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India SBOM compliance

The one map to CERT-In, SEBI CSCRF and RBI software-supply-chain rules — who they cover, what they mandate, and the deadlines

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India now has three overlapping software-supply-chain regimes, and which ones apply depends on who you are. CERT-In's Technical Guidelines make a Software Bill of Materials the baseline expectation for government, public-sector and software-export entities. SEBI's CSCRF mandates SBOM for its regulated entities (exchanges, brokers, AMCs). RBI's IT-governance and cyber-resilience directions push the same expectations into banks and NBFCs. On top of that sits CERT-In's mandatory 6-hour incident-reporting duty under Section 70B of the IT Act.

This page is the map: which framework applies to you, what each one actually requires, the deadlines that matter, and where they overlap so one SBOM programme can satisfy several. Each framework links to a deep-dive.

At a glance
3 regimesCERT-In · SEBI CSCRF · RBI
SBOMCommon baseline across all three
31 Aug 2025SEBI CSCRF go-live for most REs
6 hoursCERT-In incident-reporting window
CERT-In, SEBI CSCRF and RBI software-supply-chain and cyber-resilience frameworks
Why this matters

One supply-chain programme, three overlapping Indian mandates

The frameworks were written by different regulators for different sectors, but they converge on the same core demand: know what your software is made of, track its vulnerabilities, and be able to prove it. A machine-readable SBOM — increasingly a whole xBOM family (SBOM, CBOM, QBOM, AIBOM, HBOM) under CERT-In v2.0 — is the artefact that satisfies all three.

The practical win is consolidation: an SBOM programme built to CERT-In's minimum elements, with VEX/CSAF vulnerability status and reachability-based prioritisation, covers most of what SEBI CSCRF and RBI expect too. Build it once, map it to each regulator's control language, and you avoid running three parallel compliance efforts.

How O3 helps

Find it before attackers do. Catch it if they try. Fix it fast.

Across these requirements, O3 runs one continuous loop on your own software so issues surface, get caught, and get fixed before they become an incident.

1 · Find it first

Test like an AI-assisted attacker

An agentic pentest probes your app across 50+ vulnerability classes the way a real attacker chains them, so exploitable flaws surface in your build before someone outside finds them.

2 · Catch it live

Detect and block exploitation at runtime

A kernel-level eBPF agent watches process trees and syscalls, recognises an attack sequence as it unfolds, and restricts the offending process on the spot rather than taking down the host.

3 · Fix it fast

Auto-patch what is reachable

Reachability ranks what genuinely matters, then autofix opens a pull request with the change, so remediation starts inside tight fix windows instead of sitting in a queue.

Risk-based prioritisation

From alert flood to a short list

KEV + EPSS + reachability turn a raw scan into the few findings that actually need action now.

Raw findings in dependency tree~12,400
Vulnerable & version-matched~4,700
Reachable in your code~1,360
KEV / high-EPSS · act now~370

Illustrative funnel. Reachability removes the bulk of unexploitable noise before triage.

Who it covers

Which Indian SBOM rules apply to you: CERT-In, SEBI or RBI

Start here — the regime you must meet depends on your sector.

Government, PSU, essential services, software exporters → CERT-In Technical Guidelines (SBOM/CBOM/QBOM/AIBOM/HBOM v2.0) and the mandatory Section 70B incident-reporting duty.
SEBI-regulated entities (stock exchanges, depositories, brokers, mutual funds/AMCs, etc.) → SEBI CSCRF, which carries a field-level SBOM mandate and VAPT via CERT-In-empanelled auditors.
Banks and NBFCs → RBI's IT Governance Master Direction and Cyber Security Framework — secure SDLC, third-party/supply-chain risk, VAPT and incident reporting.
Almost everyone operating in India → CERT-In's 6-hour incident-reporting obligation applies regardless of sector.
Where O3 helps

O3 produces the SBOM (and CBOM/AIBOM) once, tracks reachable vulnerabilities against it, and maps the same evidence to each regulator's controls — so one programme answers CERT-In, SEBI and RBI.

What they mandate

Required SBOM fields under CERT-In, SEBI and RBI guidelines

Different words, same substance. These three demands recur across all the Indian frameworks.

