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Learn · CERT-In

What CERT-In Is, and What It Actually Does.

CERT-In is the Indian Computer Emergency Response Team — the agency the Central Government appointed under section 70B of the Information Technology Act, 2000 to serve as India's national agency for cyber security incidents. It collects and analyses incident information, issues alerts and advisories, coordinates response, publishes guidelines, empanels the organisations that perform information security audits in India, and issues directions that are binding on the entities it names.

The distinction the whole hub turns on: CERT-In empanels auditors. It does not certify auditees. There is no CERT-In certificate issued to your company, no CERT-In accreditation of a business, and no register of CERT-In-certified organisations — there is a list of empanelled auditing organisations, and the report is signed by one of them.

70Bthe section of the IT Act, 2000 that creates CERT-In
Jan 2004operational as India’s national CSIRT
27 Oct 2009statutory footing — section 70B in force
6 hoursthe incident reporting window under the 2022 Directions

Plain-English explainer · IT Act, 2000 s.70B · CERT-In Rules, 2013 · Directions of 28 April 2022 · Comprehensive Cyber Security Audit Policy Guidelines v1.0, 25 July 2025 · Last reviewed September 2026

CERT-In — the Indian Computer Emergency Response Team — is the agency of the Government of India appointed under sub-section (1) of section 70B of the Information Technology Act, 2000, by a notification dated 27 October 2009, to serve as the national agency for cyber security. It functions under the administrative control of the Ministry of Electronics and Information Technology, and it is headed by a Director General — section 70B(2) requires the Central Government to provide the agency with one. On its own website CERT-In describes itself as “the national nodal agency for responding to computer security incidents as and when they occur”, and states that it “is operational since January 2004”. It publishes its own description of itself in the standard CSIRT format — RFC 2350, version 1.0 of 17 March 2022 — and that document states the constituency plainly: the Indian cyber community and Indian cyberspace, with services to organisations in the Government, public and private sectors, and to individuals and home users as well. In that document CERT-In puts its authority in one sentence: “CERT-In is designated as the National Nodal Agency for Incident Response under Section 70(B) of the Indian Information Technology Act 2000.”

What CERT-In stands for

CERT-In is short for the Indian Computer Emergency Response Team. The acronym reads oddly because it is not built from the words in order: it is CERT — Computer Emergency Response Team, the international name for this class of body, used by national teams worldwide — with “In” for India appended. CERT-In and ICERT are both used for the same agency. CERT-In’s own 2025 audit policy guidelines note that the agency appointed by the 2009 notification “is now referred as CERT-In or ICERT”, and CERT-In is the form used throughout the Directions, the guidelines and the email addresses. The Act itself uses the full name, not the acronym.

When CERT-In was established, and why two dates circulate

Both dates you will see are right, and they answer different questions. CERT-In has been operational since January 2004 — that is CERT-In’s own wording on cert-in.org.in, and it is the date the national CSIRT began work, before there was a section of the Act to put it in. Its statutory footing dates from 27 October 2009: section 70B was inserted into the Information Technology Act, 2000 by the Information Technology (Amendment) Act, 2008, which the published Act records as coming into force with effect from 27 October 2009, and CERT-In’s own instruments describe the agency as appointed under sub-section (1) “vide notification dated 27th October 2009 published in the official Gazette”. So: operating from 2004, statutory from 2009. A source that gives you only one of those is not wrong, it is answering half the question — and the half that matters for compliance is the 2009 one, because obligations run from the statute rather than from the help desk.

What it does is set out in sub-section (4) of section 70B, in six clauses: collection, analysis and dissemination of information on cyber incidents; forecast and alerts of cyber security incidents; emergency measures for handling cyber security incidents; coordination of cyber incidents response activities; issue guidelines, advisories, vulnerability notes and whitepapers relating to information security practices, procedures, prevention, response and reporting of cyber incidents; and such other functions relating to cyber security as may be prescribed. Sub-section (6) then gives it the power to call for information and give directions to service providers, intermediaries, data centres, body corporate and any other person, in order to carry out those activities — and sub-section (7) attaches punitive consequences to failure. That chain, from (1) through (4) to (6) and (7), is the whole legal architecture, and almost every practical question about CERT-In resolves by asking which link in it you are standing on.

The part that generates the most confusion is the audit ecosystem, and it is worth stating the mechanism before the detail. Sub-section (5) says the manner of performing CERT-In’s functions shall be as prescribed, and the Rules made under it — the Information Technology (The Indian Computer Emergency Response Team and Manner of performing functions and duties) Rules, 2013, notified on 16 January 2014 — prescribe information security assurance and audit to CERT-In at rule 9. That is the origin of the empanelment scheme: CERT-In assesses and lists information security auditing organisations, those organisations perform audits under commercial contracts with auditees, and CERT-In sets the rules those organisations must follow and the consequences when they do not. CERT-In is the referee and the rule-maker. It is not the auditor, and it is not a certification body.

Key Takeaways

  • CERT-In is the Indian Computer Emergency Response Team. It has been operational as India’s national CSIRT since January 2004 on its own account, and on a statutory footing since 27 October 2009, when section 70B of the Information Technology Act, 2000 came into force and the Central Government appointed the agency under sub-section (1) by gazette notification. It functions under the Ministry of Electronics and Information Technology and is headed by a Director General.
  • Its six statutory functions under section 70B(4) are: (a) collection, analysis and dissemination of information on cyber incidents, (b) forecast and alerts, (c) emergency measures, (d) coordination of response activities, (e) issuing guidelines, advisories, vulnerability notes and whitepapers, and (f) such other functions as may be prescribed.
  • Section 70B(6) empowers CERT-In to call for information and issue directions to service providers, intermediaries, data centres, body corporate and any other person. Section 70B(7) attaches punitive consequences to non-compliance. This is what makes a CERT-In direction binding rather than advisory.
  • The Directions of 28 April 2022 are the binding instrument most organisations meet first: NTP synchronisation to NIC or NPL, mandatory reporting of twenty classes of incident within six hours of noticing, a designated point of contact, 180 rolling days of logs held inside India, five-year subscriber records for data centre, VPS, cloud and VPN providers, and five-year KYC and transaction records for virtual asset providers.
  • CERT-In empanels information security auditing organisations. Empanelment attaches to the auditing organisation, not to the organisation being audited, and it does not transfer — there is no such status as a “CERT-In certified” company.
  • CERT-In is not a certification body, it does not audit your company in the ordinary course, and its own guidelines instruct auditors to ensure it is not made or projected to be a part of any contract between an auditee and its auditor.
  • We deliver CERT-In audits, end to end, with our CERT-In empanelled partners.
CERT-In obligations and deadlines

Every CERT-In clock, in one table

The rest of this page takes each of these apart. This is the summary to keep: what you owe, by when, under which clause, and the artefact that proves you did it. Every row cites the instrument it comes from, and no row is an interpretation of one.

