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Learn · CERT-In & VAPT

VAPT, Penetration Testing and Red Teaming Are Not the Same Engagement

Four activities get quoted against each other in India as though they were sizes of the same thing: a scan, a vulnerability assessment, a penetration test, and a red team engagement. They differ in objective, in how the scope is set, in how much the tester is told, in who knows the test is happening, in how long they run, and in what the deliverable proves. Buying the wrong one is not a pricing mistake. It is an assurance mistake that surfaces later, usually in front of somebody who matters.

Where the definitions come from: CERT-In’s Comprehensive Cyber Security Audit Policy Guidelines (version 1.0, 25 July 2025) list twenty-six classes of engagement at §6 and define three of these four separately — vulnerability assessments at (iii), penetration testing at (iv), and red team assessment at (xvi). The fourth, scanning, is not a class of engagement at all.

26classes of engagement CERT-In names at §6
3of the four defined separately, in their own words
2different things CERT-In’s documents call a “Red Team”

Plain-English explainer · CERT-In Comprehensive Cyber Security Audit Policy Guidelines v1.0 (25 July 2025) · Auditor Guidelines v3.0 (May 2018) · Empanelment terms v7.2 (April 2024) · Every clause locator checked 22 September 2026

The short answer

What is VAPT, and how is it different from red teaming?

What is the difference between VAPT and penetration testing?

Penetration testing is not an alternative to VAPT. It is the second half of it. VAPT stands for Vulnerability Assessment and Penetration Testing, so a quote labelled “VAPT” and a quote labelled “penetration test” do not differ by depth of testing — they differ by whether a systematic assessment of the estate is bundled in. Almost everybody arriving at this comparison is holding two proposals and trying to work out which one is bigger, and that is the wrong axis. The question that settles it is which of §6(iii) and §6(iv) each proposal actually covers, across which assets. Get that answer in writing and the two documents become comparable. Leave it and you are comparing a bundle against one of its own halves.

VAPT stands for Vulnerability Assessment and Penetration Testing. It is an umbrella term for two distinct activities usually sold as one engagement: an assessment, which examines a defined estate to find and rank security deficiencies, and a penetration test, which actively tries to exploit what it finds in order to establish what an attacker could actually reach. A red team assessment is a third thing entirely — a simulated adversary pursuing an objective against your live organisation, measured by whether your people detected it and what they did next. CERT-In’s Comprehensive Cyber Security Audit Policy Guidelines (version 1.0, 25 July 2025) treat them as three separate classes of engagement, at §6(iii), §6(iv) and §6(xvi) respectively.

The cleanest way to hold the difference is by the question each one answers. A vulnerability assessment answers what is wrong here, and how much of it is there. A penetration test answers what is actually exploitable here, and what does exploiting it reach. A red team assessment answers would we detect this, and would we respond well enough to stop it. A vulnerability scan answers none of those. It answers what a tool recognised. Four questions, four engagements, four prices — and a quote that says only “VAPT” has not yet told you which of them you are buying.

Key Takeaways

  • Penetration testing is the PT inside VAPT, not an alternative to it. Two quotes labelled "VAPT" and "penetration test" differ by whether a systematic assessment of the estate is included, not by how deep the testing goes.
  • VAPT is a category, not a specification. §13.2.3(i)(a) lists it as one of nine named audit types alongside EAPT, device level audit, configuration audit, process audit, mobile, web, API and compliance audits — and ends the list with "etc.".
  • A vulnerability assessment aims at completeness, while a penetration test aims at proof. §6(iii) defines the first as examination to identify security deficiencies and confirm the adequacy of measures, and §6(iv) defines the second as active testing to identify and exploit, and to determine whether exploitation compromises the application, accesses sensitive data or affects the underlying infrastructure.
  • A red team assessment is a separate class at §6(xvi) — an exercise reflecting real-world conditions, conducted as a simulated attempt by an adversary — and it measures your defence rather than your attack surface. It is not a bigger penetration test.
  • CERT-In uses "Red Team" in a second, unrelated sense. The 2018 auditor guidelines require an auditing organisation to deploy a verification team (Red Team) to verify the work performed by its audit team (White Team). That is internal quality control on the auditor, not an engagement you buy.
  • Who knows is an axis, not a detail. §15.1.1(i) limits notification of the test to key personnel — policy-making level, and managers responsible for security processes, incident response and security operations. Tell the SOC and you have stopped measuring the SOC.
  • Scanning is a technique, not an engagement. §8(i) says solely tools-based testing should be discouraged, because it may overlook the non-automated and manual components and produce an incomplete view of the overall security.
  • The fastest way to read a quote honestly is the test plan. §13.2.2(ii) requires it to state both calendar time and man-hours, which is what makes two bids comparable at all.
  • Almost every rule on this page binds CERT-In empanelled auditing organisations. If your tester is not empanelled, none of it reaches them by default — and the remedy is to import the clauses into your engagement letter.
Definitions, in the instruments’ own words

Four activities, three of them defined

What is a vulnerability assessment, a penetration test and a red team assessment?

§6 of the 2025 audit policy guidelines lists twenty-six classes of cyber security audit and assessment, introduced with the phrase “including, but not limited to”, so the list is a floor rather than a boundary. Three of the four activities below appear in it with a definition attached. The fourth appears nowhere, and that absence is itself the finding.

Vulnerability scanning

A tool runs against a target and reports what it recognises.

The question it answers

What do the signatures match?

Not defined, and not named. It is not one of the twenty-six classes of engagement §6 lists, and a full-text search of the 2025 audit policy guidelines returns no occurrence of “scan”, “scanning” or “scanner” anywhere in the document. What the guidelines say instead is §8(i), and this page quotes it once, here, because four later sections rely on it: “Solely tools-based testing should be discouraged as tool-based audits may focus primarily on automated processes and may overlook non-automated or manual components of the IT infrastructure. This limitation can result in an incomplete view of the overall security.”

What you receive: A tool report, ranked by the tool.

Vulnerability assessment

A systematic examination of a defined estate to find and rank security deficiencies, tooling used but not trusted.

The question it answers

What is wrong here, and how much of it is there?

§5(xxi) and §6(iii): “Examination of an information system or product to determine the adequacy of security measures, identify security deficiencies, provide data from which to predict the effectiveness of proposed security measures, and confirm the adequacy of such measures after implementation.”

What you receive: A findings register with severity, evidence and remediation advice.

Penetration testing

Active testing of components or the whole application to identify and exploit vulnerabilities, and to see what the exploitation reaches.

The question it answers

What is actually exploitable here, and what does exploiting it get you?

§5(xxii) and §6(iv): “A security testing methodology in which individual components or the application as a whole are actively tested to identify and exploit potential vulnerabilities. The objective is to determine whether these vulnerabilities can be exploited to compromise the application, access sensitive data, or affect the underlying infrastructure and environment.”

What you receive: Proven attack paths with reproduction steps, impact and business risk.

Red team assessment

A simulated adversary pursues an objective against the live organisation under real-world conditions.

The question it answers

Would we detect this, and would we respond well enough to stop it?

§5(xxiii) and §6(xvi): “An exercise, reflecting real-world conditions, that is conducted as a simulated attempt by an adversary to attack or exploit vulnerabilities in an enterprise’s information systems.”

What you receive: A narrative of the operation against a detection and response timeline, and the gaps that let it run.

Two of those definitions repay a second reading. §6(iii) ends with confirm the adequacy of such measures after implementation — the assessment has a closure role built into its own definition, which is why a retest is not an extra. And §6(iv) does not stop at “exploit”: its stated objective is to determine whether the vulnerabilities can be exploited to compromise the application, access sensitive data, or affect the underlying infrastructure and environment. A penetration test that proves an injection point exists and never asks what the injection point reaches has completed half of its own definition.

A drafting detail worth knowing if you are quoting these in a scope of work: all three definitions appear twice in the same document. §5, the definitions section, carries them at (xxi), (xxii) and (xxiii), word for word identical to §6(iii), (iv) and (xvi). Either locator is correct. This page cites the §6 numbers throughout, because §6 is also where the class list lives and a scope of work is naming a class rather than reciting a definition.

Vulnerability scanning vs vulnerability assessment vs penetration testing vs red teaming

Nine axes, and the differences that cost money

Vulnerability assessment vs penetration testing vs red teaming, compared

Most comparison tables on this subject vary one axis — depth — and present the four as a ladder. They are not a ladder. They differ on at least nine axes, and on three of them (knowledge of the target, who is told, and what counts as success) the differences run in opposite directions rather than in degrees.

AxisVulnerability scanningVulnerability assessmentPenetration testingRed team assessment
ObjectiveCoverage. Enumerate known conditions across as many hosts as possible.Completeness. Know the security deficiencies across a defined estate and rank them.Proof. Establish which weaknesses are exploitable and what exploitation reaches.Effect. Reach a defined objective and learn whether the organisation noticed.
Scope, and who sets itAn address range or a URL. Set by whoever runs the tool.An asset list. §13.1.1 requires the scope to be derived from the consolidated and updated asset inventory, and vetted by internal audit in consultation with the CISO.An asset list plus a rules-of-engagement document. §17(i) requires written rules of engagement from auditee management.An objective and a set of boundaries — not an asset list. The scope says what is off limits and what counts as success.
Knowledge of the targetWhatever the tool can reach unauthenticated.Full. Credentials, architecture diagrams, configuration and, where in scope, source. §13.1.4(ii) requires the auditee to assign a technical team as point of contact to assist and monitor the auditing organisation.Agreed per engagement, and it changes the finding set. Authenticated testing at every role is where authorisation defects live, and unauthenticated-only testing cannot see them.Deliberately limited at the start. The operator works from what an outsider could discover, and the value of the exercise depends on not being handed the map.
Who is told it is happeningEveryone, usually. It is a scheduled job.Everyone who has to provide access, credentials and environments.The teams providing access, plus change management. §15.1.2 requires temporary privileged access to be revoked immediately on completion.§15.1.1(i) is the clause: notification of the test is limited to key personnel — generally expected to include personnel at the policy-making level, as well as managers responsible for security processes, incident response, and security operations. If the SOC knows, you are not measuring the SOC.
How long it runsHours. It is bounded by the estate and the tool.Bounded by the asset count and the depth agreed. Read the man-hours, not the calendar.Bounded by the attack surface and the roles to be tested. A four-role application is not a one-role application with three extra logins.Bounded by the objective, not by the estate. §15.1.1(ii) also constrains the auditee: no unusual or major network changes during the period, because a changed environment invalidates the result.
What counts as successThe scan completed and the report generated.Every in-scope asset examined, every finding evidenced, nothing silently omitted.The exploitable path is demonstrated and reproducible, and its blast radius is established.The objective is reached — or the defence stops the operation, which is the better outcome and the one nobody budgets for.
What the deliverable provesThat a tool ran. Nothing about the findings has been confirmed by a person.That the estate was examined against a stated method and these are the deficiencies as at a stated date.That these specific paths work, against this build, in this environment. §10.1(i) limits the auditor to reviewing and reporting on the state of security at the point in time of the audit.That the detection and response capability performed this way against this adversary behaviour on these dates.
What it cannot tell youWhether any of it is exploitable, whether any of it matters, or what it missed.Whether a finding is reachable in practice, or what an attacker would chain together.Whether anyone would have noticed. A pentest is normally announced, and an announced test measures the surface, not the defence.Whether the estate is clean. A red team that reaches its objective through one route says nothing about the assets it never touched.
Named in the instruments asNothing. The word does not appear in the 2025 guidelines at all. It is a technique inside an engagement, not an engagement.§6(iii) Vulnerability Assessments, restated verbatim in the definitions at §5(xxi). In §13.2.3(i)(a) it is the VA half of “VAPT”.§6(iv) Penetration Testing, restated verbatim at §5(xxii). §13.2.3(i)(a) additionally names EAPT — External Attack Penetration Testing — as its own audit type, and expands the acronym without defining it.§6(xvi) Red Team Assessment, restated verbatim at §5(xxiii) — a separate class from (iii) and (iv), not a bigger version of either.