A machine-readable SBOM to CERT-In's minimum elements (Table 5): component names, versions, suppliers, hashes, licences and relationships — in CycloneDX or SPDX.
Vulnerability status communicated via VEX and CSAF (CERT-In §6), not raw scanner dumps — so consumers know which listed CVEs actually affect the product.
VAPT / security testing, in SEBI's case via CERT-In-empanelled auditors, plus secure-SDLC and third-party-risk controls under RBI.
Where O3 helps

O3's reachability analysis converts a raw SBOM into a prioritised, VEX-ready view — which CVEs are actually reachable in your code — which is exactly the signal these frameworks want and scanners can't give.

Deadlines

SBOM compliance deadlines for CERT-In, SEBI CSCRF and RBI

Compliance is time-boxed. Track the go-live dates per regime.

CERT-In Directions (incident reporting): in force since 27 June 2022 — already live.
SEBI CSCRF: circular issued August 2024; go-live for most regulated entities from 31 August 2025 (phased for some categories).
RBI: the IT Governance, Risk, Controls and Assurance Master Direction (Nov 2023) and the Cyber Security Framework apply on their notified timelines to banks/NBFCs.
CERT-In SBOM Guidelines v2.0: published 09 July 2025 — the reference standard for the xBOM family.
Where O3 helps

O3 gives you a continuously-current SBOM + vulnerability posture, so you can produce evidence on the regulator's timeline instead of scrambling before an audit.

CERT-In

How to build an SBOM that meets CERT-In's minimum elements

Table 5 of the v2.0 Guidelines defines three minimum elements, not one: Data Fields, Automation Support, and Practices and Processes. The Data Fields element alone lists 21 attributes for every component, which is more than most generated SBOMs carry by default.

Populate all 21 Table 5 data fields per component: name, version, description, supplier, license, origin, dependencies, vulnerabilities, patch status, release date, end-of-life date, criticality, usage restrictions, checksums or hashes, comments, author of the SBOM data, timestamp, executable property, archive property, structured property and unique identifier.
Satisfy Automation Support by emitting a machine-readable format — CycloneDX or SPDX — rather than a spreadsheet, so the SBOM can be consumed by tooling at scale.
Satisfy Practices and Processes by defining generation frequency, dependency depth, how "known unknowns" are declared, distribution and delivery, access control, and how mistakes are corrected (§5.3 covers public vs private SBOM sharing).
Generate the right SBOM class for each SDLC stage — the guidelines align SBOM types to Design, Source, Build, Analyzed, Deployed and Runtime (§3.2).
Where O3 helps

O3 emits CycloneDX with component identifiers, transitive dependency graphs, licenses and hashes, enriched from deps.dev, so the Table 5 data fields are populated automatically rather than hand-completed before an audit.

SEBI

How to meet the SEBI CSCRF field-level SBOM mandate

CSCRF is the first Indian regulation to put SBOM attributes into the text of the rule itself. It applies across five regulated-entity tiers, and the obligations scale with the tier.

Confirm your tier first — CSCRF classifies regulated entities as MII, Qualified, Mid-size, Small-size or Self-certification, and the depth of what you must do follows from that.
Maintain SBOMs for critical systems: in-house software, third-party COTS, and SaaS in scope.
Run VAPT through CERT-In-empanelled auditors — CSCRF does not accept arbitrary testing vendors for this.
Map controls to the six NIST CSF functions CSCRF is organised around (Govern, Identify, Protect, Detect, Respond, Recover) so evidence lines up with the framework's own structure.
Where O3 helps

O3 keeps the SBOM current for every in-scope system and tracks which listed CVEs are actually reachable, so the "Identify" and "Protect" evidence is continuous rather than a point-in-time snapshot.

RBI

How to satisfy RBI's secure-SDLC and third-party risk expectations

RBI does not publish a standalone "SBOM circular". The requirement arrives through IT governance, secure SDLC and outsourcing/third-party risk controls that together demand you know and can evidence what your software is made of.