ObligationThe clockInstrument and clauseWho owes itThe evidence that proves it
Report an Annexure I incident to CERT-In6 hours from noticingDirections of 28.04.2022, direction (ii)Service providers, intermediaries, data centres, body corporate, Government organisationsThe filing itself, with the detection timestamp it reports, reconciled against the incident register entry it came from.
Synchronise all ICT system clocks to NIC or NPLContinuousDirection (i)All addresseesConfiguration across every device class, plus log evidence of actual synchronisation events and drift within tolerance.
Designate a point of contact, and keep it currentOn designation, and on every changeDirection (iii) and Annexure IIAll addresseesThe dated Annexure II filing to info@cert-in.org.in, plus proof the named mailbox is monitored and re-filed on change.
Enable and retain logs of all ICT systems, within Indian jurisdictionRolling 180 daysDirection (iv)All addresseesA system-generated retention configuration, a live retrieval of a 180-day-old record, storage-region evidence, and coverage reconciled to the asset inventory.
Maintain seven validated fields of subscriber records5 years, surviving cancellation of the registrationDirection (v)Data centres, VPS, cloud service and VPN service providersThe verification step in the onboarding flow and its retained output, against each of the seven fields.
Maintain KYC and financial transaction records, reconstructable5 yearsDirection (vi) and Annexure IIIVirtual asset service providers, exchanges and custodian wallet providersA live reconstruction of one historic transaction from the stored elements, and the named KYC regime the process was built against.
Comprehensive audit covering all aspects of the ICT estateAt least once a year2025 audit policy guidelines, §6 and §13.1.2(i)Auditee organisations covered by the guidelinesThe audit report, with the date up to which the asset inventory was updated stated in it under §13.2.3(ii).
Audit a major changeBefore implementation§13.1.2(iii)AuditeeThe change classification record. “Major” is defined by risk, not size — a configuration adjustment affecting sensitive data or critical infrastructure counts.
Re-audit a web application under GIGWAt least once a year, or on any change to the source code, whichever is earlierGIGW 3.0, statement 5.3.1 developer actionGovernment organisations and their developersThe current audit clearance certificate, and the hash and version it was issued against.
Auditor sends the audit report and metadata to CERT-InWithin 5 days of completion of the audit§10.6, and empanelment T&C clause 3.2.2The empanelled auditing organisation — not youNothing you hold. Clause 3.1.7 says it happens without your permission, and §13.2.1(iii) says the auditor must tell you so before the assignment starts.
Auditor reports critical vulnerabilities left unfixed after follow-upWithin 5 days of completion of the auditEmpanelment T&C clause 3.2.1 and 3.2.2The empanelled auditing organisation, with your details attachedYour closure record for every critical finding — the only side of this filing you control.

One date is deliberately not in that table because it is not a recurring clock: when the 2022 Directions started to bite. They became effective 60 days after 28 April 2022 generally, on 25 September 2022 for MSMEs, and on 25 September 2022 for the validation limb of direction (v)(a) and (v)(f), for all four provider classes. The second and third of those come from a separate extension order of 27 June 2022, which is linked from CERT-In’s own Directions page and is missing from almost every summary of the Directions in circulation.

What CERT-In does

The six functions, and what each one looks like

These are the functions as the Act sets them out. Each card says what it is in operation — because the gap between a statutory clause and a working help desk is where most of the practical questions live.

(a)

Collection, analysis and dissemination of information on cyber incidents

The 24x7 incident response help desk at incident@cert-in.org.in and 1800-11-4949, the incident reporting form on cert-in.org.in, and the analysis that turns individual reports into sector-wide warnings. This is also the function the six-hour reporting clock in the 2022 Directions exists to feed — the clock is not an end in itself, it is the input to clause (a).

(b)

Forecast and alerts of cyber security incidents

Security alerts, advisories and vulnerability notes, plus indicators of compromise and situational awareness of existing and potential threats. Subscription runs through subscribe@cert-in.org.in. CERT-In also states in its RFC 2350 that it has been authorised by the CVE Program as a CVE Numbering Authority for vulnerabilities impacting all products designed, developed and manufactured in India — so an Indian product vulnerability can receive a CVE identifier from an Indian authority.

(c)

Emergency measures for handling cyber security incidents

Reactive services when an incident is live, including evidence collection and incident investigation, and a cyber forensic laboratory that extracts and analyses data from digital devices involved in cyber crimes. This is the function the power to call for information exists to serve.

(d)

Coordination of cyber incident response activities

CERT-In’s RFC 2350 lists the stakeholders it interacts with and seeks assistance from under the Act: sectoral computer emergency response teams, intermediaries, internet registry and domain registrars, industry, vendors of IT products including security products and services, academia and R&D organisations, security and law enforcement agencies, individuals, international CERTs, forums and expert groups, the agency engaged for the protection of critical information infrastructure, and the Department of Telecommunications. The same document records that CERT-In has been a full member of FIRST and an operational member of APCERT since 2006, and a listed team in TF-CSIRT since 24 June 2021.

(e)

Issue guidelines, advisories, vulnerability notes and whitepapers relating to information security practices, procedures, prevention, response and reporting of cyber incidents

The publication function, and the one most often misread. A guideline published under clause (e) and a direction issued under sub-section (6) are different instruments with different consequences, and CERT-In issues both. Knowing which one is on your desk is the whole of the compliance question.

(f)

Such other functions relating to cyber security as may be prescribed

The clause that lets the Rules extend the remit, and the one the whole assurance side of CERT-In hangs from. The 2013 Rules used it, and CERT-In states the result in its own words: “The provision of rule no.9 of these Rules, 2013, inter-alia, prescribes the activity of Information security assurance and audit to CERT-In.” That is the legal root of the empanelment scheme, of the audit policy guidelines, and of every CERT-In empanelled audit report signed in India.

Read the list again with a specific question in mind: where is certification? It is not there. Nothing in sub-section (4) empowers CERT-In to certify an organisation, and CERT-In does not do it. What clause (f) permits is extension by Rules, and the extension that was actually made — rule 9 of the 2013 Rules — is information security assurance and audit. That is the empanelment of auditors, which is a different thing from the certification of auditees, and the difference is the single most consequential misunderstanding in the Indian market. See CERT-In empanelment explained for how the scheme works, and who can issue safe-to-host certificates for where the signing authority actually sits.

How to contact CERT-In

CERT-In’s services, help desk and contact channels

The operational picture below comes from CERT-In’s RFC 2350, version 1.0 of 17 March 2022 — the least rhetorical account of the agency available, because the format is a standard CSIRT self-description rather than a communications document. It prints the address as Electronic [sic] Niketan, 6 CGO Complex, Lodhi Road, New Delhi – 110003. It records that “Director General, CERT-In is the Head of the Organization” and describes an establishment of around 100+ officers working at different levels.

Incident response

A 24x7 incident response help desk, evidence collection and incident investigation, and a cyber forensic laboratory. The help desk is the operational face of the agency: phone 1800-11-4949 (toll free) and +91-11-24368572, fax 1800-11-6969 (toll free), email incident@cert-in.org.in, with an incident reporting form published on cert-in.org.in.

Prevention and awareness

Tracking of security threats and cyber attacks, security alerts and advisories, and security workshops and awareness programmes. Alerts and advisories reach info@cert-in.org.in and advisory@cert-in.org.in, and subscription runs through subscribe@cert-in.org.in.

Vulnerability coordination

Responsible disclosure and coordination for vulnerabilities reported to CERT-In, at vdisclose@cert-in.org.in — an activity CERT-In says it has undertaken since its inception, and the basis on which it became a CVE Numbering Authority (above).

Security quality management

The assurance side: a security assurance framework and audit services, empanelment of security auditors for information security audit including vulnerability assessment and penetration testing, episodic security audits of key organisations, promotion of security best practices and standards, cyber security exercises and drills, and the Cyber Crisis Management Plan.

Botnet cleaning

The Botnet Cleaning and Malware Analysis Centre — Cyber Swachhta Kendra, at csk.gov.in — established by CERT-In to detect compromised devices in India and to notify and enable cleaning of end-user systems, working with internet service providers, antivirus companies, academia and industry.

Training and capacity building

Training and upgrading of technical know-how for stakeholders, and cyber security training and awareness programmes. CERT-In’s own description of its services also includes scanning of cyber space for vulnerabilities, breaches and malicious activity.

The channels

Which address does what

Mixing these up costs time in the hour you can least afford it. An incident report sent to the information desk is not a filing under direction (ii), and a vulnerability disclosure sent to the incident help desk lands in a 24x7 queue built for something else.