The row that decides the most arguments is “knowledge of the target”. In an assessment you hand the tester everything, because withholding information only buys you a worse map of your own estate. In a red team you withhold deliberately, because an operator handed the architecture diagram is no longer simulating anything. Both positions are correct for their own engagement and wrong for the other, which is why a single scope of work cannot govern both.

Routing

Start from what is driving it, not from the menu

Which one do you need?

Nobody wakes up wanting a §6(iv) engagement. Something arrives — a questionnaire, a hosting gate, an audit, a board question, an incident — and the engagement is the answer to it. Find the row that describes why you are here. The fourth column matters as much as the second, because buying the wrong one is rarely a failure to buy. It is buying the adjacent thing.

What is driving the requestWhat to buyWhy that oneWhat not to buy instead
An enterprise customer’s security questionnaire asks for a “penetration test report”§6(iv) penetration testing of the named application and its API tier, at every authenticated role, with the scope annexure naming the product the customer buys.The customer is asking for evidence that somebody tried, not for an inventory. The scope annexure is the part they will actually read.An unauthenticated external sweep of your IP range. It will be delivered on time, and the first reviewer who opens the findings will see that no result required a login.
SOC 2 or ISO 27001 evidence§6(iii) plus §6(iv) on the systems in the assurance scope, on a cadence you can show, with the retest and closure evidence retained.The auditor is testing whether you run a process, not whether one report exists. Dates, scope stability and closure matter more than depth in any single cycle.A one-off deep engagement with no retest. It proves a moment and leaves the period unevidenced.
A government hosting provider, or a safe-to-host clearanceApplication-level testing by a CERT-In empanelled organisation against the build that will ship, on the staging environment the hosting provider supplies, under §15.2.3(ii), with §6(iii) and §6(iv) both named in the scope.GIGW 5.3.1 requires an audit clearance certificate issued by NIC, STQC, an STQC empanelled laboratory or a CERT-In empanelled laboratory before hosting in production. Who signs is part of the requirement.Testing by a firm that is not on the published list. The work may be excellent and the certificate will not be the one the gate asks for.
The board asked whether the organisation would detect a breach§6(xvi) red team assessment, with an objective, a trusted-agent list under §15.1.1(i), and the four intervals defined before it starts.That is a question about your people and your runbooks. No amount of §6(iv) depth answers it, because a penetration test is announced.A larger penetration test. It will produce more findings and still say nothing about detection.
The first security test the organisation has ever commissioned§6(iii) across the asset inventory first, then §6(iv) on whatever the assessment shows matters.You cannot prioritise depth until you know the size of the estate. §13.1.1 has the scope derived from the consolidated and updated asset inventory for this reason.§6(xvi). An adversary simulation against an unexamined estate measures the wrong thing at the highest day rate on the menu.
A major release, a migration or a configuration change affecting sensitive dataA scoped audit of the change and what it touches, before implementation.§13.1.2(iii) classifies changes minor or major and requires a major change — system overhauls, technology migrations, or configuration adjustments affecting sensitive data or critical infrastructure — to undergo an audit before implementation, and §13.1.2(iv) requires an audit after every major change.Waiting for the annual cycle. The change gate is separate from the calendar and it comes first.
The annual cadence, with nothing in particular having changedThe comprehensive audit §6 frames and §13.1.2(i) requires — all aspects of the ICT estate, at least once in the year.§13.1.2(v) requires periodic audits even where no major change has occurred, because the vulnerabilities are new even when the system is not.Re-running last year’s scope unexamined. §13.2.3(ii)(b) requires the as-of date of the asset inventory in the report, which is the line that exposes a stale scope.
Something has already happened — an incident, or a near missThe investigation first, then §6(iii) and §6(iv) over the affected estate, then §6(xvi) once the gaps are closed, to test whether the fix to detection actually worked.§14.3(iii) names security incidents or breaches occurring during the audit period as a legitimate trigger for revising scope, and §18(vi) sets what a forensic report must say where evidence or logs were inadequate.A red team immediately. You already have the finding it would give you, and you have not fixed it yet.
Investor or acquirer diligence§6(iii) for coverage and §6(ix) source code review where the code is the asset, with the findings register and the closure evidence together.Diligence reads the remediation record more carefully than the finding list. An open critical with a dated plan reads better than a clean report nobody believes.A report with the findings removed. Item 21 of Annexure I to the empanelment terms expects reports to state all states of security found, not only the failed measures — a redacted one answers neither question.
Weekly or daily release cadenceContinuous tooling in the pipeline as hygiene, plus a periodic §6(iii)/§6(iv) engagement, plus the change gate above for anything classified major.§8(i) is explicit that solely tools-based testing should be discouraged, so the pipeline is the floor and never the whole answer. §13.1.2(ii) treats the stated frequency as a minimum.Treating the pipeline scanner as the audit. That is the substitution §8(i) exists to prevent, and it is the easiest one to make at speed.

Two rows deserve to be read together. The annual row and the change row are not alternatives: §13.1.2(i) sets the yearly minimum, §13.1.2(iii) requires an audit before a major change is implemented, and §13.1.2(iv) requires one after every major change. An organisation that ships a migration in March and audits in December has satisfied one of the three and missed the other two. More on turning any of these rows into a scope in how to scope a VAPT, and on the shapes each class takes in the types of VAPT.

Two different questions

“What is exploitable here” is not “would we detect and respond”

This is the distinction that survives every change of vocabulary, and the one worth carrying into a board paper. A penetration test measures the surface. A red team measures the organisation. An organisation can be strong on one and weak on the other, and the two results do not predict each other in either direction.

A penetration test asks: what is exploitable here?

The subject of the sentence is the system. Success is a demonstrated path with reproduction steps and a blast radius, and the answer is durable only for that build in that environment — §10.1(i) limits the auditor to reviewing and reporting on the state of security at the point in time of the audit.

Because the objective is proof, the test wants maximum access. Credentials at every role, the architecture, the API inventory, and often the source. Anything withheld shrinks the finding set rather than making the test more realistic.

It answers: which weaknesses are real, which are chainable, what each one reaches, and in what order to fix them. It cannot tell you whether anybody was watching, because your teams were told it was happening.

A red team asks: would we detect this, and respond?

The subject of the sentence is your organisation. §6(xvi) frames it as an exercise reflecting real-world conditions, conducted as a simulated attempt by an adversary. The route the operator takes is instrumental. The measurement is what your controls, your runbooks and your people did about it.

Because the objective is measurement, the exercise wants minimum disclosure. §15.1.1(i) limits notification of the test to key personnel, which the guidelines gloss as personnel at the policy-making level and managers responsible for security processes, incident response and security operations. §15.1.1(ii) adds the other half of the discipline: no unusual or major network changes during the period, because a changed environment invalidates the reading.

It answers: time to detect, time to triage, time to escalate, time to contain, and which of the four failed. It cannot tell you the estate is clean, because one successful route says nothing about the assets it never touched.

There is a sequencing consequence, and this is the page’s canonical statement of it. A red team run against an estate that has never had a systematic assessment is expensive theatre: the operator will enter through something an assessment would have found in an afternoon, and the exercise ends before it reaches the detection questions you paid for. Two clauses set the order between them. §6 frames it — auditee organisations are expected to ensure a comprehensive audit covering all aspects of their ICT systems at least once a year, and may also opt for additional assessments and audits during the year. §13.1.2(i) is the operative requirement: the cyber security audit should be conducted at least once in a year, with sectoral regulators free to increase that frequency. So the comprehensive annual audit is the floor, and adversary simulation is one of the things you layer on top of it once the floor holds. Wherever the annual rule is cited later on this page, it is this pair: §6 frames it, §13.1.2(i) requires it.

Setting one up

The eight artefacts a red team runs on

“Do not tell the SOC” is easy to say and hard to run. What makes an exercise legal, safe and measurable is a small set of documents that mostly do not exist in a penetration test, and that an auditee who has never commissioned one has no reason to know about. Each is listed with the clause it hangs on where the auditing organisation is CERT-In empanelled — and each is worth writing into the engagement letter where it is not, because none of these are the auditor’s to invent on your behalf.

§15.1.1(i)

The trusted-agent list

The named few who know the exercise is running. §15.1.1(i) tells the auditee to limit notification about the testing to key personnel only, says it is the auditee organisation’s discretion to identify who those key individuals are, and adds that they are generally expected to include personnel at the policy-making level as well as managers responsible for security processes, incident response and security operations. Write the list as roles with names against them, date it, and keep it short enough that the population under test is genuinely unaware — a workable default is the accountable executive, the CISO and the head of incident response, with every further name argued for rather than assumed. The clause gives a reason as well as a rule: it exists to prevent a temporary increase in security measures solely for the duration of the audit.

§13.2.6

The control cell and a single deconfliction channel

One channel, known to the trusted agents and to the operators, on which either side can ask “was that you?” and get an answer within minutes. It exists so that a real intrusion during the exercise window is not mistaken for the exercise, and so that a genuine outage is not left running while somebody guesses. §13.2.6 requires a well-defined escalation matrix for both the auditee and the auditing organisation for any problem encountered during the audit process, shared with the respective authorities. The clause does not use the word deconfliction, but read on a red team, a staffed channel is what satisfying it looks like. Name a person and a deputy on each side, with an out-of-hours number, because the exercise will not keep office hours.

§13.2.7(i), §13.2.2(v)

Written authorisation carried by each operator

Two clauses set the floor. §13.2.7(i) requires that in the case of remote testing the identity of the auditor, with mobile number and/or IP addresses, be disclosed and formal written permission be obtained from the auditee organisation clearly outlining the tasks to be performed, and §13.2.2(v) requires written approvals before penetration tests. What practice adds on top — and this part is our recommendation rather than the instrument’s requirement — is that the permission travels with the operator as a signed letter held for the duration, naming the authorising officer and their office, the exercise dates and window, the systems and premises in scope, the activities authorised, and the trusted-agent contacts to call if the operator is challenged or detained. Where any part of the exercise is physical, that letter is the difference between an exercise and an incident involving your own security staff.