RBI/2023-24/107RBI/2020-21/74DBS.CO/CSITE/BC.11/33.01.001/2015-16
Anchor the programme to the IT Governance, Risk, Controls and Assurance Master Direction (RBI/2023-24/107, 07 Nov 2023), which puts accountability at board level.
Apply the Cyber Security Framework for banks (DBS.CO/CSITE/BC.11/33.01.001/2015-16) and, for payment operators, the Digital Payment Security Controls direction (RBI/2020-21/74).
Evidence a secure SDLC: dependency review before release, change management, and testing gates rather than an annual scan.
Treat outsourced and third-party software as in-scope — component inventory and vulnerability status for supplier-delivered code, not just code you wrote.
Where O3 helps

O3 produces the component inventory plus malicious-dependency detection (typosquats, malicious post-install scripts, compromised maintainers) for supplier-delivered code, which is the evidence third-party-risk controls actually ask for.

Incident reporting

Incident reporting timelines: CERT-In 6 hours, SEBI and RBI

This is the obligation with the least tolerance for improvisation, and it applies far beyond the sector-specific regimes.

IT Act §70B(6)28 Apr 2022 Directions180-day retention
Report listed cyber incidents to CERT-In within 6 hours of noticing them, under the Directions issued 28 April 2022 under Section 70B(6) of the IT Act, in force since 27 June 2022.
Retain ICT logs for 180 days within India and make them available to CERT-In on request.
Keep clocks synchronised to NPL or NIC time sources, so incident timelines reconcile across systems.
Layer the sector obligation on top: SEBI REs and RBI-regulated entities have their own reporting lines in addition to the 70B duty, not instead of it.
Where O3 helps

A current SBOM shortens the hardest step of an incident report — establishing whether a newly-disclosed component is present anywhere in your estate, and where.

Beyond SBOM

How to extend the programme to CBOM, QBOM, AIBOM and HBOM

CERT-In v2.0 is the reason "xBOM" is now the Indian baseline rather than SBOM alone. Each additional bill of materials answers a question an SBOM structurally cannot.

CBOM and QBOM (§8): inventory cryptographic assets and quantum-vulnerable algorithms so a post-quantum migration can be planned against real usage rather than assumption.
AIBOM (§9): record models, versions, developers, licensing, software dependencies, training and performance characteristics for AI systems.
HBOM (§10): cover hardware and component provenance for firmware and embedded products.
Treat these as views over one programme. The discipline — inventory, keep it current, track vulnerabilities against it, be able to prove it — does not change per BOM type.
Where O3 helps

O3 generates SBOM, CBOM, QBOM and AIBOM from the same scan, so extending coverage to the xBOM family is a configuration change rather than a second programme.

The whole framework

The three regimes, side by side

All 27 requirement areas, each with the reference and a vendor-neutral note on how teams meet it.

12CERT-In
CERT-In Guidelines + 70B
5SEBI
SEBI CSCRF
5RBI
RBI IT Governance + Cyber
5Shared
SBOM · VEX · VAPT
The three regimes, side by side — 27 requirement areas, each with its reference and how teams meet it.
Requirement areaRef
SBOM mandateCERT-In v2.0 · SEBI CSCRF · RBI
Extended xBOMCERT-In v2.0
Vulnerability statusCERT-In §6
VAPT / security testingSEBI CSCRF · RBI
Incident reportingCERT-In Sec 70B
Third-party / supply-chain riskRBI · SEBI
Applicabilitysector-specific
SBOM minimum elementsCERT-In Table 5
Machine-readable formatCERT-In Table 5
SBOM class per SDLC stageCERT-In §3.2
Known unknownsCERT-In Table 5
SBOM distribution and accessCERT-In §5.3
License managementCERT-In §3.4
CBOM / QBOMCERT-In §8
AIBOMCERT-In §9
HBOMCERT-In §10
RE tieringSEBI CSCRF
Framework structureSEBI CSCRF
Empanelled auditorsSEBI CSCRF
Scope of SBOMSEBI CSCRF
Board accountabilityRBI/2023-24/107
Secure SDLCRBI IT Gov MD
Digital payment controlsRBI/2020-21/74
Cyber Security FrameworkDBS.CO/CSITE/BC.11/33.01.001/2015-16
Log retentionCERT-In Directions
Clock synchronisationCERT-In Directions
Vulnerability prioritisationshared

Run one SBOM programme, satisfy all three

O3 generates the SBOM/CBOM/AIBOM, ranks vulnerabilities by real reachability, keeps a VEX-ready status, and maps the evidence to CERT-In, SEBI and RBI controls — so India compliance is one workflow, not three.