ChannelUse it for
incident@cert-in.org.inReporting a cyber security incident. This is the incident response help desk, operated 24x7, and it is the email channel named in direction (ii) of the 2022 Directions.
1800-11-4949 (toll free) · +91-11-24368572The incident response help desk by phone, 24x7. The toll-free number appears in the Directions themselves.
1800-11-6969 (toll free fax)The fax channel named in direction (ii). Still named, still listed, and occasionally still the only channel that works from inside a contained network.
info@cert-in.org.in · advisory@cert-in.org.inThe information desk: security alerts and technical questions or feedback on cyber security. Not for incident reporting — but note that info@cert-in.org.in is also the address Annexure II of the 2022 Directions names for filing your point-of-contact information. Two different jobs, one mailbox.
subscribe@cert-in.org.inSubscribing to CERT-In alerts and advisories. Worth doing before you need them, and worth pointing at a monitored distribution list rather than an individual.
vdisclose@cert-in.org.inVulnerability reporting and responsible disclosure. CERT-In is a CVE Numbering Authority for vulnerabilities affecting products designed, developed and manufactured in India.
empanelment@cert-in.org.inEmpanelment matters, and the auditee feedback form. Section 11(iii) of the 2025 guidelines describes providing feedback on a completed audit as both a right and a duty of the auditee, says all feedback and complaints are kept confidential and acted on promptly, and directs you here for the form.

“I received an email claiming to be CERT-In.” How to check

This question is going to get more common, not less, now that AMBAK is being invoked in vendor pitches and a CERT-In letterhead carries weight in a procurement conversation. CERT-In gives you more to check against than most agencies do. Four checks, and three negatives.

Check the address it came from.

CERT-In corresponds from the addresses in the table above and its RFC 2350 lists them: incident@, info@, advisory@, subscribe@, vdisclose@ and empanelment@cert-in.org.in. A lookalike domain, a free mailbox or a consultant forwarding “on CERT-In’s behalf” is not CERT-In.

Check the signature, and fetch the keys in peacetime.

CERT-In publishes PGP keys for its incident, information and vulnerability-disclosure addresses, and uses PGP key signing to authenticate communication from the incident response help desk to its stakeholders. Fetch and pin those keys now. Authenticating a message that arrives mid-incident, from a team you have never corresponded with, is not a problem to solve at three in the morning.

Check where it arrived.

An order for information under section 70B(6) arrives at the point of contact you filed under Annexure II — direction (iii) says all communications from CERT-In seeking information and providing directions for compliance go there. Something that reaches your billing address, your sales inbox or an individual’s personal email deserves scrutiny before it deserves a reply.

Check who is asking, if it is a demand for logs.

CERT-In’s FAQ at Q38 says the requisition for logs may be given by an officer of CERT-In not below the rank of Deputy Secretary to the Government of India. A log demand that names no officer and no rank is worth a call to the help desk on the published number before anything leaves your estate.

And the negatives, which do most of the work. CERT-In issues no certificate to an auditee — an email offering you one is not from CERT-In. CERT-In charges no fee for a compliance status, because there is no status to charge for. The empanelment terms even instruct auditors to ensure CERT-In is not made or projected to be a part of any contract. And as at 18 September 2026, CERT-In has published no portal for auditees to register on — including under AMBAK, which neither official account of its launch describes as a registration or verification service. If a message asks you to register, pay or claim a certificate, those three sentences settle it. On certificates specifically, see how to verify a CERT-In audit certificate and CERT-In AMBAK.

The CERT-In documents that bind you

The instruments, and who each one binds

CERT-In publishes a great deal. Ten documents carry most of the operational weight, and between them they answer nearly every question an Indian organisation has about what is expected of it. The third column is the one to read first: these instruments bind different people, and a document that binds your auditor is not a document that binds you.

InstrumentDateWho it bindsWhat it does
Information Technology Act, 2000 — section 70BAgency appointed by notification dated 27 October 2009Everyone within the Act’s reachCreates CERT-In, lists its six functions, empowers it to call for information and issue directions, and attaches punitive consequences to non-compliance.
IT (CERT-In and Manner of performing functions and duties) Rules, 2013Notified 16 January 2014 · made under s.87(2)(zf) read with s.70B(5)CERT-In, and through it the entities it deals withPrescribes how CERT-In performs its functions. CERT-In quotes the operative provision in its own 2025 guidelines: “The provision of rule no.9 of these Rules, 2013, inter-alia, prescribes the activity of Information security assurance and audit to CERT-In.” That is the basis of the empanelment scheme.
Directions under sub-section (6) of section 70B28 April 2022 · No. 20(3)/2022-CERT-In · effective 60 days after issueService providers, intermediaries, data centres, body corporate and Government organisationsBinding obligations: NTP synchronisation, six-hour incident reporting, a designated point of contact, 180-day log retention within Indian jurisdiction, five-year subscriber records for data centre, VPS, cloud and VPN providers, and five-year KYC and transaction records for virtual asset service providers. Read with the extension order below: the general effective date is not the only one.
Extension order — timelines for MSMEs and for the validation limb of direction (v)27 June 2022 · No. 20(3)/2022-CERT-InMSMEs, and data centre, VPS, cloud and VPN service providersThe instrument almost every summary of the 2022 Directions drops. It provides that the Directions “will become effective on 25th September, 2022” for Micro, Small & Medium Enterprises classified under MSME notification S.O. 1702(E) of 1 June 2020, and that the requirement to register and maintain “Validated names of subscribers/customers hiring the services” and “Validated address and contact numbers” at paragraph (v)(a) and (v)(f), to that limited extent, also became effective on 25 September 2022 — for all four provider classes. So there are three effective dates, not one. It is linked from CERT-In’s own Directions landing page alongside the Directions themselves.
Guidelines for CERT-In Empanelled Information Security Auditing OrganizationsVersion 3.0, May 2018Empanelled auditing organisationsConduct rules for auditors: background checks, manpower declared to CERT-In, methodology expectations, testing restrictions, data handling inside India, and the branding restriction that limits what an auditor may say about its relationship with CERT-In.
Comprehensive Cyber Security Audit Policy GuidelinesVersion 1.0, 25 July 2025Empanelled auditing organisations and auditee entitiesThe current operating manual for audits in India. Twenty sections covering definitions, scope of engagements, audit principles, applicable standards, auditee and auditor responsibilities, auditor selection, planning, engagement terms, performance, reporting, evidence, and the graded consequences for an auditing organisation that falls short.
Cyber Security Audit Baseline RequirementsPublication NSCS-46-16 Rev 1.0 · October 2020 · National Security Council Secretariat · hosted on cert-in.org.inAuditees and auditing organisations, as the basis of an audit programmeIts own abstract describes it as the minimum security assurance baseline expected across the cyber information infrastructure of organisations, forming the criterion for the conduct of cyber security audits. Section 8(iii) of the 2025 policy guidelines says it should be used by auditees and auditing organisations to build their audit programme — in place of a vulnerability top-ten list. Note the issuer: this one is an NSCS document that CERT-In hosts and adopts, not a CERT-In publication.
Guidelines for Secure Application Design, Development, Implementation & OperationsIssued by CERT-In · published on cert-in.org.inApplication owners and developers, through procurementThe secure development expectations an application is measured against before it is accepted for audit at all. Section 8(viii) is explicit: an application developed without secure design and development practices should not be considered for assessment and audit, and the auditee is to be told so in writing with a copy marked to CERT-In.
Policy Guidelines for Handling Audit related DataVersion 1.0, June 2014Auditing organisationsHow working notes, evidence and reports are to be stored, transmitted, retained and destroyed. The 2025 policy guidelines pull it in through the definition of Working Notes at section 5(iv), which requires the auditing organisation to adhere to it.
Technical Guidelines on SBOM, QBOM & CBOM, AIBOM and HBOMVersion 2.0, dated 9 July 2025 · issued by CERT-InSoftware producers and consumers, and auditors scoping a bill-of-materials auditCERT-In publishes technical guidelines on the bill-of-materials family at version 2.0, covering SBOM, QBOM, CBOM, AIBOM and HBOM. The audit policy guidelines name the BOM types at scope item (xxvi) without citing this document, so the two are read together rather than one citing the other. It is the document to reach for before an RFP asks for an SBOM.