§13.2.7(ii)

Specific written permissions for the four named techniques

Survivability-failure testing, denial-of-service testing, process testing and social engineering each need their own specific written permission under §13.2.7(ii) — the clause says “specific”, so a blanket authorisation to test does not carry them. §15.2.2(ii) adds explicit written permission before DoS, DDoS or flood testing over the Internet. Most red team scopes touch social engineering, which means most red team scopes need this and most engagement letters do not have it.

§15.2.2(iii)

Third-party consent, started at scoping

Where the exercise would touch a managed service provider, a shared SOC, a payment partner or anyone else outside your own organisation, §15.2.2(iii) bars it unless specific written consent is obtained from the target organisation. That consent is yours to get, not the auditor’s, and it moves at the speed of somebody else’s legal team. Start it when you write the objective. A consent request that begins at kick-off rather than at scoping moves the start date by whatever the other organisation’s legal review takes, and that delay is entirely predictable in advance.

§13.2.6, §15.2.2(iv)

Stop conditions, and who holds stop authority

Write the conditions that halt the exercise before it starts: a production outage attributable to the operation, an action that would affect a real customer or a real payment, discovery of a genuine prior compromise, or an unplanned law-enforcement or regulator involvement. Name one person on the auditee side and one on the auditor side who can call stop unilaterally, with a deputy each, and give both the deconfliction channel. §15.2.2(iv) pushes the same way for critical environments where availability is a top priority: testing should be conducted in a passive manner to avoid any potential downtime or service disruption. A stop authority with no named holder is a stop authority nobody exercises.

§15.1.1(ii)

The change freeze, which is the auditee’s to enforce

§15.1.1(ii) tells the auditee to refrain from implementing any unusual or major network changes during the testing period. On a red team that is a scheduling constraint with teeth: a firewall migration halfway through makes the detection result unreadable, because you can no longer say which control was in place when. Put the window on the change calendar before the engagement letter is signed, not after, and expect to move the exercise rather than the release.

§15.1.1(i), §16.1(ii)

The notification ledger

A dated record of who was told what, and when — including the trusted agents, any mid-exercise disclosure, and the moment the exercise was revealed at the end. It is what later proves the §15.1.1(i) discipline was respected, and it is what settles the debrief argument about whether a fast detection was real. It also feeds §16.1(ii), which requires the report to carry the audit process, duration, sampling decisions, manpower involved, exemptions, limitations and other constraints.

What does a red team actually measure?

Four intervals, and they are worthless until three things are fixed in writing before the exercise starts: what starts the clock, what each one means, and where the timestamp comes from. Most disputes at a red team debrief are definitional rather than factual — one side counts from engagement start and the other from first contact, or one side calls an alert that fired and was never read a detection and the other does not. Settle it in the engagement letter and the debrief argues about the gap instead of about the arithmetic.

IntervalWhen the clock starts and stopsWhat it actually tells youWhere the timestamp comes from
Time to detectStarts at the first operator action of consequence against a monitored asset — not at engagement start, and not at pretext delivery. Stops when an alert about that activity is generated by a control.An alert exists somewhere. Nobody has necessarily seen it. This measures instrumentation and nothing else.The SIEM or EDR record carrying the generation timestamp, read against the operator log for the same action. Both clocks stated in the same time zone, and reconciled if they differ.
Time to triageStarts at alert generation. Stops when a human first works the alert — opens the ticket, acknowledges the page, or otherwise takes it out of the queue.Somebody looked. This is the interval that separates a monitoring failure from a staffing or routing failure, and it is the one most often missing from a red team report.The ticket or case record with its first-touch timestamp, plus the on-call or paging log where one exists.
Time to escalateStarts at first triage. Stops when the alert is raised to the incident-response function as a suspected incident rather than handled as routine noise.The alert was believed. An alert triaged, closed as benign, and later shown to be the operation is the most expensive finding in the exercise and the one the ledger exists to prove.The escalation record, the IR channel message, or the call log — and the analyst’s own disposition note on the closed case where it was closed.
Time to containStarts at escalation. Stops when an action taken by the defence measurably impedes the operator — a credential revoked, a host isolated, a path blocked — as recorded on both sides.The response worked. Containment is the only one of the four the operator can corroborate from their own side, which is what makes it the most reliable number in the report.The defensive action record, paired with the operator log entry showing the access that stopped working and when.

Notice that the common phrase “time to detect” hides the second row. An alert generated at hour nine and first read at hour sixty-one is not a nine-hour detection and it is not a sixty-one-hour failure — it is a nine-hour detection followed by a fifty-two-hour triage gap, and those two numbers belong to different teams with different budgets. A report that gives you one number has decided that argument for you without telling you which way. Recording the intervals is the auditee’s job as much as the auditor’s: §15.1.3(i) puts monitoring the execution of the agreed tests on the auditee organisation, through the scheduled progress meetings.

What a red team timeline looks like

The same imaginary estate as the worked illustration below, on one clock, with both tracks side by side. Hours run from the first operator action of consequence, per the definitions above. This is an illustration built to show the shape of the artefact — it is not a case study and it does not describe any client, and the hours exist to make the gaps legible.

ClockOperator trackDefensive track
H−21 dObjective agreed and written: obtain and exfiltrate a sample of citizen records from the production database without being stopped. Trusted-agent list signed — Secretary, CISO, head of incident response. Stop authority named on both sides.Nothing. The managed SOC is not told, and will not be told until the debrief. The change freeze goes on the calendar for the exercise window.
H−14 dSpecific written permission obtained for social engineering under §13.2.7(ii). Consent request sent to the managed SOC provider under §15.2.2(iii), because the operation may generate activity they will handle.The provider’s legal team begins reviewing the consent request. This takes eleven days, which is why it was started first.
H−3 dReconnaissance against public sources only. No contact with the estate.No signal, and none expected. Nothing here is instrumented, and nothing here starts the clock.
H+0Pretext delivered to the agreed group. One recipient authenticates to a lookalike portal. Clock starts here: this is the first operator action of consequence against a monitored asset.The mail gateway scores the message and delivers it. No alert.
H+2Captured credential used against the identity endpoint from an unfamiliar network. Session established at a citizen-plus role.The impossible-travel rule does not fire because the source is in-country. No alert.
H+9Enumeration of the undocumented API base path. First request patterns that do not resemble any legitimate client.Alert generated by an API gateway rate rule nobody had reviewed in eighteen months. Time to detect: 9 hours. It routes to a shared queue.
H+31Internal header trust on the undocumented API yields administrative read across the tenant. The operator slows down deliberately.The alert is still unworked in the shared queue. The queue has no named owner at the weekend, which is the finding rather than the alert.
H+52Staged extract assembled. Exfiltration begins over a channel chosen to resemble a legitimate integration.The data-loss control logs the transfer and does not alert, because the destination matches an allowlist entry created for a decommissioned integration.
H+58Objective reached. Sample exfiltrated. The operator does not stop — the exercise now measures whether anyone arrives.Still nothing worked. Two records exist that would have answered the question, and neither has been read by a person.
H+61Operator continues low-rate activity to give the defence a live target.Monday shift picks up the H+9 alert. Time to triage: 52 hours. The analyst correlates it with the H+52 transfer log within twenty minutes.
H+62Access to the API base path begins failing.Escalated to incident response. Time to escalate: 1 hour from triage. The credential is revoked and the allowlist entry removed. Time to contain: 1 hour from escalation.
H+62 → debriefExercise revealed. Operator log handed over in full, timestamped, to be read against the defensive record.Four numbers, one story: detection worked at 9 hours, triage failed for 52, and once a human looked, escalation and containment took an hour each. The gap is not the SIEM. It is an unowned weekend queue.

What the four numbers say, and to whom. Detection at nine hours is an engineering result and a good one. Triage at fifty-two hours is an operating-model result and a bad one, and it belongs to whoever owns the weekend rota rather than to whoever owns the SIEM. Escalation and containment at an hour each say that once a human believed the alert, the response worked — which is the finding that stops a board from buying a detection platform to fix a staffing problem. One exercise, four numbers, three different owners. That is the deliverable, and it is why the timeline and not the intrusion narrative is the part worth paying for.

How to read a VAPT quote

When the quote says VAPT and scopes a scan

How to tell a scan from a penetration test in a quote

Nobody writes “this is a scan” on a proposal. The signals are structural, they are all visible before award, and most of them have a clause behind them. Each row is a thing you can look for in a document you already have, what it means, and the single question that settles it.

What you see in the quoteWhat it usually meansThe question that settles it
The deliverable is described as “a VAPT report” and nothing elseThe quote has not committed to a method, a depth or a coverage claim. VAPT is a category, not a specification — §13.2.3(i)(a) lists it alongside eight other named audit types and ends the list with “etc.”.Which of the §6 classes is this, and what is the method for each in-scope asset type?
The methodology line says “OWASP Top 10”§8(ii) says in terms that limited lists such as OWASP Top 10, SANS Top 25 and similar should not be considered as standards or references for audits, and that audits should instead include discovery of all known vulnerabilities based on comprehensive standards and frameworks. A methodology line naming only a top-ten list has therefore named something the guidelines expressly exclude as a reference.Which testing guide — WSTG, MSTG, OSSTMM 3 — and which control standard, at which version and level?
No man-hours anywhere in the documentYou cannot compare two quotes on calendar time alone, because a five-day engagement can be one person or four. §13.2.2(ii) requires the test plan shared by the auditing organisation to include both calendar time and man-hours, and item 10 of Annexure I to the empanelment terms says the same.Give me the test plan with man-hours per phase — planning, assessment, reporting, revalidation.
A named tool is the centre of the proposalTooling is expected, but tooling as the offer is not. §8(i) discourages solely tools-based testing, for the reason quoted in full above. The 2018 guidelines say the same in one line: auditors must utilise industry standard methodologies and best practices for security testing, and solely tools-based testing should be discouraged.What proportion of the effort is manual, and which classes of finding does the manual work exist to catch?
The price is the same whether we have one application role or sixAlmost certainly unauthenticated testing, or authenticated testing at one role. Authorisation defects only appear when a tester holds two accounts at different privilege levels and tries to cross the line between them.How many authenticated roles are in scope, and how many test accounts do you need from us at each?
No retest, or the retest is a separate quoteClosure has not been priced. §9.3(iv) says follow-up audits should be included within the scope or RFP proposal and must be conducted after closure of the vulnerabilities identified, and §13.1.1(g) requires the scope of work to specify follow-up audits as part of the engagement.How many retest rounds are included, and what triggers a chargeable one?
The word “red teaming” appears in a two-week web application quoteEither the word is decoration, or the quote is offering adversary simulation at the price of an application test. Both are problems, and the second is worse.Is this §6(iv) or §6(xvi)? If it is (xvi), what is the objective, who will be told, and what is out of bounds?
The scope names a URL and stopsThe admin console on a second hostname, the API tier, the mobile binary and the identity endpoint are all out of scope by omission. §13.2.3(ii)(c) requires version-specific details of web and mobile applications to be explicitly mentioned in the audit scope and report.Reconcile the scope against our asset inventory line by line, and name what is excluded.
The environment is not statedA finding set from staging and a finding set from production are different documents. §15.2.3(i) requires the environment — test, development, UAT, pre-production or production — to be specified.Which environment, and who is providing it on the day you start?
The final milestone pays “on issue of the certificate”The commercial structure is now arguing against the finding count. §7 requires payments not to be contingent upon the outcome of the audit, favourable or unfavourable, nor tied to the submission or approval of any closure reports.Re-cut the milestones on delivery of the phases, not on the conclusion.

