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Cyber Resilience | Beyond Cybersecurity — SIRI Law LLP
Cyber Resilience

Cyber resilience — surviving the incident prevention didn't stop.

Prevention alone is no longer what regulators or enterprise customers expect. Cyber resilience is the ability to keep operating through an incident and recover on a tested, documented timeline — and SIRI delivers the full loop, Sense through Adapt, as one integrated legal-and-technical engagement.

31 Jul 2026RBI's new Resilience & Assurance Framework took effect
29.44LIncidents CERT-In handled in the latest reporting year
24%Rise in ransomware incidents reported by CERT-In
7Capabilities under one resilience engagement
The resilience regulatory clock
Live tracking · scroll to see every relevant change
New framework
31 JUL 2026
RBI's Commercial Banks Cybersecurity, Technology Risk, Resilience and Assurance Framework Directions, 2026 take effect — replacing the prior patchwork with a single consolidated standard.
Parallel direction
31 JUL 2026
RBI/DoS/2026-27/461 — the equivalent NBFC Resilience & Assurance Framework Directions, issued the same day for specified categories of NBFCs.
Still governing
APR 2024
NBFCs currently operate under the ITGRCA Master Directions for IT governance and cybersecurity — pending the anticipated NBFC-specific extension of the July 2026 bank framework.
Live deadline
30 JUN 2026
SEBI CSCRF first-audit deadline for Qualified and mid-size regulated entities — daily penalties for non-compliance plus NSE/BSE regulatory action.
Baseline since 2022
S.70B(6) IT ACT
CERT-In's 2022 Directions require notification within 6 hours of becoming aware of a qualifying cyber incident — a resilience programme is what makes that window achievable.
Notified
14 NOV 2025
DPDP Rules 2025 notified, with the operative compliance deadline for most substantive obligations at 13 May 2027 — breach notification and recovery obligations sit inside this same framework.

The assumption that no longer holds

"We have a firewall and an antivirus" stopped being a resilience answer somewhere around July 2026.

For years, Indian organisations could point to preventive controls — a firewall, endpoint protection, an annual penetration test — and treat that as the compliance answer to "what's your cybersecurity posture?" RBI's new Commercial Banks Resilience & Assurance Framework, effective 31 July 2026, makes clear that this is no longer sufficient even for the sector where it was most entrenched: the framework requires a 24×7 Cyber Security Operations Centre, continuous SIEM-based monitoring, vulnerability assessments every six months, annual penetration testing of critical systems, and — critically — half-yearly disaster recovery drills with a documented Recovery Time Objective and Recovery Point Objective.

That last requirement is the real shift. A DR drill with a documented RTO/RPO isn't asking "can you prevent an incident" — it's asking "when one happens anyway, how long until you're actually running again, and how much data do you lose in between." That's resilience, not security, and it's now a named regulatory expectation, not an aspirational best practice.

RBI's pattern: banks first, NBFCs within 12–18 months
A parallel NBFC-specific direction (RBI/DoS/2026-27/461) was issued the same day as the bank framework. RBI's regulatory history over the past eight years has consistently extended bank-level cybersecurity requirements to NBFCs on a 12-to-18-month lag — organisations that treat the July 2026 bank framework as a preview of their own roadmap are materially better positioned than those waiting for a sector-specific circular.

The same shift shows up outside banking. SEBI's CSCRF is now in its recurring audit cycle rather than a one-time implementation exercise, and CERT-In's 6-hour breach notification window — unchanged since 2022 — is only genuinely achievable for an organisation that already has a tested incident response plan, a pre-identified legal and technical team, and evidence-preservation procedures documented before an incident happens, not improvised during one.

What organisations get wrong

Four assumptions that quietly fail during an actual incident

Most resilience gaps aren't exotic — they're a plausible-sounding assumption that was never actually tested.

01 — PLAN

"We have an incident response plan"

A document exists, but it was written once, never rehearsed, and nobody currently at the organisation has actually run through it. An untested plan behaves differently than expected the first time it's needed for real.

02 — RECOVERY

"Our backups mean we can recover"

Backups exist, but the actual Recovery Time Objective has never been measured against a real restoration. RBI's new framework requires half-yearly DR drills specifically because "we have backups" and "we can recover within a defined window" are different claims.

03 — NOTIFICATION

"We'll figure out notification when it happens"

CERT-In's 6-hour window, and DPDPA's separate breach obligations, are not generous enough to draft a first notification from scratch during an active incident. Organisations that meet the deadline cleanly have the legal and technical assessment structure already built.

04 — SCOPE

"This is an IT problem, not a legal one"

Containment decisions, evidence handling, and communications made in the first hours carry legal consequences that are far easier to get right in real time than to fix afterward — which is exactly where a technical-only response falls short.

What cyber resilience actually covers

Seven capabilities, one operating model — Sense, Prevent, Detect, Respond, Recover, Assure, Adapt.