Two of these deserve a note. The Comprehensive Cyber Security Audit Policy Guidelines, version 1.0 dated 25 July 2025, are the most significant change to the Indian audit landscape in years: a twenty-section document that sets out, in one place, what an audit is, what it must cover, who may perform it, how it is planned, how it is reported, and what happens to an auditing organisation that falls short. It states in its own authority section that it is binding on all CERT-In empanelled auditing organisations and on auditee entities covered under the relevant provisions. And the Guidelines for CERT-In Empanelled Information Security Auditing Organizations, version 3.0 of May 2018 remain the source of the conduct rules that govern how an auditor behaves on your systems — and of the branding restriction that limits what any auditor may claim about its relationship with CERT-In. Both are read in detail in the rules of engagement for an empanelled auditor.

The CERT-In Directions of 28 April 2022

The Directions of 28 April 2022

Reference No. 20(3)/2022-CERT-In, issued by CERT-In at Electronics Niketan, 6 CGO Complex, New Delhi, under sub-section (6) of section 70B, and expressed to become effective sixty days after the date of issue. The subject line is worth quoting because it is the phrase the Directions are indexed under: directions relating to information security practices, procedure, prevention, response and reporting of cyber incidents for Safe & Trusted Internet. Six directions, applying to service providers, intermediaries, data centres, body corporate and Government organisations.

One thing to fix before reading any summary of these directions, including the ones that circulate in tender documents. There are three effective dates, not one. A separate order of 27 June 2022, carrying the same file number and linked from CERT-In’s own Directions page, provides that the Directions “will become effective on 25th September, 2022” for Micro, Small & Medium Enterprises classified under MSME notification S.O. 1702(E) of 1 June 2020, and that the requirement to register and maintain Validated names of subscribers/customers hiring the services and Validated address and contact numbers at paragraph (v)(a) and (v)(f), “to the said limited extent”, also became effective on 25 September 2022 — for data centres, VPS providers, cloud service providers and VPN service providers alike. All three dates are long past, so nothing turns on them prospectively. What turns on them is credibility: a summary that gives you one date has not read the instrument set, and it is reasonable to wonder what else it missed.

(i)

Synchronise your clocks to NIC or NPL

All ICT system clocks must be synchronised to the NTP server of the National Informatics Centre or the National Physical Laboratory, or to NTP servers traceable to these. An entity spanning multiple geographies may use another accurate standard time source, but its time source shall not deviate from NPL and NIC.

Without a common clock, a six-hour reporting window and a 180-day log archive cannot be reconciled across parties. This is the direction that makes the others legible.

(ii)

Report cyber incidents within six hours

Incidents of the types listed in Annexure I must mandatorily be reported to CERT-In within six hours of noticing them or of being brought to notice about them. Channels: incident@cert-in.org.in, phone 1800-11-4949, fax 1800-11-6969.

The clock runs from noticing, not from confirming, and not from finishing the investigation. A first report that says what is known and what is not is compliant. A complete report filed on day three is not.

(iii)

Designate a point of contact and keep it current

A point of contact in the format at Annexure II must be designated, communicated to CERT-In and kept updated. CERT-In may order information up to and including near real-time, and failure to furnish it is treated as non-compliance.

A stale point of contact is the most common silent failure in the entire directions set. The person named left, the mailbox is unmonitored, and the first anyone notices is when an order arrives and nobody sees it.

(iv)

Keep 180 days of logs, inside India

Logs of all ICT systems must be mandatorily enabled and maintained securely for a rolling period of 180 days, and maintained within Indian jurisdiction.

Two obligations, not one. The retention period is the part everybody reads, but the jurisdiction requirement is the part that breaks architectures which ship logs to an overseas observability platform by default.

(v)

Data centre, VPS, cloud and VPN providers: five years of subscriber records

Registered and maintained for five years or longer as mandated by law, and retained after any cancellation or withdrawal of registration: validated subscriber names, period of hire including dates, IP addresses allotted to or being used by members, email address, IP address and time stamp used at the time of onboarding, purpose for hiring the services, validated address and contact numbers, and ownership pattern of the subscriber.

Seven specific fields. The word that does the work is “validated” — a self-asserted name and address collected at signup and never checked does not satisfy it. Note the timing, because summaries drop it: the extension order of 27 June 2022 gave the validation limb specifically — “Validated names of subscribers/customers hiring the services” at (v)(a) and “Validated address and contact numbers” at (v)(f) — a later effective date of 25 September 2022, for all four provider classes. The rest of direction (v) ran from the general date.

(vi)

Virtual asset providers: five years of KYC and transaction records

Virtual asset service providers, virtual asset exchange providers and custodian wallet providers must maintain all KYC information and records of financial transactions for five years. KYC follows the RBI Directions of 2016, the SEBI circular dated 24 April 2020 and the Department of Telecommunications notice dated 21 September 2021, as set out at Annexure III. Transaction records must be maintained so that an individual transaction can be reconstructed.

Reconstruction is the standard, not retention. Holding five years of rows is not enough if the counterparties, addresses and IP records cannot be reassembled into a single transaction narrative.

The consequence clause is one sentence, and it is the reason these are not optional: non-compliance may invite punitive action under sub-section (7) of the section 70B of the IT Act, 2000 and other laws as applicable. The 2025 audit policy guidelines then close the loop from the other side: an auditing organisation must include verification of compliance with these Directions in every audit assignment, with the findings and supporting evidence carried into the audit report. If you are audited in India, your compliance with the 2022 Directions is being tested whether or not you asked for it to be in scope. The Directions are unpacked in full in the 2022 Directions explained.

Direction (iv), in detail

Do logs have to stay in India? Two obligations, not one

This is the direction most likely to require an architecture change, so it is worth separating its two limbs before deciding anything. The text is one sentence: covered entities shall mandatorily enable logs of all their ICT systems and maintain them securely for a rolling period of 180 days and the same shall be maintained within the Indian jurisdiction. The direction then adds a third clause that is frequently dropped in summaries: these should be provided to CERT-In along with reporting of any incident or when ordered / directed by CERT-In.

Limb one: retention. A rolling 180 days, for all ICT systems.

“All their ICT systems” is the demanding half, not the 180 days. CERT-In’s FAQ at Q37 gives an indicative list of what it has in mind — firewall logs, intrusion prevention system logs, SIEM logs, web, database, mail, FTP and proxy server logs, event logs of critical systems, application logs, ATM switch logs, SSH logs, VPN logs — and says explicitly that the list is not exhaustive but is meant to give a flavour of what should be maintained. It adds the requirement most log pipelines get wrong: “From the incident response and analysis perspective both successful as well as unsuccessful events shall be recorded.” A pipeline tuned to drop failed authentication noise is a pipeline missing the events an investigation needs.

Limb two: residency. And CERT-In’s own gloss on it.

The direction says logs shall be maintained within the Indian jurisdiction. CERT-In’s FAQ then answers the obvious follow-up at Q35 — “Is it required to store copy of logs in India only?” — with: The logs may be stored outside India also as long as the obligation to produce logs to CERT-In is adhered to by the entities in a reasonable time. Q36 then narrows it back: any service provider offering services to users in the country needs to enable and maintain logs and records of financial transactions in Indian jurisdiction.

Read together, the defensible reading is: an India-resident copy, plus a demonstrated ability to produce logs quickly. Q38 names who can ask — the requisition for logs may be given by an officer of CERT-In not below the rank of Deputy Secretary to the Government of India — which tells you the request will be formal and will not wait. CERT-In has not published a numeric definition of “reasonable time”, and this page will not invent one.

Three architectures, and a verdict on each

India-resident primary log store, offshore analytics replica

Retention

Satisfied, if the India-resident store itself holds the full rolling 180 days rather than a hot window backed by an offshore archive.

Residency

The strongest position available. The logs are maintained in Indian jurisdiction, and the replica is an additional copy, not the record.