If you only have time for one of these, take the roles. Ask how many authenticated roles are in scope and how many test accounts the auditor needs from you at each. A bidder offering a real application test will have an opinion about this before you ask, because the role matrix is what the effort estimate was built from. A bidder offering a scan will say they will confirm during kick-off, because the role count does not change what their tool is going to do. More on getting the scope right in how to scope a VAPT.

A worked illustration

One system, four engagements, four answers

The abstract difference becomes obvious the moment you run all four against the same thing. The system below is imaginary and the numbers exist to make the shapes legible — this is an illustration, not a case study, and it does not describe any client. Everything in the failures and timeline tables on this page should be read the same way. It is also deliberately the same imaginary estate used in the walkthroughs on what a safe-to-host certificate is and the types of VAPT, so that the four engagements, the certificate route and the testing types can be read against one system rather than three. A second, shorter contrast follows it, for the private-sector buyer whose trigger is a customer questionnaire rather than a hosting gate.

The system

A citizen-facing services portal. Four hostnames — public portal, administrative console, file service, identity endpoint. Six application roles from anonymous visitor to super-administrator. Three API base paths, one of them undocumented and built for an internal integration two years ago. One database. A mobile app that talks to the same APIs. Hosted by a provider the department does not control, with a SOC on a shared managed service.

Quote A — the scan sold as VAPT

Unauthenticated tooling against the four hostnames over two days. It returns 140 items: TLS configuration, missing headers, an outdated library banner, a handful of medium CVEs on the web tier. Not one of them requires a login. The undocumented API is never found, because nothing links to it. The report is delivered in a fortnight and every finding is true. The organisation now knows less than it thinks, because a clean-looking authenticated surface was never opened.

Quote B — the vulnerability assessment

The same four hostnames plus the database and the mobile binary, with credentials at all six roles and a configuration review of the hosting tier. Tooling runs, and then a person checks every result and discards the ones the tool got wrong. The API inventory is reconciled against the code, which is how the undocumented base path is discovered. The output is a complete register with CVSS supplemented by EPSS, every observation mapped to a CWE and, where one exists, a CVE. What it does not answer: which of these an attacker would actually use.

Quote C — the penetration test

The same scope, and a mandate to chain. A role check enforced in the interface but not in the controller lets a citizen-role account read another citizen’s documents. That alone is a high. Chained with the undocumented API, which trusts an internal header, it becomes administrative read across the tenant. The report carries reproduction steps, the blast radius and the three independent fixes that each break the chain. The critical is notified the day it is found, under §16.3(ii), not held for the draft.

Quote D — the red team assessment

One objective: obtain and exfiltrate a sample of citizen records from the production database, without being stopped. No asset list. Notification limited to the Secretary, the CISO and the head of incident response under §15.1.1(i) — the managed SOC is not told. The operation starts with a phishing pretext against a group agreed in advance, reported later in aggregate under §15.2.2(iii). The result that matters is not the route taken. It is that the first alert fired at hour 9 on a control nobody expected, and that nobody triaged it until hour 61 because the runbook routed it to a queue with no owner at the weekend.

What the four buy you

A is an artefact. B tells you the size of the problem. C tells you which parts of the problem are real and what they cost you. D tells you whether any of it would be noticed. They are not stages of the same product and they do not substitute for one another. They do have an order, for the reason set out above under the two questions: D against an estate that has never had B measures the wrong thing, because the operator finishes before reaching the questions D was bought to answer.

Notice what happens to the undocumented API across the four. Quote A never finds it, because nothing links to it. Quote B finds it by reconciling the inventory against the code. Quote C turns it into the second half of a chain. Quote D might never touch it at all, because the operator took a faster route — and the exercise would still be a success, because it was never measuring the API. Four true reports, four different pictures of the same system, and only one of them is wrong about what it claims: the one that called itself VAPT.

The same four engagements, for a private SaaS buyer

The portal above is a government estate, and the clauses land cleanly on it. Most of the people searching this comparison in India are not buying for a government estate — they are a SaaS vendor with a customer questionnaire on the desk and no hosting gate anywhere in sight. Same four engagements, different question, and one part of the answer changes materially. Imaginary again, for the same reason.

The system, and the trigger

A B2B SaaS platform: one multi-tenant web application, a public API, an admin back-office used by the vendor’s own staff, and a data pipeline into a managed warehouse. Four customer-facing roles plus two internal ones. Nobody is asking for a safe-to-host certificate. What arrived is an enterprise customer’s security questionnaire with a line reading “provide your most recent penetration test report, dated within twelve months”.

What the questionnaire is actually asking for

Almost always §6(iv) work — evidence that somebody competent tried to break the application and wrote down what happened — with a date, a scope and a remediation status. It is rarely asking for §6(iii) coverage of the whole estate, and it is almost never asking for §6(xvi). A VAPT report satisfies it if the scope annexure names the application the customer cares about and the penetration-testing half is real. It does not satisfy it if the scope names an IP range and the findings are all unauthenticated.

Where the multi-tenant wrinkle lives

Tenant isolation is the finding class this buyer cannot afford to miss, and it is structurally unreachable without two tenants and two roles inside each. That is a scoping decision, not a testing decision: it means asking the tester for accounts across two customer tenants, and it is the single question that separates a real quote from a cheap one here, in the same way the role matrix does for the portal above.

What the CERT-In instruments do and do not do here

The clauses on this page bind CERT-In empanelled auditing organisations. A private SaaS vendor buying from a non-empanelled firm gets none of them by default — which is exactly why the shortlist below exists. The 2022 Directions are a different matter: they reach service providers, intermediaries, data centres, body corporate and Government organisations alike, so log retention, clock synchronisation and the point of contact are live obligations for this vendor whether or not it ever commissions an empanelled audit.

The difference worth carrying away is not technical. For the portal, who signs is part of the requirement, because GIGW 5.3.1 names the four bodies that may issue the clearance. For the SaaS vendor, nobody is checking the signature — the customer is checking the scope, the date and the remediation status. That changes what you optimise the procurement for, and it changes which of the clauses on this page you have to write into the contract yourself.

What the deliverable proves

Three reports, three different burdens of proof

A report is the only part of a security engagement most stakeholders will ever see, so it is worth knowing what each kind has to carry. The floor is the same for all of them — §16.1(ii) and Annexure II of the empanelment terms set the content format — but what makes each one credible differs.

ElementIn a vulnerability assessmentIn a penetration testIn a red team assessment
The findings registerEvery in-scope asset, every observation, with objective evidence. §18(iii) requires observations to be well supported with objective evidence, compiled carefully with the report and presented so decision-makers can make credible risk-based decisions.The same, plus reproduction steps and the demonstrated consequence of each exploited path.Fewer findings, and a different kind. The register records the enabling conditions of the operation, not an inventory of the estate.
Severity§16.2(ii) requires CVSS for severity, supplemented with EPSS for real-world exploitation likelihood, and every observation mapped to a CWE and a CVE number.The same scoring, but the score is no longer the argument — the demonstrated impact is, and the report should say where the two disagree.Severity by consequence to the objective. A medium that provided the pivot outranks a high that went nowhere.
The timelineAudit dates, and the as-of date of the asset inventory. §13.2.3(ii)(b) requires that inventory date to be reflected in the audit reports.The same, plus the dates critical and high findings were notified. §16.3(ii) requires those to be notified during the audit on an as-and-when-found basis, not held for the report.The heart of the deliverable: every operator action against every defensive action, on one clock, with the clock-start conventions written down. Generated at, triaged at, escalated at, contained at — or not. There is a worked example of the shape above.
What was not covered§16.1(ii) requires exemptions, limitations and other constraints in the report, and §16.1(iii) requires every asset given in scope by the auditee to be mentioned in it.The same, plus anything the rules of engagement forbade. §10.1(ii) requires in-scope assets that could not be accessed to be named with reasons, and brought to CERT-In’s notice.The boundaries that were respected, so nobody reads a clean result as coverage it never claimed.
Honesty about unknownsItem 20 of Annexure I to the empanelment terms: reports include all unknowns clearly marked as unknowns. Item 21: reports state all states of security found, not only the failed measures.The same two items, and they bite harder — an attack path that was plausible but unproven belongs in the report labelled as unproven.Whether the alert was never generated, generated and never triaged, or triaged and not acted on. Those are three different findings with three different owners, and collapsing them into “we did not detect it” wastes the exercise.
MetricsItem 22 of the same annexure: only qualitative metrics based on industry-accepted methods, based on a mathematical formula and not on feelings of the auditor.Same rule. A risk rating that cannot be derived from a stated formula is an opinion wearing a number.Time to detect, time to triage, time to escalate, time to contain — each one useless until the clock-start convention and the meaning of “detect” are fixed in writing. The four intervals are defined above, under how a red team is actually run.

The two Annexure I rules in the “honesty about unknowns” row deserve to be quoted into your contract verbatim, because they are the crispest statement of what a report does with the things it could not establish. Reports include all unknowns clearly marked as unknowns. Reports state all states of security found, not only the failed measures. They do not stand alone: §16.1(ii) requires exemptions, limitations and other constraints in the report, §16.1(iii) requires every in-scope asset to be mentioned in it, §10.1(ii) requires in-scope assets that could not be accessed to be named with reasons, and §13.2.4(ii) requires the auditing organisation to communicate exemptions, limitations and constraints to the auditee in the first place. Annexure I is the version short enough to paste into a contract. A report that only lists failures is not a stricter report — it is an unreadable one, because you cannot tell a control that passed from a control nobody looked at. More on reading one in how to read a VAPT report.

What the tester tests against

Methodologies are named, and one popular answer is ruled out

Whichever of the four you buy, the methodology line in the scope decides how repeatable the result is. §8(ii) of the audit policy guidelines is unusually prescriptive here, and it begins by ruling out a widely used methodology line.

“The limited lists such as OWASP Top 10, SANS Top 25 and similar, should not be considered as standards or references for audits.”
— Comprehensive Cyber Security Audit Policy Guidelines, version 1.0, 25 July 2025, §8(ii). The same clause says audits should instead include discovery of all known vulnerabilities based on comprehensive standards and frameworks.

The comprehensive alternatives §8(ii) names are ISO/IEC standards, the Cyber Security Audit Baseline Requirements (National Security Council Secretariat, publication NSCS-46-16 Rev 1.0, October 2020, published on CERT-In’s website), the CSA Cloud Controls Matrix for cloud security, OSSTMM 3, the OWASP Web Security Testing Guide, the OWASP Application Security Verification Standard, the OWASP Mobile Security Testing Guide and the OWASP DevSecOps Maturity Model. §8(iii) adds that the baseline requirements document should be used by auditees and auditing organisations to build their audit programme, so it belongs in your scope as well as theirs. Two of those are linked here because this page tells you to demand one by name, and a demand you cannot point at is an argument rather than a requirement. Note the drift in the mobile entry: §8(ii) names the Mobile Security Testing Guide (MSTG), and OWASP now publishes mobile testing guidance as the Mobile Application Security Testing Guide (MASTG), so name the document and its version in the scope rather than the acronym.