Not seven separate vendors. One resilience engagement, entered through whichever capability you need first.

RECURRING

SIRI Shield

The managed cyber resilience retainer — SOC monitoring, quarterly testing, GRC, and incident response on one fixed monthly fee.

  • 24/7 monitoring & SIEM
  • Quarterly penetration testing
  • Dedicated attorney & incident SLA
View SIRI Shield plans →
MATTER-BASED

SIRI Response

Emergency incident response and digital forensics — activated when an incident is happening now.

  • Containment & forensic acquisition
  • Attack reconstruction
  • Data-impact assessment
Explore SIRI Response →
INTEGRATED

SIRI Cyber Legal Response

Legal and regulatory response run inside the technical incident — not a separate call after containment.

  • Notification analysis
  • Legal hold & evidence strategy
  • Board & regulator communications
Explore Cyber Legal Response →
DIAGNOSTIC

SIRI Cyber Resilience Audit

The entry-level assessment — where your resilience programme actually stands today, against RBI, SEBI, and CERT-In expectations.

  • Maturity & gap assessment
  • RTO/RPO validation
  • Board-ready remediation roadmap
Explore the Resilience Audit →
PREPARATION

SIRI Incident Readiness

Building the plan, playbooks, and tested procedures before an incident — not writing them during one.

  • Tabletop exercises
  • Playbook & escalation drafting
  • Legal-response procedures
Explore Incident Readiness →
DETECTION

SOC & SIEM

The continuous monitoring layer RBI's 2026 framework specifically requires — a 24×7 Security Operations Centre with SIEM-based detection.

  • 24/7 SOC monitoring
  • SIEM deployment & tuning
  • Alert triage & escalation
Explore SOC & SIEM →
RECOVERY

Cyber Recovery & Assurance

Backup validation, recovery testing, and the documented RTO/RPO that half-yearly DR drills now require.

  • Backup & DR testing
  • Recovery time validation
  • Post-recovery security assurance
Explore Recovery & Assurance →

Evidence, not guesswork

Cybersecurity vs. cyber resilience vs. compliance-only — what each actually covers

These get used interchangeably in vendor marketing. They aren't the same thing, and a regulator or enterprise buyer increasingly asks which one you actually have.

CapabilityCybersecurity (prevention-only)Compliance-only (paper-based)Cyber Resilience (SIRI model)
Preventive controls (firewall, endpoint, access management)YesDocumented, not always implementedYes
24/7 monitoring & detection (SOC/SIEM)SometimesNoYes
Tested incident response planNoWritten, rarely rehearsedYes — tabletop-tested
Documented Recovery Time / Recovery Point ObjectiveNoNoYes — drilled half-yearly
Legal response integrated into the technical incidentNoNoYes
Attorney-client privilege over findingsNoNoYes
Satisfies RBI 2026 Framework / SEBI CSCRF resilience criteriaPartiallyPartiallyYes

Sources: RBI (Commercial Banks — Cybersecurity, Technology: Risk, Resilience and Assurance Framework) Directions, 2026, effective 31 July 2026; RBI/DoS/2026-27/461 (NBFC Directions, 2026); SEBI Cybersecurity and Cyber Resilience Framework (CSCRF); CERT-In Directions, 2022 under s.70B(6), IT Act 2000. Framework requirements summarised for comparison; confirm current applicability to your specific entity category before relying on any specific obligation.

Numbers every board should know

What the current threat and regulatory picture actually looks like

70%

Of malware detections

Trojans and file infectors account for 70% of all malware detections in India (Seqrite, 2026) — the entry point for most ransomware incidents.

62%

Of cloud detections

Cloud misconfigurations and IAM exploitation account for 62% of detections in cloud environments (DSCI) — resilience now has to cover cloud infrastructure, not just on-premises.

8.9%

Of Indian organisations

Reported dealing with ransomware recently, against a 4.8% global rate — India's exposure runs meaningfully above the global average.

6 hrs

CERT-In notification window

Unchanged since the 2022 Directions — only genuinely achievable with a resilience programme already in place before an incident occurs.

Why SIRI for resilience specifically

Legal and technical resilience, assessed together — not two separate reports

A resilience audit from a pure consulting firm produces a document with no legal standing. A legal review with no technical validation can't actually confirm your RTO is real.

01

One assessment, both dimensions

Technical resilience testing (RTO/RPO validation, DR drills, SOC readiness) and legal resilience (notification procedures, evidence handling, regulatory exposure) assessed inside one engagement.

02

Privilege over the findings

When resilience assessment is conducted under legal engagement, findings are protected by attorney-client privilege — a regulator investigating a later incident cannot compel disclosure of your gap assessment.

03

Built around the actual current frameworks

Mapped directly to RBI's 2026 Framework, SEBI CSCRF, and CERT-In obligations as they stand today — not a generic maturity model retrofitted to Indian regulation.