Verdict

This is the architecture that survives the question without argument, and it is usually cheaper than it sounds because the India-resident tier can be object storage rather than a search index.

Offshore SIEM as the system of record, India-resident archive alongside

Retention

Satisfied, provided the archive covers the full 180 days for every in-scope system.

Residency

Defensible on CERT-In’s own FAQ answer at Q35 — logs may be stored outside India as long as the obligation to produce them to CERT-In in a reasonable time is met — read together with the direction’s requirement that they be maintained within Indian jurisdiction. The India-resident copy is what makes both readings work.

Verdict

Workable, and common. The thing that breaks it is scope drift: the archive gets configured once, new services ship, and coverage quietly stops matching the asset inventory.

Fully offshore, no India-resident copy at all

Retention

May be satisfied. Retention and residency are separate limbs.

Residency

Not satisfied on the face of direction (iv), which says logs “shall be maintained within the Indian jurisdiction”. FAQ Q35 softens the storage question but not the production duty, and FAQ Q36 states that any service provider offering services to users in the country needs to enable and maintain logs and records of financial transactions in Indian jurisdiction.

Verdict

The position to fix rather than to argue. If it is genuinely the only option, the compensating work is a demonstrated, timed production path — and a written record of the reasoning, so the audit conversation starts from your analysis rather than from a shrug.

Two questions the Directions do not answer, stated as open rather than resolved. Whether the 180 days runs per system or across the estate is not addressed. The text says “logs of all their ICT systems” and a rolling period, which reads naturally as per-system coverage for the full period. And nothing says what happens to logs older than 180 days — the direction sets a floor, not a ceiling, and your own retention schedule and data-protection obligations govern the rest. Where CERT-In has not published a position, say so in your own documentation rather than adopting a vendor’s.

How compliance with the CERT-In Directions is tested

How compliance with each direction is actually tested

Because section 15.2.1(iv) puts verification of the 2022 Directions into every empanelled audit assignment, you will be tested on this whether or not you asked for it to be in scope. That clause also names a procedure document — Method of verifications to compliance with CERT-In Directions issued on 28.04.2022 — and gives a URL for it on cert-in.org.in. As at 18 September 2026 that URL does not serve the document. It returns a short page reading “The requested URL is not found.” So this page states what section 15.2.1(iv) supports, which is that the verification must happen and that a method document is named, and nothing about what is inside it. All three columns below are ours: how each direction is tested in practice, and what we have seen accepted and rejected. Treat it as experience, not as a transcription of CERT-In’s procedure.

DirectionHow it is testedWhat is acceptedWhat is rejected
(i) NTP synchronisationEstablish that every device class in the estate resolves to an NTP source that is NIC, NPL, or demonstrably traceable to one of them — and that the clocks actually agree. The obligation is written against “all their ICT systems clocks”, so the test is coverage against the asset inventory, not the configuration of a representative host. Where an entity spans geographies and uses another standard source, show that the source does not deviate from NPL and NIC.Configuration exports across every device class in the estate, plus log evidence of actual synchronisation events and of drift within tolerance. The NIC servers are samay1.nic.in and samay2.nic.in, and the NPL server is time.nplindia.org.A screenshot of one server’s NTP config. It shows intent on one host and says nothing about the estate, which is what “all their ICT systems clocks” means.
(ii) Six-hour incident reportingReconcile the incident register for the period against what was actually filed, line by line, and check that the incident policy envisages reporting to CERT-In at all. Expect the arithmetic — detection timestamp to filing timestamp — to be computed on every Annexure I-classified entry rather than sampled. Note that section 15.2.2(i) of the audit policy guidelines gives the auditor an independent duty to report high-risk vulnerabilities such as discovered breaches to CERT-In as well as to you.The internal incident register for the period, reconciled line by line against what was actually filed, with noticing timestamps drawn from the alert, the ticket or the customer email rather than from the post-incident write-up.A policy that says the right thing with no register behind it. This is the row where the auditor has a duty that runs to CERT-In independent of your own filing, so an unreconciled register is a poor thing to hand over.
(iii) Point of contactAsk for the Annexure II filing and its date, and then ask the harder question the direction actually sets: is it current. Direction (iii) requires the information to be designated, communicated and “updated from time to time”, so a filing made once and never revisited is the failure mode, not the absence of a filing.The dated Annexure II filing sent to info@cert-in.org.in, plus evidence that the named mailbox is monitored — a rota, an alerting rule, a test message with a response time. The filing alone proves you did it once.A name in a compliance tracker. The person who filed it may have left, but the direction requires the information to be “updated from time to time”.
(iv) 180 days of logs, within Indian jurisdictionTwo tests, because the direction has two limbs. For retention: confirm logging is enabled across the estate and that the retention configuration genuinely holds a rolling 180 days, then retrieve a record from the far end of that window rather than reading the policy. For residency: establish where the record actually lives, and what the production path to CERT-In looks like when one is ordered.A system-generated retention configuration, a retrieval of a genuinely 180-day-old record performed live, storage-region evidence, and coverage reconciled against the asset inventory. Direction (iv) also requires logs to be provided to CERT-In with any incident report or when ordered.A retention policy document, and a SIEM whose coverage was never reconciled to the asset inventory. Logs enabled on the systems somebody remembered is the most common version of this failure.
(v) Five years of subscriber recordsWhere the auditee is a data centre, VPS, cloud service or VPN service provider: take the seven fields one at a time and ask, for each, what validates it and where the five-year clock is enforced. The onboarding terms and the registration forms are the documents to read, because that is where the collection obligation either exists or does not. The retention schedule is where the “after any cancellation or withdrawal of the registration” limb either survives or gets deleted with the account.Evidence that the fields were validated, not merely captured: the verification step in the onboarding flow, and its output retained against the record.A signup table with a name column. “Validated names” and “validated address and contact numbers” are the direction’s own words, and a self-asserted value never checked does not meet them.
(vi) Five years of KYC and transaction recordsWhere the auditee is a virtual asset service provider, exchange or custodian wallet provider: confirm the five-year retention of KYC information and of financial transaction records, then test the standard the direction actually sets, which is reconstruction. Ask which of the three KYC regimes at Annexure III the process was built against, and have one historic transaction reassembled end to end.A reconstruction, performed in front of the auditor, of one historic transaction from the stored elements: parties, IP addresses with timestamps and time zones, transaction ID, public keys or equivalent identifiers, addresses or accounts, nature and date, amount.Five years of rows in six systems that nobody has ever joined. Reconstruction is the standard the direction sets. Retention is only the precondition.

One observation about direction (iii) that is worth carrying into your own preparation. The point of contact is the cheapest of the six obligations to satisfy and the one whose failure costs most during a live incident, and it is also the one that produces the least evidence: a filing is a sent email, and a sent email from three years ago proves only that somebody once did it. If you want it tested properly, put the artefacts in front of the auditor yourself — the filing, its date, the re-filing trigger, and a recent test message with a recorded response time.

Who the CERT-In Directions name

The classes of entity the Directions name

This table does one job: it sets out the statutory classes, in the words the instruments use, and says which directions attach to each. The next section takes the same question from the other end — not “what class am I” but “here is my situation, does this reach me”. Read this one to place yourself, and read that one to decide what you owe.