One detail is worth settling in the scope rather than discovering in the report. ASVS defines three verification levels: Level 1 is the lowest assurance level and is fully penetration-testable from outside, Level 2 is intended for applications handling sensitive data and is the level recommended for most applications, and Level 3 is the highest, for applications requiring significant verification. The level definitions were restructured between the 4.x and 5.x lines — at 22 September 2026 the 5.x line was the current stable release — so a scope of work should name the version as well as the level, and should expect that sentence to age. Neither the audit policy guidelines nor the GIGW manual picks a level for you — GIGW guideline 5.3.1 names OWASP ASVS, OWASP Top 10 and OWASP MAVS in its government organisation action without naming an ASVS level, so the choice is the buyer’s and belongs in the scope of work.

Severity, meanwhile, is not a matter of taste. §16.2(ii) requires CVSS to categorise the severity of vulnerabilities, supplemented with EPSS to reflect the likelihood of real-world exploitation, and requires every reported observation or vulnerability to be mapped with a CWE and a CVE number. That pairing does real work in a report: a medium by CVSS with a high EPSS is not a medium in practice, and a report that carries only one of the two numbers has given you half a prioritisation.

Rules that apply whichever one you bought

The engagement rules do not change with the label

A red team engagement is not a licence to skip the paperwork, and a vulnerability assessment does not escape the data rules because it feels low-risk. Where the auditing organisation is CERT-In empanelled, the following apply to all of it. They are set out in full on what a CERT-In empanelled auditor may and may not do.

Written approval before the intrusive parts

§13.2.2(v) requires written approvals before penetration tests and before tools are installed, with installation in the presence of the auditee’s system administrator. §13.2.7(ii) extends it, in terms: “Specific written permissions must be obtained from the auditee organization before conducting tests that involve survivability failures, denial-of-service (DoS), process testing, or social engineering.” Note the word “specific” — a general authorisation to test does not carry these four. An approval ledger — who approved what, when, in writing — is the cheapest artefact in the engagement and the one nobody keeps.

No DoS, DDoS or flood testing over the Internet without explicit written permission

§15.2.2(ii): explicit written permission must be obtained from the auditee organisation prior to conducting denial-of-service, distributed denial-of-service or flood testing over the Internet, to prevent disruption of services. The 2018 guidelines put it as two flat prohibitions: refrain from carrying out distributed denial of service testing over the Internet, and refrain from any form of flood testing where a person, network, system, or service is overwhelmed from a larger and stronger source. The same sentence is item 18 of Annexure I to the empanelment terms.

Social engineering is scoped, anonymised and bounded

§15.2.2(iii) requires social engineering and process testing to use anonymised or statistical techniques so that no individual is personally identified or penalised, limits it to employees inside the agreed scope, and bars customers, business partners, vendors and other third parties unless specific written consent is obtained. Items 14 and 15 of Annexure I say the same. A phishing simulation may report a click rate. A leaderboard of names is the rule being broken.

Availability outranks thoroughness in critical environments

§15.2.2(iv): in critical environments where availability is a top priority, testing should be conducted in a passive manner to avoid any potential downtime or service disruption. That is a constraint on technique rather than a ban on the target, and it belongs in the engagement letter alongside the window and a named rollback contact.

The environment is named, and staging comes first

§15.2.3(i) requires the environment to be specified — test, development, UAT, pre-production or production. §15.2.3(ii) requires the website to be tested on the staging server or testing environment provided by the hosting service provider before the audit certificate is issued, with hash values and version numbers obtained from the auditee and included in the report.

Your data stays in India, and is destroyed afterwards

§10.3 requires auditee data to be stored only on systems located in India, encrypted on auditor laptops, and wiped so that it cannot be retrieved by any known forensic technique, with a certificate of deletion formally issued to the auditee. Where the agreement is silent, §10.3(vi) sets a default retention of one year from completion of the project, and §10.3(v) limits what may be retained to the audit reports. The 2014 Policy Guidelines for Handling Audit related Data, which §10.3(vii) requires adherence to by name, adds that the report must not be shared or hosted on public file or cloud services unless under the auditing organisation’s technical and administrative control or specifically authorised by the auditee.

The 2022 Directions are verified in every assignment

§15.2.1(iv) requires the organisation to include verification of compliance with the CERT-In Directions of 28 April 2022 in every audit assignment, with findings and relevant evidence in the audit report. That is independent of which class of engagement you bought — the log retention, the clock synchronisation and the point of contact get checked in a VAPT as well as in a compliance audit.

The report reaches CERT-In within five days

§10.6 makes it mandatory for the auditing organisation to provide information pertaining to audits carried out by it to CERT-In within five days of completion of the audit, in the format CERT-In prescribes. Clause 3.2.2 of the empanelment terms adds the audit report and metadata, and critical vulnerabilities with auditee details that were pointed out but not fixed even during follow-up audits. §13.2.1(iii) requires the auditor to tell you this before the assignment starts.

One rule is easy to miss and changes how a red team is planned. Where the engagement will touch systems or people outside your own organisation — a managed service provider, a shared SOC, a payment partner — §15.2.2(iii) bars testing against customers, business partners, vendors and other third parties unless specific written consent is obtained. It is treated above as a planning step, because it is yours to obtain rather than the auditor’s and it moves at somebody else’s speed.

Do these CERT-In rules apply if our tester is not empanelled?

No. These are conditions of empanelment, not general law, and a tester who is not on CERT-In’s published list owes you none of them by default. §2 of the 2025 guidelines states that they are binding on CERT-In empanelled auditing organisations and auditee entities covered under the relevant provisions — and does not enumerate those provisions — while the empanelment terms and conditions bind the firms that signed them. That matters, because most private-sector buyers in India are commissioning testing from firms that are not empanelled, and reading this page as though its rules arrived automatically is the single easiest mistake to make with it.

The remedy is not to avoid those firms. It is to import the clauses. Ten of them do most of the work, and each one is short enough to paste into an engagement letter as a numbered requirement with the source named beside it. Where you do engage an empanelled organisation, you get these anyway — along with §10.6 and clause 3.2.2 of the empanelment terms, which send the report and metadata to CERT-In within five days whether or not you would prefer that. Both positions are workable. Neither is the default you get by saying nothing.

  • A test plan with calendar time and man-hours, before work starts§13.2.2(ii)
  • The environment named — test, development, UAT, pre-production or production — in the scope and in the report§15.2.3(i)
  • Every in-scope asset named in the report, and every asset that could not be reached named with the reason§16.1(iii), §10.1(ii)
  • Critical and high findings notified during the engagement as and when found, not held for the draft§16.3(ii), §16.4
  • Follow-up testing inside the scope and the price, and the final report withheld until closure is verified§9.3(iv), §13.1.1(g), §16.3(v)
  • Your data held only in India, encrypted, wiped beyond forensic recovery, with a certificate of deletion issued to you§10.3
  • Specific written permission before survivability-failure testing, denial of service, process testing or social engineering§13.2.7(ii)
  • Social engineering reported in anonymised or statistical form, inside the agreed employee group, with no third parties absent their written consent§15.2.2(iii)
  • Unknowns marked as unknowns, and all states of security found reported — not only the failuresAnnexure I items 20 and 21, empanelment terms
  • Fees on predefined scope, deliverables and timelines, never contingent on the finding count or on a closure report§7

Two things reach you regardless of who tests. The CERT-In Directions of 28 April 2022 apply by their own terms to service providers, intermediaries, data centres, body corporate and Government organisations — so log retention, clock synchronisation and the point of contact are live obligations for a private company whether or not it ever commissions an empanelled audit, and §15.2.1(iv) folds verification of them into any audit assignment that does happen. And your own contractual and regulatory duties to customers are unaffected by whom you hired to test. Those are set out in the CERT-In Directions of 2022.

What goes wrong

Eight ways the wrong engagement gets bought

Every one of these is recoverable if it is caught at scoping and expensive if it is caught at the report. The middle column is the point at which each one usually surfaces.

The failureWhere it surfacesHow you knowWhat it costs
A scan was bought and a penetration test was assumed
The quote said VAPT, the work was a credentialed scan with a cover page, and nothing was exploited or chained. The estate looks assessed and the exploitable path is still there.
The next real incident, or the customer’s security questionnaireEvery finding maps to a CVE and none has reproduction steps. No finding required two accounts. No finding required understanding the business logic.A second engagement, and a period where the organisation believed it had been tested.
A red team was bought and the SOC was told
Somebody sensible warned the operations centre so the alerts would not cause a panic. The exercise then measured a defence that was watching for it.
The debriefDetection times are implausibly good, and the timeline shows the first alert before the first operator action of any consequence.The entire budget. §15.1.1(i) limits notification to key personnel for exactly this reason.
A penetration test was bought to answer a detection question
The board asked whether the organisation would notice an intrusion. A pentest was commissioned, came back with a findings register, and answered a different question well.
The board paperThe report has no timeline of defensive actions in it, because nobody was measuring any.A year of believing detection was tested when only exposure was.
The roles were never enumerated
Testing ran with one account. Every authorisation finding — horizontal, vertical, tenant-to-tenant — was structurally unreachable.
Scoping, discovered at the findings reportThe scope annexure names hostnames and no roles, and the test accounts were requested on day one rather than agreed in the scope.The most damaging class of web-application defect, unexamined and unremarked.
Nobody fixed what “done” meant
The engagement had a start date and a report date and no success criterion. For a red team that is fatal, because the exercise has no objective to reach or fail to reach.
Week twoThe status calls are about activity rather than progress toward anything.A narrative with no verdict, which no board can act on.
The scope was revised verbally
Assets appeared, a subsidiary was added, an environment moved. None of it went into writing, so the report describes an engagement nobody agreed to.
Report reviewThe scope annexure and the findings do not describe the same estate. §14.2 requires revisions to be documented in writing with justification, evaluated for impact on timelines, resources and deliverables, approved by authorised representatives and recorded as an addendum to the audit engagement letter — so the absence of an addendum is itself the signal.A deliverable nobody can review against an agreed scope, and a dispute with no written baseline to settle it.
The red team result was used as an assurance certificate
The operation failed to reach its objective, and the result was presented as evidence that the estate is secure.
The next auditA one-page summary with a conclusion sentence and no coverage statement.A large untested estate, and a document that implies otherwise to everyone who reads it.
The same firm built it, fixed it and tested it
One team wrote the application, remediated the findings, and signed the assurance on its own work.
Whenever somebody independent reads the arrangementThe remediation owner and the testing owner have the same email domain. §5(xvii) defines conflict of interest to expressly cover the same entity implementing controls and auditing them, or auditing while responsible for remediation, as overlaps that inherently undermine the independence of the audit process.Assurance that fails the first independent read, and a finding at the next audit.