04

One team from audit through recovery

The team that runs your resilience audit is the same team available for incident response if something is found — continuity a separate vendor relationship doesn't offer.

Who this is built for

Organisations building or rebuilding a genuine resilience programme

Banks & NBFCs SEBI-regulated intermediaries HealthTech & FinTech SaaS & enterprise technology Manufacturing & critical infrastructure Government contractors Insurance & IRDAI-regulated entities Post-incident rebuilds

How we work

From first assessment to a tested resilience programme

01

Resilience Audit

Maturity and gap assessment against RBI, SEBI, and CERT-In frameworks — where you actually stand today.

Weeks 1–2
02

Readiness Build

Incident response plans, playbooks, and escalation procedures — built and tabletop-tested, not just written.

Weeks 3–6
03

Detection & Recovery

SOC/SIEM deployment and recovery testing — establishing a real, drilled Recovery Time Objective.

Weeks 6–12
04

Ongoing Assurance

SIRI Shield retainer — continuous monitoring, quarterly testing, and incident response on standby.

Ongoing

Frequently asked

Cyber resilience, answered directly

What's the actual difference between cybersecurity and cyber resilience?

Cybersecurity is about preventing and detecting an incident. Cyber resilience is the broader capability to keep critical operations running during an incident and recover on a tested, documented timeline afterward — it assumes prevention will eventually fail and asks what happens next. RBI's 2026 Resilience & Assurance Framework and SEBI's CSCRF both now examine resilience and recovery capability directly, not just preventive controls, which is why "we have a firewall and an antivirus" no longer satisfies a regulator or an enterprise customer's due diligence.

What does RBI's new 2026 framework actually require?

The RBI (Commercial Banks — Cybersecurity, Technology: Risk, Resilience and Assurance Framework) Directions, 2026, effective 31 July 2026, replaced the previous patchwork of circulars with a single consolidated framework requiring a 24×7 Cyber Security Operations Centre, continuous SIEM-based monitoring, vulnerability assessments every six months, annual penetration testing of critical internet-facing systems, and half-yearly disaster recovery drills with documented Recovery Time and Recovery Point Objectives. A parallel NBFC-specific direction was issued the same day; RBI's regulatory pattern has consistently extended bank-level requirements to NBFCs within 12 to 18 months.

Do CERT-In's 6-hour notification rules apply differently under a resilience programme?

The 6-hour CERT-In notification obligation under the 2022 Directions doesn't change, but an organisation with a genuine resilience programme — a tested incident response plan, a pre-identified legal and technical team, evidence-preservation procedures already documented — can actually meet that window with an accurate, defensible notification. Without that preparation, the 6-hour clock is frequently missed or met with a rushed, incomplete filing that creates its own regulatory exposure.

Is cyber resilience only relevant for banks and NBFCs?

No. RBI and SEBI frameworks are the most codified examples, but CERT-In's Directions apply across sectors, and enterprise customers increasingly require resilience evidence — tested recovery timelines, documented incident response — as part of vendor due diligence regardless of industry. Ransomware and cloud misconfiguration attacks, the two fastest-growing threat categories in India, don't discriminate by sector.

How is SIRI's resilience audit different from a generic maturity assessment?

It's mapped directly to the frameworks that actually apply to Indian organisations today — RBI's 2026 Framework, SEBI CSCRF, CERT-In — rather than a generic international maturity model retrofitted with Indian references. It's also conducted under legal engagement, so findings are protected by attorney-client privilege, and it's delivered by the same team available to run incident response if the audit surfaces something that needs it.

Do I need SIRI Shield, or can I start with just the Resilience Audit?

The Resilience Audit is the right starting point if you don't yet know where your gaps are — it's the diagnostic. SIRI Shield is the ongoing retainer for organisations ready to operate a continuous resilience programme (monitoring, testing, incident response) rather than address it as a point-in-time project. Many clients start with the audit and move into a Shield retainer once the roadmap is clear.

Build resilience, not just prevention

Find out where your resilience programme actually stands.

Book a consultation, or start with the Cyber Resilience Audit if you're ready for a full assessment.

24/7 for active incidents: +91 79819 12046

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SIRI Law LLP — Hyderabad, India

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Telephone+91 79819 12046
Emailinfo@sirilawllp.com
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© SIRI Law LLP · Hyderabad, Telangana

This page is provided for general informational purposes and does not constitute legal advice. References to RBI's 2026 Resilience & Assurance Framework, SEBI CSCRF deadlines, CERT-In obligations, and cited statistics reflect publicly available information as of publication and remain subject to regulatory change; verify current applicability to your specific entity category before relying on any specific requirement. No lawyer-client relationship is formed by viewing this page. Engagement requires a formal retainer. SIRI Law LLP is a registered law firm under the Limited Liability Partnership Act 2008, practising under the Advocates Act 1961; complaints regarding professional conduct may be directed to the Bar Council of Telangana.

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