ClassWhere the instrument names itWhich directions attach
Service providersNamed in the opening paragraph of the Directions as an addressee, and again in section 70B(6) of the Act as one of the classes CERT-In may call for information from and give directions to.Directions (i) to (iv).
IntermediariesNamed in the opening paragraph of the Directions, and in section 70B(6). “Intermediary” carries the definition in section 2(1)(w) of the IT Act.Directions (i) to (iv).
Data centresNamed in the opening paragraph of the Directions and in section 70B(6), and named again inside direction (v) alongside VPS, cloud and VPN providers.Directions (i) to (iv), plus direction (v).
Body corporateNamed in the opening paragraph of the Directions and in section 70B(6). The Act defines it at the Explanation to section 43A as “any company”, including “a firm, sole proprietorship or other association of individuals engaged in commercial or professional activities”.Directions (i) to (iv).
Government organisationsNamed in the opening paragraph of the Directions as an addressee.Directions (i) to (iv) — independently of the separate pre-production audit regime for government websites and applications.
Virtual Private Server (VPS) providers, Cloud Service providers and VPN Service providersNamed inside direction (v), which addresses “Data Centres, Virtual Private Server (VPS) providers, Cloud Service providers and Virtual Private Network Service (VPN Service) providers”. CERT-In’s FAQ at Q7 adds all three to the addressee list.Directions (i) to (iv), plus direction (v).
Virtual asset service providers, virtual asset exchange providers and custodian wallet providersNamed inside direction (vi), in those three terms, and added to the addressee list at FAQ Q7.Directions (i) to (iv), plus direction (vi).
Individual citizensNamed only to be excluded. FAQ Q7 ends: “Individual citizens are not covered by these Directions.”Nothing.

The narrower obligations in directions (v) and (vi) are additive, not alternative — a cloud service provider that also operates a custodian wallet is subject to both. And the classes overlap by design: an MSP is a service provider and its customer is a body corporate, and both are inside the perimeter for the same incident. CERT-In’s own FAQ at Q7 gives the consolidated addressee list — service providers, intermediaries, data centres, body corporate, Virtual Private Server providers, Cloud service providers, VPN Service providers, virtual asset service providers, virtual asset exchange providers, custodian wallet providers and Government organisations — and ends with the line nobody quotes: “Individual citizens are not covered by these Directions.”

Do the CERT-In Directions apply to my company

Do the CERT-In Directions apply to my company?

The table above names statutory categories. This one names situations, because that is how the question actually arrives. Every row is settled by a specific sentence in the Directions themselves or in CERT-In’s own FAQs on the Cyber Security Directions of 28.04.2022, published in May 2022 — a document that is far less read than it deserves, because it answers most of the hard cases directly and in CERT-In’s own words.

The situationWhich directions biteWhat you owe firstThe sentence that settles it
Indian SaaS company, no government customers, ten peopleDirections (i), (ii), (iii) and (iv) — clock synchronisation, six-hour reporting, a designated point of contact, 180 days of logs.File the Annexure II point of contact. It is the one obligation you can discharge this afternoon, and it is the one CERT-In uses to reach you.The Directions name “body corporate”, and the Explanation to section 43A of the IT Act defines that as “any company”, including “a firm, sole proprietorship or other association of individuals engaged in commercial or professional activities”. Size is not a threshold for applicability — the extension order of 27 June 2022 gave MSMEs a later effective date of 25 September 2022, not an exemption.
Indian company whose entire estate runs in a foreign cloud regionThe same four, with direction (iv) the one that may require an architecture change.Establish where 180 days of logs live and how fast you can produce them to CERT-In on demand.Direction (iv) says logs “shall be maintained within the Indian jurisdiction”. CERT-In’s own FAQ of May 2022 then answers the question directly at Q35: “The logs may be stored outside India also as long as the obligation to produce logs to CERT-In is adhered to by the entities in a reasonable time.” Read the two together before you move a petabyte.
Foreign company with no Indian entity, serving Indian usersReporting, certainly. FAQ Q26 says the Directions “are applicable to any entity whatsoever, in the matter of cyber incidents and cyber security incidents”.A point of contact. FAQ Q29 is explicit that service providers, intermediaries, data centres and body corporate offering services to users in the country shall designate a Point of Contact to liaise with CERT-In, whether or not they have a physical presence in India.Section 75 of the IT Act applies the Act to an offence or contravention committed outside India by any person irrespective of nationality, where the act involves a computer, computer system or computer network located in India.
Indian subsidiary of a foreign parent, incident detected by the parent’s SOCAll four general directions, on the Indian entity.A reporting decision inside six hours of the parent noticing — not six hours after the Indian team is told.FAQ Q13: “Any entity which notices the cyber security incident, shall report to CERT-In. The obligation of reporting of cyber incident is neither transferrable nor indemnified or dispense with.” A group escalation path that routes through a foreign parent first is how the window is lost.
MSP or systems integrator operating a customer’s systemsAll four, on the MSP as a service provider — and separately on the customer as a body corporate.Agree, in writing, who files. Then file anyway if you are the one who noticed.FAQ Q13 again, on the outsourcing case specifically: the obligation is not transferable, not indemnified, and cannot be contracted away. Two parties may both owe a report on the same incident. Neither is discharged by the other.
Data centre, VPS, cloud service or VPN service providerThe four general directions plus direction (v): seven fields of validated subscriber records, held five years, surviving cancellation of the registration.Check whether the seven fields are validated rather than merely collected, and whether your deletion-on-termination logic would destroy them.Direction (v) lists the seven fields and requires them “for a period of 5 years or longer duration as mandated by the law after any cancellation or withdrawal of the registration”. On timing: the extension order of 27 June 2022 provided that the validation limb specifically — “Validated names of subscribers/customers hiring the services” at (v)(a) and “Validated address and contact numbers” at (v)(f) — became effective on 25 September 2022 for all four provider classes.
Enterprise VPN — the corporate remote-access kindThe four general directions. Direction (v) does not reach it.Nothing under direction (v). Stop treating it as a blocker.FAQ Q34 asks whether direction (v) applies to enterprise or corporate VPNs and answers: “No. For the purpose of this direction, VPN Service provider refer to an entity that provide ‘Internet proxy like services’ through the use of VPN technologies, standard or proprietary, to general Internet subscribers/users.”
Consumer VPN provider whose product promise is that it keeps no logsDirection (v), squarely, for the Indian market.A commercial decision, taken openly. There is no reading of direction (v) under which a general-internet VPN service serving Indian subscribers keeps none of the seven fields.Direction (v) names Virtual Private Network Service providers alongside data centres, VPS and cloud providers. FAQ Q34 confirms that the term is aimed at exactly this kind of service. The conflict is real, and several providers resolved it by withdrawing Indian infrastructure, which is a choice rather than a compliance position.
Virtual asset service provider, exchange or custodian wallet provider, wherever locatedThe four general directions plus direction (vi): five years of KYC and transaction records, reconstructable at the level of the individual transaction.Confirm which KYC standard your process was built against — RBI Directions 2016, the SEBI circular of 24 April 2020 or the DoT notice of 21 September 2021, as set out at Annexure III.FAQ Q27 addresses providers “not located in India but catering to Indian users” and answers that the Directions are applicable to any entity in the matter of cyber incidents and cyber security incidents.
Government department or public sector organisationThe four general directions, on top of the separate pre-production audit regime that governs government websites and applications.Both. They are independent obligations, and holding a valid audit clearance certificate does not excuse an unreported incident.The Directions name Government organisations among their addressees. GIGW 3.0 statement 5.3.1 separately requires an audit clearance certificate from NIC, STQC, an STQC empanelled laboratory or a CERT-In empanelled laboratory before hosting in the production environment.
An individual — a freelancer, a hobby project, a personal blogNothing.Nothing under these Directions.FAQ Q7, last line: “Individual citizens are not covered by these Directions.” If you are operating commercially or professionally, however, section 43A’s definition of body corporate reaches a sole proprietorship.

Two things run through the whole table and are worth stating on their own. The reporting obligation cannot be moved by contract. FAQ Q13 deals with the case where a consumer-facing business and its outsourcing partner are both affected, and answers that any entity which notices the incident shall report it, and that the obligation “is neither transferrable nor indemnified or dispense with”. And a confidentiality clause does not override it either — FAQ Q22 says the obligation is statutory in nature and overrides any confidentiality clause in any contract, by virtue of section 81 of the IT Act, under which the Act has effect notwithstanding anything inconsistent contained in any other law for the time being in force.