The second row is the one that hurts most, and it is normally done out of consideration rather than carelessness. Somebody tells the operations centre so the on-call engineer is not woken at 3am by an exercise, and in that moment the budget stops measuring anything. If the concern is real — and it often is — the answer is the trusted-agent list and the deconfliction channel described above: a named, silent holder of stop authority at policy-making level, which is exactly the population §15.1.1(i) contemplates, and not a broadcast to the team under test. §15.1.1(i) even gives the reason in its own words: the limit exists to prevent a temporary increase in security measures solely for the duration of the audit.

Recovery

If you already bought it, this is the week to fix it

Most people reading a page like this are not planning a procurement. They are holding a report that does not look like what they expected, or a customer email asking a question the report cannot answer. The table above tells you which failure you are in. This is what to do about it. Work down in order and stop when the problem is solved — and note that the first three steps establish facts rather than fault, which is what makes the conversation recoverable.

  • 01 Establish what you actually received, before anyone argues about what was promised. Read the delivered report against §16.1(ii): does it carry the audit process, the detailed scope, the duration, the methodologies and standards, the tools, the manual process, the findings, the prioritisation, the sampling decisions, the manpower involved, and the exemptions and limitations? Then apply this page’s own test: did any finding require a login, and did any finding require two accounts at different privilege levels? A document that fails both is a scan whatever its cover says.
  • 02 Ask for the test plan with man-hours, even after the fact. §13.2.2(ii) requires the plan shared by the auditing organisation to include both calendar time and man-hours, and item 10 of Annexure I to the empanelment terms says the same. Man-hours per phase against the finding set is the fastest way to establish whether manual effort happened, and the answer arrives in one email.
  • 03 Require the coverage statement the report should already carry. §16.1(iii) requires every asset provided in the scope by the auditee to be mentioned in the report, and §10.1(ii) requires in-scope assets that could not be accessed to be named with reasons. Ask which in-scope assets were not reached and why. Silence on that question is itself the answer.
  • 04 Tell the customer or the regulator waiting on the report where you actually are, in writing, before they find out from the document. A dated note saying the current report covers X, that Y was not reached, and that a further engagement is scheduled, survives scrutiny. A report handed over in the hope that nobody reads the scope annexure does not, and it converts a procurement problem into a credibility one.
  • 05 Use the revision route rather than inventing one. §14.2 requires scope revisions to be documented in writing with justification, evaluated for impact on timelines, resources and deliverables, approved by authorised representatives of both sides and recorded as an addendum to the audit engagement letter. If what you bought and what you need are genuinely different engagements, that is an addendum or a new engagement — not an argument about the existing one.
  • 06 Keep the payment discipline while you do it. §7 requires fees to be based on predefined scopes, deliverables and timelines, and not to be contingent on the outcome of the audit, favourable or unfavourable, nor tied to the submission or approval of any closure reports. Decline to accept an undelivered phase if that is the position. Do not renegotiate the fee against the finding count, because that is the arrangement the clause exists to prevent.
  • 07 Use the stop-and-replace clause if it is in the contract, and put it in the next one if it is not. §12.4(ii) contemplates a contractual right for the auditee to stop the audit and choose another auditing organisation within a reasonable time, to avoid financial loss on both sides.
  • 08 Where the firm is CERT-In empanelled, give feedback afterwards whichever way it ends. §11(iii) describes auditee feedback as both a right and a duty, says it is kept confidential and acted on promptly, and points auditees at empanelment@cert-in.org.in for the form. It costs nothing, it has no deadline, and it is the step everybody skips.

One thing not on the list: do not commission the second engagement until step one is done. The commonest way a scan-sold-as-VAPT becomes two wasted engagements is that the buyer, having discovered the first was thin, writes the second scope in the same words. Establish what you actually received, write the scope from the asset inventory and the role matrix rather than from the last proposal, and name the §6 class. The second engagement is only worth buying if it is a different document from the first.

Where we fit

We deliver CERT-In audits

We deliver CERT-In audits, end to end, with our CERT-In empanelled partners.

See how a CERT-In audit runs with us. For the testing itself, see penetration testing and VAPT. For the assurance programmes these engagements usually sit inside, see ISO 27001, SOC 2 and the DPDP Act.