Frameworks are linked individually below
FAQ

Common
questions.

Everything teams ask before rolling this out. Still stuck? Reach our team.

  • Yes, depending on your sector. CERT-In's Technical Guidelines make a Software Bill of Materials the baseline expectation for government, public-sector and software-export entities; SEBI's CSCRF mandates SBOM for its regulated entities; and RBI's directions drive the same expectations into banks and NBFCs. A single SBOM programme built to CERT-In's minimum elements can satisfy all three.
  • Three main ones: CERT-In's Technical Guidelines on SBOM/CBOM/QBOM/AIBOM/HBOM (v2.0, July 2025), SEBI's Cybersecurity and Cyber Resilience Framework (CSCRF, 2024), and RBI's IT Governance Master Direction and Cyber Security Framework for banks and NBFCs.
  • CERT-In sets the technical standard (what an SBOM must contain and the wider xBOM family). SEBI CSCRF applies that to securities-market entities with a field-level SBOM mandate and CERT-In-empanelled VAPT. RBI applies equivalent expectations to banks and NBFCs through secure-SDLC and supply-chain-risk controls. They overlap heavily, so one programme can cover several.
  • CERT-In's incident-reporting Directions have been in force since June 2022. SEBI CSCRF goes live for most regulated entities from 31 August 2025. RBI's directions apply on their notified timelines. CERT-In's SBOM Guidelines v2.0 were published on 09 July 2025.
  • Largely, yes. Build the SBOM to CERT-In's minimum elements with VEX/CSAF vulnerability status and reachability-based prioritisation, then map that same evidence to SEBI's and RBI's control language. The core demand — a machine-readable component inventory with tracked, prioritised vulnerabilities — is common to all three.
  • Table 5 of the CERT-In Technical Guidelines v2.0 defines three minimum elements: Data Fields, Automation Support, and Practices and Processes. The Data Fields element lists 21 attributes per component: name, version, description, supplier, license, origin, dependencies, vulnerabilities, patch status, release date, end-of-life date, criticality, usage restrictions, checksums or hashes, comments or notes, author of the SBOM data, timestamp, executable property, archive property, structured property and unique identifier. Automation Support requires a machine-readable format such as CycloneDX or SPDX, and Practices and Processes covers frequency, depth, known unknowns, distribution, access control and correction of mistakes.
  • The Cybersecurity and Cyber Resilience Framework was issued on 20 August 2024 as circular SEBI/HO/ITD-1/ITD_CSC_EXT/P/CIR/2024/113, with compliance required for most regulated entities from 31 August 2025. CSCRF classifies regulated entities into five tiers — MII, Qualified, Mid-size, Small-size and Self-certification — and obligations scale with the tier.
  • Not through a standalone SBOM circular. The requirement arrives indirectly, through the IT Governance, Risk, Controls and Assurance Master Direction (RBI/2023-24/107, 07 November 2023), the Cyber Security Framework for banks (DBS.CO/CSITE/BC.11/33.01.001/2015-16), and the Digital Payment Security Controls direction (RBI/2020-21/74). Together these demand secure SDLC, third-party and outsourcing risk management, and vulnerability management — obligations you cannot evidence without knowing your software composition. Confirm the reference and effective date applicable to your entity type on RBI's Master Directions index.
  • Listed cyber incidents must be reported to CERT-In within 6 hours of noticing them. The Directions were issued on 28 April 2022 under Section 70B(6) of the Information Technology Act and have been in force since 27 June 2022. They also require ICT logs to be retained for 180 days within India and made available to CERT-In on request, with system clocks synchronised to NPL or NIC time sources.
  • xBOM is the umbrella for the bill-of-materials family that CERT-In v2.0 defines beyond the classic SBOM: CBOM and QBOM for cryptographic assets and quantum readiness (§8), AIBOM for AI systems covering model name, version, type, developer, licensing and dependencies (§9), and HBOM for hardware and component provenance (§10). They are views over one inventory discipline rather than separate programmes.

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