Common CERT-In compliance objections, answered

Six sentences you will hear, and the answer to each

Everything above is the position. These are the conversations in which the position gets tested — by a vendor, a customer, a parent company, or your own engineering lead at eleven at night. Each answer below is sourced from the same instruments the rest of the page uses, arranged so you can use it in the room rather than look it up afterwards.

“Our auditor says they’re CERT-In certified — the tender asks for that, so we’re covered.”

Two different problems, and both are yours. First, there is no such status: CERT-In certifies nobody, and the only sentence an empanelled organisation may use about itself is “This Organization is empanelled by CERT-In for providing information Security Auditing Service.” No other words may be used without CERT-In’s prior written permission. A firm that writes “certified” or “approved” about its own status has decided that a rule about itself is optional, which is a fair thing to weigh when what you are buying is its judgement about rules. Second, and more practically: go and read the published list on cert-in.org.in rather than a PDF or a letter forwarded to you. Empanelment runs for a period, and it can be suspended or withdrawn during that period under the graded framework at section 19 — a suspension does not come with a press release. While you are in the snapshot information, check that the individuals proposed for your engagement appear in the declared manpower, because section 9.5(iii) says the report may be signed only by manpower declared to CERT-In in that snapshot.

“Our customer’s NDA says we can’t disclose the incident.”

It does not reach this. CERT-In answers the point directly in its FAQ of May 2022 at Q22: the reporting obligation is statutory in nature and overrides any confidentiality clause in any contract, by virtue of section 81 of the IT Act, under which the Act has effect notwithstanding anything inconsistent contained in any other law for the time being in force. The useful conversation with your legal team is not whether to file. It is what goes in the filing. A report that states the incident class, the detection timestamp, the affected system and what is known and not known does not require you to publish your customer’s name to the world — it requires you to tell a technical agency what happened, on a channel that is not public.

“We notified the Data Protection Board. Isn’t that the same filing?”

No, and treating it as one is how organisations end up having made neither filing properly. Section 8(6) of the Digital Personal Data Protection Act, 2023 provides that in the event of a personal data breach the Data Fiduciary shall give the Board and each affected Data Principal intimation of the breach, in such form and manner as may be prescribed. The CERT-In duty is direction (ii) of the 2022 Directions: an Annexure I incident, reported within six hours of noticing, at any severity, whether or not personal data was involved at all. Different statute, different body, different trigger, different clock — and the DPDP duty additionally runs to every affected individual, which the CERT-In one does not. A ransomware event touching no personal data is a CERT-In incident and not a personal data breach, while a misconfigured store exposing customer records is both. Ask the two questions at the same moment, as independent checks.

“Our parent’s SOC saw it first and they’re handling it.”

Then the clock has already been running for however long they have been handling it. FAQ Q13 is unambiguous: “Any entity which notices the cyber security incident, shall report to CERT-In. The obligation of reporting of cyber incident is neither transferrable nor indemnified or dispense with.” The six hours run from noticing, and a group escalation path that routes through a foreign parent before the Indian entity is told is the single most common way a compliant organisation misses the window. The fix is structural rather than legal: the Indian entity needs to be on the detection path, not on the notification path. Where the affected data sits in someone else’s systems, Q31 adds that the Directions apply to all entities so far as reporting a cyber incident is concerned.

“It was a P3. No customer impact, no data loss — we closed it.”

Your severity scale is not the test, and nothing in Annexure I refers to one. An incident either falls within one of the twenty classes or it does not. Unauthorised access of IT systems or data is item (iii) whatever the impact assessment concluded. Targeted scanning or probing of critical networks and systems is item (i) — reportable before anything has gone wrong at all. The practical fix is one form field: put the twenty Annexure I classes into your triage form as a mandatory question, parallel to severity and independent of it. CERT-In’s own reporting form makes you tick a class before you can file, so make your own tooling ask first.

“We’re ten people. This is for telcos and data centres.”

The Directions name “body corporate”, and the Explanation to section 43A of the IT Act defines that as “any company”, including “a firm, sole proprietorship or other association of individuals engaged in commercial or professional activities”. Size is not a threshold for applicability. It did affect timing, once: the extension order of 27 June 2022 gave MSMEs classified under MSME notification S.O. 1702(E) of 1 June 2020 an effective date of 25 September 2022 instead of the general 60-day date — a later start, not an exemption, and that date is long past. What a ten-person company owes is the same four general directions everyone else owes, and the cheapest of them is the one to do this afternoon.

What CERT-In is not

What CERT-In is not

Six claims circulate in the Indian market that do not survive contact with CERT-In’s own documents. Each of them costs somebody money: a procurement team buys the wrong thing, a vendor is believed when it should not be, or a department discovers at go-live that the certificate it holds was signed by a body with no standing to sign it.

Commonly claimed

“CERT-In certifies companies”

It does not. There is no CERT-In certificate issued to an auditee, no CERT-In accreditation of a business, and no register of CERT-In-certified companies. What exists is empanelment: a list of information security auditing organisations that CERT-In has assessed as competent to perform audits. The audit report and, where one applies, the audit clearance certificate are issued by the empanelled organisation on its own letterhead and under its own signatures — never by CERT-In.

Commonly claimed

“CERT-In audits your company”

Not in the ordinary case. The audit is performed by an empanelled auditing organisation you select and contract with. CERT-In’s involvement is a quality-assurance reservation, not a service. Section 11(i) of the 2025 policy guidelines — the section headed “Quality control of auditing organisations involved in Audit” — puts it in one sentence: CERT-In at any point in time can be a part of the audit team of the auditing organisation to assess the quality and maturity of audit, and the same should be communicated clearly in writing to the auditee by the auditing organisation. That is the only clause on the page that creates a written-notice duty about CERT-In’s presence, and it sits on the auditor, not on you. CERT-In also lists episodic security audits of key organisations among its security quality management services, which is a national-assurance activity rather than something you can commission.

Commonly claimed

“CERT-In is a party to the audit contract”

Expressly not. The 2025 policy guidelines instruct auditing organisations to “ensure that CERT-In is not made or projected to be a part of any contract between auditee and auditing organization”, and the 2018 auditor guidelines carry the same instruction. Your contract is a commercial contract with an audit firm. CERT-In receives audit metadata afterwards and can ask questions, but it is not a counterparty, it does not approve your scope, and it does not adjudicate a dispute about your invoice.

Commonly claimed

“An empanelled auditor can advertise its CERT-In relationship freely”

It cannot, and the restriction is unusually specific. An auditing organisation “shall not use the CERT-In logo, nor make any reference to the Auditors association with CERT-In on any publicity material, promotional material or product without the prior written permission of CERT-In”. It may use one sentence: “This Organization is empanelled by CERT-In for providing information Security Auditing Service.” No other words may be used to describe the relationship without prior written permission. If a vendor’s website says more than that sentence, it is either holding a written permission or it is out of line with the guidelines.

Commonly claimed

“Empanelment transfers to the audited company”

Empanelment attaches to the auditing organisation, for a period, and moves nowhere. Being audited by an empanelled organisation does not make the auditee empanelled, certified, approved or listed. The correct construction on a website or in a bid is factual: name the empanelled organisation that performed the audit and signed the report, and let the certificate carry the weight.

Commonly claimed

“CERT-In fixes your vulnerabilities”

The 2025 policy guidelines are blunt about where responsibility sits, from both ends. Section 9.1(ii), on the auditee: while cyber security audits identify vulnerabilities and assess risks, “the responsibility for maintaining an efficient and robust cyber security posture ultimately rests with the auditee organization, not the auditor”. Section 9.3(iii) adds that patching and correction of vulnerabilities is the responsibility of the auditee organisation. Section 10.1(i), on the auditor: the auditor is not responsible for managing or maintaining the organisation’s security measures directly or indirectly, and “their responsibility is limited to reviewing and reporting on the state of security at the point in time of the audit”. Two clauses, one boundary.

The cleanest way to hold all six in your head: CERT-In regulates the audit market. It does not participate in it. It decides who is competent to audit, publishes the rules those auditors must follow, collects the metadata afterwards, and penalises the ones who fall short. The audit itself is a commercial engagement between you and an empanelled organisation, and the signature on the report belongs to that organisation and its named people.

