SEBI CSCRF for AMC / Mutual Funds
3 tiers are reachable, decided by assets under management (aum) in inr crores.
Classification
What decides a AMC / Mutual Fund's tier
Asset managers are classified on assets under management, which tracks the number of investors relying on the systems rather than the complexity of them. The distinctive feature of an AMC's estate is how much of it belongs to somebody else: registrars, exchange order-routing platforms and distributor channels all sit inside the investor journey while sitting outside the AMC's own perimeter.
Assets Under Management (AUM) in INR crores
Some answers put a AMC / Mutual Fund outside CSCRF entirely. The wizard states the exact threshold and shows the exemption alongside the result.
Obligations
What each reachable tier requires
Only the tiers a AMC / Mutual Fund can actually land in are listed.
Qualified REs
KRAs (post Apr 2025), Institutional DPs not registered as Stock Brokers, Stock Brokers >10L clients OR >₹10L Cr trading volume, AMCs ≥₹1L Cr AUM, Custodians ≥₹10L Cr AUC.
VAPT
Once a year (twice a year if CII)
Cyber audit
Twice a year
Red team
Half-yearly
Drill
Half-yearly
- ISO 27001 — recommended (Aug 2025 made voluntary; was mandatory in master)
- CCI self-assessment — annually
- IT Committee with external cybersecurity expert — mandatory, quarterly meetings
- 24×7 SOC (own / group / Market SOC / 3P-managed); half-yearly functional efficacy review
- HSM mandatory under cloud framework
- Direct CISO reporting line to MD/CEO; grade ≥ CTO/CIO
- RTO 2 hours / RPO 15 minutes
ISO 27001
Recommended, not mandatory
Cyber Capability Index
Self-assessment, annually
M-SOC
Eligible for SEBI M-SOC, encouraged
HSM for key storage
Mandatory
CISO reporting line
CISO reports directly to MD/CEO
IT Committee
Mandatory, meets quarterly
RTO
2 hours (IOSCO)
RPO
15 minutes
Incident reporting
6 hr to SEBI Incident Reporting portal + [email protected] AND CERT-In (per April 2022 Directions). Interim report 3d, mitigation 7d, RCA 30d, incident-VAPT 45d (CSCRF Annexure-O).
Mid-size REs
Stock Brokers 1-10L clients OR ₹1-10L Cr volume, AMCs ₹10k-1L Cr AUM, Custodians ₹1-10L Cr AUC, Portfolio Managers ≥₹10k Cr AUM, AIF+VCF managers >₹10k Cr corpus, RTAs 1-2 Cr folios.
VAPT
Once a year (commences Q1 of FY)
Cyber audit
Once a year (twice a year if providing IBT or Algo trading)
Drill
Annually
- IT Committee with external cybersecurity expert — mandatory, quarterly meetings
- 24×7 SOC (own / Market SOC / 3P-managed); annual functional efficacy review
- HSM — risk-assessed alternative permitted (Board approval required)
- Designated CISO or equivalent officer
- Annual cyber resilience posture evaluation (EV.ST.S5)
M-SOC
Eligible for SEBI M-SOC, encouraged
HSM for key storage
Risk-assessed alternative permitted
CISO reporting line
Designated officer is sufficient
IT Committee
Mandatory, meets quarterly
RTO
As set in your CCMP
RPO
As set in your CCMP
Incident reporting
6 hr to SEBI Incident Reporting portal + [email protected] AND CERT-In (per April 2022 Directions). Interim report 3d, mitigation 7d, RCA 30d, incident-VAPT 45d (CSCRF Annexure-O).
Small-size REs
Stock Brokers 10k-1L clients OR ₹10k-1L Cr volume, AMCs <₹10k Cr AUM, Custodians <₹1L Cr AUC, Portfolio Managers ₹3k-10k Cr AUM, AIF+VCF managers ₹3k-10k Cr corpus, RTAs 10k-1Cr folios, all active Merchant Bankers, Non-individual IAs (registered in another category).
VAPT
Once a year
Cyber audit
Once a year (twice a year if providing IBT or Algo trading)
Drill
Annually
- Onboard to Market SOC (NSE/BSE) — MANDATORY, unless RE has own SOC and submits efficacy reports
- Designated CISO or equivalent officer
- IT Committee optional (otherwise MD/CEO/Board approves CSCRF compliance)
- Annual cyber resilience posture evaluation
M-SOC
Market SOC mandatory unless you run your own
HSM for key storage
Risk-assessed alternative permitted
CISO reporting line
Designated officer is sufficient
IT Committee
Not mandated
RTO
As set in your CCMP
RPO
As set in your CCMP
Incident reporting
6 hr to SEBI Incident Reporting portal + [email protected] AND CERT-In (per April 2022 Directions). Interim report 3d, mitigation 7d, RCA 30d, incident-VAPT 45d (CSCRF Annexure-O).
Scope
What a CSCRF VAPT has to reach at a AMC / Mutual Fund
A redemption is an irreversible movement of money initiated through a customer channel, so the authentication and authorisation around it carry the same weight they do at a broker. The distributor surface is the underrated one: a distributor login typically reaches many investors' records, is issued to a third party, and is rarely governed as tightly as an employee credential.
Cyber audit covers 100% of critical systems and a 25% sample of the rest, so what is classified as critical is a scoping decision with consequences rather than a labelling exercise.
The scope has to follow the transaction across those boundaries:
- Investor portals and mobile applications, including transaction and redemption paths
- Registrar interfaces and the file exchanges that run over them
- Exchange order-routing platform integrations
- Distributor and partner portals, and the entitlement model that decides what a distributor can see
- Fund accounting and NAV computation, where the risk is integrity rather than disclosure
- Dealing-room and order management systems
- Digital onboarding and payment paths
Where this goes wrong
Calling registrar-side systems out of scope
Because the registrar is a separate regulated entity, its systems are often excluded from the AMC's assessment entirely, leaving the file exchanges and integration points between them tested by nobody. The interface belongs in your scope even when what sits on the far side of it does not. Ask specifically what happens at your end if the far end sends something unexpected.
Submission
Where a AMC / Mutual Fund files, and by when
Reports go to SEBI. CSCRF Tables 17 and 23 route MIIs and all remaining regulated entities to SEBI.
Within 1 month
Report submitted
The VAPT report is filed within a month of the activity completing, after your IT Committee has approved it where one is mandated, together with the MD/CEO declaration the format requires.
Within 3 months
Findings closed
Closure runs from submission, graded by criticality. Anything still open at three months needs IT Committee approval to stay open and has to be closed before the next cycle starts.
Within 5 months
Revalidation complete
Revalidation runs from completion of the VAPT, not from submission — which is why a cycle started late in the year rarely leaves room to finish it.
Plan the cycle at the start of the financial year rather than against the deadline. No audit period may be left unaudited because a category changed mid-year: an unaudited stretch has to be pulled into the current cycle.
How we help
CERT-In empanelled, and the report is written for the submission
We run the VAPT and cyber-audit scope your tier requires, and the deliverable is written to be filed — mapped to the CSCRF control set rather than handed over as a generic findings list that someone then has to translate.
Verified against the source circulars as of 3 August 2026.