The advisory says "using conventional and suitable AI-based Vulnerability Assessment Tools where possible." That language is permissive on the AI side ("where possible") but mandatory on the assessment ("Conduct Vulnerability Assessment"). In practice, regulated entities should be evaluating AI-based VA tooling for adoption — and engaging auditors who already operate AI-driven testing platforms. Security Brigade has been delivering AI-driven VAPT through B-52 for years.

Who must comply? Is this MII-only?

No. The advisory addresses 19 categories of regulated entities — including AIFs, mutual funds, AMCs, portfolio managers, investment advisors, research analysts, KRAs, RTAs, merchant bankers, custodians, debenture trustees, and venture capital funds — alongside the more obvious MIIs (exchanges, depositories, clearing corporations, brokers).

What is M-SOC and who must onboard?

The Market SOC (M-SOC) is a centralised security platform jointly established by NSE and BSE that provides 24x7 real-time monitoring and threat detection across digital infrastructure. The advisory directs that "all eligible REs (not on boarded with any M-SOC) shall expedite the onboarding." MIIs are also required to run awareness and handholding programs to support member onboarding.

What is the cyber-suraksha.ai task force?

A task force constituted by SEBI ([email protected]) comprising representatives from MIIs, QRTAs, all QREs, and other stakeholders. Its mandate covers AI cyber-risk examination, threat-intelligence sharing, priority incident reporting, and review of third-party vendor security posture. It is the standing forum through which subsequent guidance is likely to flow.

Why does the advisory name Mythos specifically?

The advisory cites "Claude Mythos" as a representative example of AI-driven vulnerability identification tools — the named threat is the class of capability, not a single product. SEBI is signalling that the regulator is tracking AI tools that can identify and exploit vulnerabilities at speed and scale — and expects regulated entities to recalibrate their cyber posture accordingly.

What does Security Brigade deliver to support compliance?

A four-track engagement: (1) gap assessment against Annexure-A; (2) full B-52-powered VAPT covering AI-augmented attacker scenarios and AI-system-defender scenarios; (3) M-SOC onboarding readiness and SOAR/SIEM tuning; (4) long-term AI defence plan for IT-committee submission. CERT-In empanelled since 2008, with 370+ BFSI engagements and the B-52 platform inside every assessment.

Start your gap assessment.

Map your current cyber posture against all 10 Annexure-A directives in two weeks. The output is an evidence pack for your IT committee — not a sales call.

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