Frequently Asked Questions

What is the difference between VAPT and penetration testing?
They are not alternatives, and that is the answer most comparisons miss. Penetration testing is the PT inside VAPT. VAPT stands for Vulnerability Assessment and Penetration Testing, so a quote labelled “VAPT” and a quote labelled “penetration test” differ by whether a systematic assessment of the estate is bundled with the testing — not by how deep the testing goes. CERT-In’s Comprehensive Cyber Security Audit Policy Guidelines (v1.0, 25 July 2025) treat the two halves as separate classes of engagement: vulnerability assessments at §6(iii), penetration testing at §6(iv). So when a seller prices VAPT and a penetration test as two products, the question that settles it is which of §6(iii) and §6(iv) each one actually covers, across which assets. In practice the label difference usually signals one of three things: that the VAPT bundles breadth the pentest does not, that the pentest goes deeper on a narrower target, or — most often worth checking — that the two words are being used interchangeably and the scope annexure is the only document that tells you anything.
What is the full form of VAPT?
Vulnerability Assessment and Penetration Testing. CERT-In writes it out at §13.2.3(i)(a) of the 2025 audit policy guidelines as “VAPT (Vulnerability Assessment Penetration Testing)”, listing it as one of nine named audit types that must be communicated to the auditee before the audit commences — a list the guidelines themselves end with “etc.”, so it is not a closed set. The two halves are defined separately elsewhere in the same document, at §6(iii) and §6(iv).
What is VAPT?
VAPT stands for Vulnerability Assessment and Penetration Testing. It is an umbrella term for two distinct activities sold together: a vulnerability assessment, which examines a defined estate to identify and rank security deficiencies, and a penetration test, which actively attempts to exploit weaknesses to establish what an attacker could reach. CERT-In’s Comprehensive Cyber Security Audit Policy Guidelines (v1.0, 25 July 2025) treat them as separate classes of engagement — vulnerability assessments at §6(iii) and penetration testing at §6(iv) — and §13.2.3(i)(a) lists “VAPT (Vulnerability Assessment Penetration Testing)” as one of nine named audit types, a list the guidelines themselves end with “etc.”. Because VAPT is a category rather than a specification, the word tells you almost nothing about what a quote contains: the scope, the authenticated roles, the manual effort and the retest are what tell you.
What is the difference between a vulnerability assessment and a penetration test?
Objective and proof. A vulnerability assessment answers “what is wrong here, and how much of it is there” — §6(iii) defines it as examination of an information system or product to determine the adequacy of security measures, identify security deficiencies, provide data from which to predict the effectiveness of proposed security measures, and confirm the adequacy of such measures after implementation. A penetration test answers “what is actually exploitable, and what does exploiting it reach” — §6(iv) defines it as a security testing methodology in which individual components or the application as a whole are actively tested to identify and exploit potential vulnerabilities, with the objective of determining whether those vulnerabilities can be exploited to compromise the application, access sensitive data, or affect the underlying infrastructure and environment. An assessment aims at breadth and completeness, while a test aims at depth and demonstration. Most organisations need both, which is why they are usually sold as one engagement.
What is the difference between a penetration test and a red team engagement?
A penetration test measures your attack surface. A red team assessment measures your defence. §6(xvi) defines a Red Team Assessment as an exercise, reflecting real-world conditions, conducted as a simulated attempt by an adversary to attack or exploit vulnerabilities in an enterprise’s information systems — a separate class of engagement from penetration testing at §6(iv), not a larger version of it. Three practical differences follow. A pentest is scoped by assets and a red team by objective. A pentest is announced to the teams that provide access. A red team is not, and §15.1.1(i) limits notification of the test to key personnel, generally expected to include personnel at policy-making level and managers responsible for security processes, incident response and security operations. And the deliverables differ: a pentest produces proven attack paths, while a red team produces a timeline of what was detected, when, by whom, and what happened next.
Is vulnerability scanning the same as a vulnerability assessment?
No, and the instruments are unusually direct about it. Scanning is a technique inside an engagement, not an engagement: it is not one of the twenty-six classes §6 lists, and a full-text search of the 2025 audit policy guidelines returns no occurrence of “scan”, “scanning” or “scanner” anywhere in the document. What the guidelines do say is §8(i) — solely tools-based testing should be discouraged, because tool-based audits may focus primarily on automated processes and may overlook non-automated or manual components of the IT infrastructure, and this limitation can result in an incomplete view of the overall security. The 2018 Guidelines for CERT-In Empanelled Information Security Auditing Organizations say the same in one line: auditors must utilise industry standard methodologies and best practices for security testing, and solely tools-based testing should be discouraged. A vulnerability assessment, by contrast, is defined at §6(iii) as examination of an information system or product to determine the adequacy of security measures, identify security deficiencies, provide data from which to predict the effectiveness of proposed security measures, and confirm the adequacy of such measures after implementation. A scan with a cover page is also the easiest thing to detect in a delivered report: no finding in it requires a login, and no finding in it required a human being.
Why does CERT-In use the term “Red Team” for an auditor’s own verification team?
Because the two uses come from two different documents written seven years apart, and both are still in force. The Guidelines for CERT-In Empanelled Information Security Auditing Organizations (v3.0, May 2018) say, under Technical, that auditors should deploy a verification team (Red Team) to verify the work performed by their audit team (White Team). That is an internal quality-control requirement on the auditing organisation: a second group inside the firm checks the first group’s work. The 2025 guidelines carry the same idea without the colour coding at §15.2.5(iii), which requires a separate verification team to review and validate the work of the audit team. Separately, §6(xvi) of the 2025 guidelines defines a Red Team Assessment as an adversary-simulation engagement. So when an Indian proposal says “red team”, ask which one is meant — you may be reading a description of the firm’s maker-checker process rather than an offer of adversary simulation.
What is a White Team in CERT-In’s terminology?
In the 2018 auditor guidelines the White Team is the audit team itself — the people who performed your engagement — and the Red Team is the verification team that checks their work before it is issued. Note that this differs from how the colours are used in wider exercise practice, where a white team usually means the referees or exercise control group, a blue team means the defenders, and a purple team means blue and red working together deliberately. Those wider senses are industry convention, not CERT-In’s: a full-text search of the three instruments this page relies on — the 2025 audit policy guidelines, the 2018 auditor guidelines and the empanelment terms and conditions v7.2 — returns no occurrence of “blue” or “purple” in any of them, and the only colours they use are the Red Team and White Team of that single 2018 sentence, plus Red Team Assessment as the name of the §6(xvi) engagement class. When a document uses a colour, read it against the source it is quoting rather than assuming a shared convention.
What does EAPT mean, and how is it different from VAPT?
EAPT stands for External Attack Penetration Testing. The expansion is CERT-In’s own, at §13.2.3(i)(a) of the 2025 guidelines, which requires the auditing organisation to communicate the type of audit before commencement and names nine of them: VAPT, EAPT, DLA (Device Level Audit), Configuration Audit, Process Audit, Mobile Application Security Audit, Web Application Security Audit, API Security Audit and Compliance audit — a list the guidelines end with “etc.”, so it is not a closed set. The important thing to know about EAPT is that the guidelines name it and never define it: the acronym appears exactly once in the document, and it is not among the twenty-six classes §6 defines. Read from the words themselves, the distinction is vantage point — an external attacker’s view of the estate rather than a credentialed one — but because there is no official definition, that reading is ours and not the instrument’s. Which means an RFP asking for EAPT should say in terms which vantage point and which roles it means, rather than relying on the acronym. Buying EAPT and reporting it internally as VAPT is a coverage claim the scope will not support either way.
How do I tell whether a quote is offering a scan or a real test?
Six things, all visible before you sign. Whether the methodology names a testing guide rather than the OWASP Top 10 — §8(ii) says limited lists such as OWASP Top 10 and SANS Top 25 should not be considered standards or references for audits. Whether the test plan states man-hours as well as calendar time, which §13.2.2(ii) requires. How many authenticated roles are in scope and how many test accounts the auditor is asking you for. Whether the environment is named, which §15.2.3(i) requires. Whether a retest is priced in, which §13.1.1(g) and §9.3(iv) require to be in the scope. And whether the price changes when your role count changes — if it does not, the roles are probably not being tested.
Which one does a CERT-In empanelled audit or a safe-to-host certificate require?
Neither term maps cleanly to an acronym, which is why the question keeps arriving. Start with what the two documents actually say. GIGW 3.0 guideline 5.3.1 requires that a website, web application, web portal or mobile app “have been Security Audited and an Audit Clearance certificate has been issued by NIC/ STQC/ STQC empanelled laboratory/CERT-In empanelled laboratory before hosting in production environment”. GIGW’s new-features page calls the same artefact by its working name: government organisations “must continue to obtain a ‘safe to host’ certificate issued by the cybersecurity auditors empanelled by CERT-In/STQC or the auditors of STQC or NIC”. So 5.3.1 is the requirement and “safe to host” is the phrase — and the phrase appears on the new-features page, not in 5.3.1 itself. Separately, GIGW 5.3.2 (Hosting Environment) puts a recurring obligation on the hosting estate: among the mandatory aspects of choosing a hosting service provider, “Servers, Network devices used to host the website should be hardened with latest security patches and periodic Vulnerability Assessment (VA) and Penetration Testing (PT) followed by corrective actions should be performed as per the security policy.” Cite that one to the GIGW 3.0 manual rather than to the live attributes page, which prints “5.3.2” twice and mis-numbers the policies statement. The practical answer: the certificate rests on application-level testing, the hosting estate carries its own recurring VA and PT obligation alongside it, and §6 and §13.2.3 add that the class of engagement has to be named in the scope and in the report either way.
How often does each of these need to happen?
The floor is annual and it is an organisation-level duty, not a per-application one. Two clauses carry it and they do different jobs: §6 frames it, stating that auditee organisations are expected to ensure a comprehensive audit covering all aspects of their ICT systems at least once a year and may also opt for additional assessments and audits during the year. §13.1.2(i) is the operative requirement, stating that the cyber security audit should be conducted at least once in a year and adding that sectoral regulators may decide to increase the frequency based on the size of the organisation, the criticality of the assets being audited and the complexity of the adoption of digital infrastructure. §13.1.2(ii) says that frequency may be treated as the minimum. §13.1.2(iii) then adds the change rule: every change goes through formal change management and is classified minor or major, minor changes need standard change management but not an audit, and major changes — system overhauls, technology migrations, or configuration adjustments that affect sensitive data or critical infrastructure — must undergo an audit before implementation. §13.1.2(iv) requires an audit after every major change, and (v) requires periodic audits even where nothing major has changed. Red teaming carries no cadence of its own: the phrase “Red Team” appears in the 2025 guidelines only in the definition at §6(xvi), restated at §5(xxiii), and nowhere in §13.1.2 or anywhere else that sets a frequency. It is one of the additional assessments §6 contemplates during the year, scheduled on judgment rather than on a clause.
Will a red team engagement disrupt production?
It can, which is why the constraint belongs in writing before it starts. §15.2.2(iv) requires that in critical environments where availability is a top priority, testing should be conducted in a passive manner to avoid any potential downtime or service disruption. §15.2.2(ii) requires explicit written permission before denial-of-service, distributed denial-of-service or flood testing over the Internet, and the 2018 guidelines prohibit DDoS testing over the Internet and any form of flood testing where a person, network, system or service is overwhelmed from a larger and stronger source. §13.2.7(ii) requires written permission before survivability-failure testing, denial-of-service testing, process testing and social engineering. The workable arrangement is an agreed window, a named out-of-hours contact on both sides, a stop condition, and an escalation matrix — §13.2.6 requires a well-defined escalation matrix for both organisations for any problem encountered during the audit process.
Can the red team phish our staff, and can we be told who clicked?
Yes to the first, within limits. No to the second. §15.2.2(iii) requires social engineering and process testing to be conducted in a controlled and ethical manner, and where general staff — untrained or non-security personnel — are targeted, requires anonymised or statistical techniques so that no individual is personally identified or penalised. It limits the exercise to the group of employees explicitly included in the agreed scope, and bars customers, business partners, vendors and other third parties unless specific written consent is obtained. Items 14 and 15 of Annexure I to the empanelment terms say the same in the 2018 lineage. So the deliverable reports a rate and a pattern. A list of names is the rule being broken, and it is usually broken with good intentions.
What should the report contain, whichever engagement we bought?
§16.1(ii) sets the floor: the report should be clear, precise and comprehensive, and include all details of the audit process, the detailed scope, the duration of the audit, methodologies and standards used, tools, manual process, findings, prioritisation, sampling decisions, manpower involved, exemptions, limitations and other constraints. §16.1(iii) requires every asset provided in the scope by the auditee to be mentioned in it, and §16.1(iv) requires draft and final versions with the date of issuance of each. §16.2(i) requires an executive summary for the board or top management that translates technical findings into business risks, and §16.2(ii) requires CVSS for severity supplemented with EPSS, with every observation mapped to a CWE and a CVE. Annexure II of the empanelment terms sets the content format, and Annexure I adds the two honesty rules worth quoting in a contract: reports mark all unknowns clearly as unknowns, and state all states of security found rather than only the failed measures.
Does the auditor have to send our test results to CERT-In?
Where the auditing organisation is CERT-In empanelled, yes, and you should be told so before the engagement starts. §10.6 makes it mandatory for the auditing organisation to provide information pertaining to audits carried out by it to CERT-In within five days of completion of the audit, in the format CERT-In prescribes from time to time, to enable CERT-In to act in matters of capacity building, audit framework, benchmarking, quality control and other measures — and states that the audit data submitted will be kept confidential. Clause 3.2.2 of the empanelment terms adds the audit report and metadata within the same five days, plus critical vulnerabilities with auditee details that were pointed out during the audit but not fixed even during follow-up audits. Clause 3.1.7 confirms that this happens without the auditee’s explicit permission. §13.2.1(iii) requires the auditor to inform you of the requirement before the assignment starts.
Is a red team assessment the same as a purple team exercise?
No. In common industry usage a purple team exercise is a deliberately collaborative one: the offensive operators and the defenders work together in the open, replaying known adversary behaviours so that detection engineering can be improved technique by technique. It optimises for learning rather than for measurement, which is the opposite trade-off from a red team assessment, where the defenders are unaware and the value comes precisely from that. Neither word carries a CERT-In meaning: a full-text search of the 2025 audit policy guidelines, the 2018 auditor guidelines and the empanelment terms v7.2 returns no occurrence of “purple” or “blue” in any of the three. §6(xvi) defines Red Team Assessment and the instruments stop there. So if either word appears in an Indian scope of work, it carries the meaning the parties give it and nothing more — which means defining it in the engagement letter under §14.1(ii) rather than assuming it is understood. A purple team exercise is also a reasonable answer to a red team result you did not like: once you know detection failed, the collaborative format fixes it faster than repeating the measurement.
Does the CERT-In panel list tell me who can do red teaming?
Partly, and it is worth reading the field properly. The published list of empanelled organisations carries, for each one, a snapshot of skills and competence with seven numbered fields, and §12.1(i) says that information should be used by organisations or sectoral regulators to identify and select auditing organisations. Field 3 is “Capability to audit, category wise (add more if required)” — a Yes or No answer against categories the organisation itself lists. There is no fixed taxonomy: the category lines genuinely differ between organisations, and some answers are No. Field 4 gives audits carried out in the last twelve months, field 5 gives numbers by category, field 6 gives technical manpower by qualification, and field 7 gives the manpower deployed on government and critical-sector work. So the panel answers whether a firm claims a category and how much of it they say they have done — not whether they are good at it. §12.2(iv) puts that burden on you: check the domain of audits conducted, previous audits, methodology, tools and relevant-domain experience, and consider the available alternatives, before selecting.
Does our VAPT satisfy a customer’s request for a penetration test report?
Usually yes, and the scope annexure decides it rather than the title page. A customer asking for a penetration test report wants evidence that somebody competent actively tried to exploit the product they buy from you, with a date and a remediation status. A VAPT report satisfies that if the penetration-testing half is real and the scope names the application the customer cares about — §6(iv) work, as opposed to §6(iii) coverage with the exploitation never attempted. It does not satisfy it if the scope names an IP range, if the environment is unstated, or if no finding in the report required a login. Three things to check before you send it. Does the scope annexure name the product and its API tier, per §13.2.3(ii)(c), which requires version-specific details of web and mobile applications in the scope and the report? Does §16.1(ii)’s contents list actually appear — methodologies, tools, manual process, sampling decisions, exemptions and limitations? And is the remediation status current, since a report with open criticals and no closure dates raises the question it was sent to close. Where the report is going outside your organisation, note also that a report prepared for you is not automatically shareable: §16.5 and §16.6 govern distribution and consent on the auditor’s side, and your own engagement letter should say what you may do with it.
Is VAPT mandatory in India?
Not as a free-standing legal duty on every organisation, and anyone telling you otherwise is compressing several different instruments into one sentence. Four routes create the obligation in practice, and which one reaches you decides what you have to buy. First, a government website or app heading for production hosting: GIGW 5.3.1 requires an audit clearance certificate from NIC, STQC, an STQC empanelled laboratory or a CERT-In empanelled laboratory before hosting. Second, the audit policy guidelines themselves, which §2 states are binding on all CERT-In empanelled auditing organisations and auditee entities covered under the relevant provisions — noting that §2 does not enumerate those provisions — and which at §4(ii) describe auditee organisations as those in the public and private sectors “required to or are seeking to evaluate their cyber security posture”. Third, your own sector instrument, tender or customer contract: §13.1.2(i) contemplates sectoral regulators increasing audit frequency and §12.1(i) contemplates them using CERT-In’s published snapshot to select auditors, but the guidelines name no regulator, so whether a regulator requires this of you is a question about their instrument and not about CERT-In’s. Fourth, the CERT-In Directions of 28 April 2022, which reach service providers, intermediaries, data centres, body corporate and Government organisations — these do not by themselves command an audit, but §15.2.1(iv) folds verification of compliance with them into every audit assignment, so once you are audited at all they are in scope.
Does a red team assessment have to be done by a CERT-In empanelled organisation?
Not unless something in your own position requires it. Red Team Assessment is one of the twenty-six classes of engagement §6 of the audit policy guidelines lists, which means it is in scope of the document — but the document is binding on CERT-In empanelled auditing organisations and auditee entities covered under the relevant provisions, not on the security market at large. If the exercise has to sit inside an empanelled audit programme, or if a regulator, tender or customer contract requires an empanelled firm, then it does. Otherwise it is a commercial choice. Two things follow that are worth deciding deliberately. If you do use an empanelled organisation, the engagement carries the obligations on this page — including §10.6 and clause 3.2.2 of the empanelment terms, which put the report and metadata with CERT-In within five days of completion, and §15.2.1(iv), which folds verification of the 2022 Directions into the assignment. If you do not, none of §13.2.2(ii), §15.2.2, §10.3 or §16.x reaches your tester by default, and the protections you want have to be written into the contract. Where you are selecting from the published list, §12.1(ii) describes what CERT-In publishes for each organisation and field 3 of the snapshot is a Yes or No against categories the organisation itself lists — so the list tells you whether a firm claims the category, not whether it is good at it.
Do these CERT-In rules apply if our tester is not CERT-In empanelled?
No, and this is the most important sentence on the page for a private-sector buyer. Almost every rule quoted here is a condition of empanelment. §2 of the 2025 audit policy guidelines states that they are binding on CERT-In empanelled auditing organisations and auditee entities covered under the relevant provisions, and the empanelment terms and conditions bind the firms that signed them. A testing firm that is not on CERT-In’s published list owes you none of it by default: not the test plan with man-hours at §13.2.2(ii), not the India-only data handling and certificate of deletion at §10.3, not the specific written permissions at §13.2.7(ii), not the anonymisation rule for social engineering at §15.2.2(iii), and not the report contents at §16.1(ii). The remedy is not to avoid non-empanelled firms — many are excellent — but to import the clauses into your engagement letter, which is why this page prints a shortlist of the ones worth copying verbatim. Two things do reach you regardless of who tests: the CERT-In Directions of 28 April 2022, which apply to service providers, intermediaries, data centres, body corporate and Government organisations by their own terms, and your contractual and regulatory duties to customers, which no testing arrangement displaces.
How much does a VAPT cost?
We do not publish a figure, because a number without a scope is not a price, and a price quoted against an unnamed scope is the problem this page exists to describe. What the cost is actually built from is visible in the test plan §13.2.2(ii) requires: man-hours per phase — planning, assessment, reporting and revalidation — multiplied by the seniority of the people on each. The variables that move it are the asset count and what kinds of asset they are, the number of authenticated roles to be tested and whether the application is multi-tenant, whether an API tier and a mobile binary are both in scope, whether source code review or SAST is included, whether a cloud configuration audit is included, how many retest rounds are priced in, and whether your environment will be ready on the day the tester starts. One structural rule constrains any quote: §7 requires fees to be based on predefined scopes, deliverables and timelines, and states that payments should not be contingent upon the outcome of the audit — favourable or unfavourable — nor tied to the submission or approval of any closure reports. A milestone that pays on issue of the certificate is a commercial structure arguing against the finding count, and it should be re-cut before award. Compare bids on man-hours per phase rather than on the total, and the gap between two prices usually explains itself in about ten minutes.
How long does a VAPT take?
Longer than the testing window, which is the part most plans get wrong. Read the calendar in four blocks and the answer becomes specific to you rather than generic. Scoping: reconciling the asset inventory the scope has to be derived from under §13.1.1, enumerating roles and API base paths, and agreeing the environment. Mobilisation: the NDA and the engagement letter §14.1(ii) requires, the audit-team information and documented approval §13.2.2(i) requires before formal commencement, the test plan with calendar time and man-hours, and the test accounts at every role. Assessment: the testing itself, bounded by the attack surface and the role count — a four-role application is not a one-role application with three extra logins. Then remediation and revalidation, which is the block that actually moves the date, because §16.3(v) withholds the final report until closure and the follow-up audit on production are complete, and closure runs at your development team’s speed rather than the auditor’s. Two things reliably add weeks and both are avoidable: an environment that is not ready on day one, and a retest that was not in the original scope and now needs a variation approval. If a red team is in the plan, add the third-party consent lead time under §15.2.2(iii), which is measured in weeks and is yours to obtain rather than the auditor’s.
References

The instruments behind every clause

Every definition and rule on this page is drawn from one of the following, and each is linked so you can read the clause rather than our paraphrase. Section numbers in the form §13.2.2(ii) refer to the Comprehensive Cyber Security Audit Policy Guidelines unless another document is named.

Every §-locator on this page was checked against the instruments below on 22 September 2026, and every URL below was fetched on the same date with its status code, content-type and byte size recorded. Both halves of that matter, and the second is the one usually skipped: cert-in.org.in answers 200 with a 938-byte HTML page for unknown paths under /PDF/, so a status code alone proves nothing about whether a document exists. The 2025 guidelines are version 1.0 and will be superseded. Where an instrument is revised, this block is where it changes first. Two documents those guidelines name are deliberately absent because they cannot be retrieved: the “Method of verifications to compliance with CERT-In Directions issued on 28.04.2022” cited at §15.2.1(iv), and the Deter and Punish Framework cited at §11(iv) and §19. As at 22 September 2026, both cert-in.org.in paths printed in the guidelines served the CERT-In home page rather than a document. They are named here as the guidelines name them, and not linked.

Four statements on this page are negative — that scanning is not named in the 2025 guidelines, that blue and purple teams are not defined anywhere in the instruments, that red teaming carries no stated cadence, and that EAPT is named without being defined. Each of those was established by full-text search of the 2025 audit policy guidelines, the 2018 auditor guidelines and the empanelment terms and conditions v7.2 on 22 September 2026, not by having failed to find them. Absence is a claim like any other, and it needs the same work.

  • Comprehensive Cyber Security Audit Policy Guidelines · Indian Computer Emergency Response Team (CERT-In), MeitY · Version 1.0, 25 July 2025 · 69 pages, 20 sections · relied on for §2, §4(ii), §5(xvii) and the definitions restated at §5(xxi)–(xxiii), §6 and its definitions at (iii), (iv), (ix) and (xvi), §7, §8(i)–(ii), §9.3(iv), §9.5(iii), §10.1, §10.3, §10.6, §11(iii), §12.1, §12.2(iv), §12.4(i)–(ii), §13.1.1, §13.1.2(i)–(v), §13.1.3, §13.1.4(ii), §13.2.1(iii), §13.2.2, §13.2.3, §13.2.6, §13.2.7(i)–(ii), §14.1(ii), §14.2, §14.3, §15.1.1, §15.1.2, §15.2.1(iv), §15.2.2, §15.2.3, §15.2.5(iii), §16.1–§16.6, §17(i), §18(iii) and §18(vi)
  • Guidelines for CERT-In Empanelled Information Security Auditing Organizations · Indian Computer Emergency Response Team (CERT-In), MeitY · Version 3.0, May 2018 · 6 pages · relied on, under Technical, for the verification team (Red Team) verifying the audit team (White Team), for industry standard methodologies rather than solely tools-based testing, and for the DDoS and flood-testing restrictions
  • Empanelment of Information Security Auditing Organisations — Terms and Conditions for Empanelment · Indian Computer Emergency Response Team (CERT-In), MeitY · Version 7.2, April 2024 · 10 pages · relied on for clauses 3.1.7 and 3.2.2, and for Annexure I items 10, 12, 14, 15, 17, 18 and 20 to 22, and Annexure II, the audit report content format
  • Empanelled Information Security Auditing Organisations by CERT-In — the snapshot information · Indian Computer Emergency Response Team (CERT-In), MeitY · the published list §10.2(vi), §12.1(i) and §12.3(iii) refer to · 997 pages at the time of checking · relied on for the anatomy of the snapshot and the seven fields it carries
  • Policy Guidelines for Handling Audit related Data · Indian Computer Emergency Response Team (CERT-In), MeitY · Version 1.0, June 2014 · 5 pages · required by §10.3(vii) by name · relied on for §5.3.3, the prohibition on hosting the report on public file or cloud services
  • Directions under sub-section (6) of section 70B of the Information Technology Act, 2000 · CERT-In, MeitY · No. 20(3)/2022-CERT-In · 28 April 2022 · the directions §15.2.1(iv) requires to be verified in every audit assignment
  • Cyber Security Audit Baseline Requirements · National Security Council Secretariat, Government of India · publication NSCS-46-16 Rev 1.0, October 2020 · 19 pages · published on CERT-In’s website and named at §8(ii), §8(iii) and §13.1.8(i)
  • Guidelines for Indian Government Websites and Apps (GIGW 3.0) — the manual · National Informatics Centre with STQC and CERT-In, MeitY · the PDF linked from guidelines.india.gov.in as “Download GIGW Manual 3.0” · 121 pages · relied on for guideline 5.3.1 (the audit clearance requirement, manual p.80) and guideline 5.3.2 (hosting environment, manual p.84 onwards, government organisation action item (f), which is the source of the periodic VA and PT obligation quoted here) · cite the manual for these numbers: the live attributes page prints “5.3.2” twice and mis-numbers the policies statement
  • GIGW 3.0 — security guidelines and attributes (the live page) · guidelines.india.gov.in · relied on for the quote-exact text of 5.3.1 and the evaluator action requiring a valid certificate · note the numbering caveat above · the phrase “safe to host” does not appear on this page
  • GIGW 3.0 — new features · guidelines.india.gov.in · the page that carries the phrase in official use: government organisations “must continue to obtain a ‘safe to host’ certificate issued by the cybersecurity auditors empanelled by CERT-In/STQC or the auditors of STQC or NIC”
  • OWASP Application Security Verification Standard · Open Worldwide Application Security Project · not a government source · named at §8(ii) of the audit policy guidelines and in GIGW 5.3.1 · relied on for the existence of three verification levels, and for the 5.x line being the current stable release at 22 September 2026 — a scope of work should name the version it means, because that will change
  • OWASP Web Security Testing Guide · Open Worldwide Application Security Project · not a government source · named at §8(ii) as one of the comprehensive alternatives to limited lists · listed here because this page tells buyers to demand a named testing guide, which means giving them the document
  • OWASP Mobile Application Security Testing Guide · Open Worldwide Application Security Project · not a government source · §8(ii) names the “OWASP Mobile Security Testing Guide (MSTG)”, but at 22 September 2026 OWASP publishes mobile testing guidance at the URL below as the Mobile Application Security Testing Guide (MASTG), under the OWASP Mobile Application Security project. Name the document and its version in a scope of work rather than the acronym
  • CERT-In SAMVAAD 2026 concludes — press release · Press Information Bureau, Ministry of Electronics & IT, Government of India · Release ID 2256581 · 29 April 2026 · relied on only for the statement that AI driven red teaming methodologies were among the topics presented

Written By Expert Auditors

Surendra Pal SinghChief Information Security Officer & Data Protection OfficerCISODPOCISAMCSEITILISO 27001 Lead AuditorISO 27701 Lead AuditorISO 42001 Lead Auditor
Saundhi ChauhanLead AuditorISO 27001 Lead AuditorISO 27701 Lead AuditorISO 42001 Lead Auditor
Last reviewed: 22 September 2026 • Content verified by certified lead auditors

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