Who is responsible for what

CERT-In, auditee, auditor: who owns each step

The single most expensive assumption in this subject is that somebody else owns a step you own. Below is the split, activity by activity, with the clause in each cell. It is written to be lifted into a RACI or a board paper — and the column that surprises people is the first one, which is empty far more often than they expect.

ActivityCERT-InAuditee — youAuditing organisation
Notice and report the incident to CERT-In within six hoursReceives it, 24x7, at incident@cert-in.org.in, 1800-11-4949 or fax 1800-11-6969.Owns it entirely. Direction (ii) and FAQ Q13 — the obligation is “neither transferrable nor indemnified or dispense with”.Tests whether it happened. §15.2.1(iv) puts the verification in every assignment, and §15.2.2(i) adds a duty to report discovered breaches to CERT-In as well as to you.
Preserve 180 rolling days of logs, within Indian jurisdictionMay order them. FAQ Q38: the requisition may be made by an officer not below the rank of Deputy Secretary.Owns it. Direction (iv).Tests coverage against the asset inventory, retention and residency.
Designate and maintain the point of contactSends every order and communication to it. Direction (iii).Owns it. Files under Annexure II to info@cert-in.org.in, and re-files on any change.Asks for the filing and its date, and for evidence that the mailbox is monitored.
Set the audit scopeSets what scope must cover — §13.1.1 — but does not set yours.Owns it. §13.1.1: derived from the consolidated and updated asset inventory, vetted by internal audit in consultation with the CISO. §9.6(i): the process “must not be delegated”.Advises, and under §13.2.3(ii) advises you to state the date the inventory was updated to.
Perform the testingMay join the audit team to assess quality and maturity — §11(i) — and the auditor must tell you in writing when it does.Provides access, credentials and the environment. §15.1.2: temporary privileged credentials, revoked on completion.Owns it. §8(i): not solely tools-based. §15.2.2(ii): written permission before DoS, DDoS or flood testing.
Classify severityPrescribes the scheme, not the score.Reviews and challenges. A score you cannot explain is a finding you cannot close.Owns it. §16.2(ii): CVSS for severity, EPSS for real-world exploitation likelihood, and every observation mapped to a CWE and a CVE.
Patch the vulnerabilityNothing.Owns it. §9.3(iii): patching and correction is the auditee’s responsibility.§10.1(i): not responsible for managing or maintaining your security measures, directly or indirectly.
Accept residual riskNothing.Owns it, personally. §9.2(i): retain, avoid, transfer or reduce must be authorised and accepted by the head of the auditee organisation.Records the decision. It does not make it, and it does not absorb it.
Verify the fix, on productionNothing.§9.3(iv): must have the follow-up audit inside the scope or the RFP proposal.Owns the retest. §16.3(v): the final report issues after closure and completion of the follow-up audit on production.
Sign the report and the certificateSigns neither. There is no CERT-In signature on any audit deliverable.Signs neither. Being audited confers no status.Owns it. §9.5(iii): signed only by manpower declared to CERT-In and by the auditors who conducted it, then reviewed and signed by a designated reviewer outside the team, from mid-management, then authorised and signed by the head of the organisation. The certificate is signed by the lead auditor and the head.
File the report and metadata with CERT-In within five daysReceives it, in the format it prescribes.Neither files nor controls it. Empanelment T&C clause 3.1.7: provided without the auditee’s explicit permission. §13.2.1(iii): you must be told before the assignment starts.Owns it. §10.6 and clause 3.2.2.
Report critical vulnerabilities left unfixed after follow-upReceives them, with the auditee’s details.Controls only the input — close the finding and there is nothing to report.Owns the filing. Empanelment T&C clause 3.2.1 and 3.2.2.
Initiate prosecution for non-complianceOwns it exclusively. §70B(8): no court takes cognizance except on a complaint by an officer authorised by CERT-In.Nothing.Nothing. An adverse finding is not a prosecution and does not start one.

Read the last four rows together and the shape of the regime becomes clear. You own the decisions, the auditor owns the signatures and the filings, and CERT-In owns only the enforcement gate. Section 9.6(i) states the principle from your side in one sentence: the complete audit process must be undertaken by the auditee organisation itself, and “this responsibility must not be delegated”. External support may be engaged for specialised expertise, but full ownership and accountability for the security of the infrastructure stays with the owner.

CERT-In vs NCIIPC, STQC and NIC

CERT-In, NCIIPC, STQC and NIC: who does what

Two different confusions get labelled the same way. One is about audits: who may sign the certificate a government department needs. The other is about incidents: who else wants to know, and on what clock. The first is answered by four issuer classes, and the second is answered by a map. Most Indian incident commanders need the second one at three in the morning and discover that nobody has drawn it.

BodyStatutory basisWho it coversWhat you reportOn what clockWhat it is not
CERT-InSection 70B, Information Technology Act, 2000. Appointed by notification dated 27 October 2009Service providers, intermediaries, data centres, body corporate and Government organisations — plus VPS, cloud, VPN, virtual asset, exchange and custodian wallet providers for the narrower directionsThe twenty Annexure I incident types, at any severitySix hours from noticing, or from being brought to noticeNot a certification body, not your auditor, and not a party to your audit contract.
The national nodal agency for Critical Information Infrastructure ProtectionSection 70A, Information Technology Act, 2000 — the Central Government “may, by notification published in the Official Gazette, designate any organisation of the Government as the national nodal agency in respect of Critical Information Infrastructure Protection”, and sub-section (2) makes that agency “responsible for all measures including Research and Development relating to protection of Critical Information Infrastructure”. The agency operating in that role is commonly named in the market, but this page does not assert the designation because we were unable to read the designating gazette notification against an official source as at 18 September 2026. Take the current position from that agency.Critical information infrastructure, and the protected systems declared under section 70. CERT-In’s own RFC 2350 lists “the agency engaged for the protection of critical information infrastructure” among the stakeholders it interacts with.As that agency requires of the sectors and systems it coversPublished by that agency, not by CERT-InNot a substitute for CERT-In and not reached by a CERT-In filing. If you operate critical information infrastructure, you are answering to both, and neither instrument says the other discharges it.
Sectoral CERTs and sectoral regulatorsTheir own instruments. CERT-In’s RFC 2350 names sectoral computer emergency response teams first in its list of stakeholdersThe entities in their sectorAs their own circulars require — frequently on a shorter clock and a wider definition than CERT-In’sSector-specificNot derived from section 70B. The only verified connection between a sectoral regulator and CERT-In empanelment is section 12.1(i) of the 2025 guidelines: the snapshot information CERT-In publishes “should be utilized by the organizations or sectoral regulators to identify and select the auditing organizations”. Take the actual requirement from your regulator, not from a vendor summary.
The Data Protection Board of IndiaSection 8(6), Digital Personal Data Protection Act, 2023Data Fiduciaries, in respect of personal dataA personal data breach — “any unauthorised processing of personal data or accidental disclosure, acquisition, sharing, use, alteration, destruction or loss of access to personal data, that compromises the confidentiality, integrity or availability of personal data”. Intimation goes to the Board and to each affected Data Principal.In such form and manner as may be prescribed by rules made under the ActNot the same trigger and not the same audience. A CERT-In filing is an incident report to a technical agency, while a DPDP intimation is a notice to a regulator and to every affected individual. Neither discharges the other, and an incident can easily require both.
Law enforcementThe IT Act and the general criminal law, and section 78 confers the power to investigate offencesCyber crime, as crimeA complaint, if you are making oneNone imposed by section 70BNot an alternative to reporting. Note section 70B(8): no court takes cognizance of a section 70B offence except on a complaint by an officer authorised by CERT-In — so the enforcement path for non-reporting runs through CERT-In, not through a police complaint.
NIC and STQCGIGW 3.0 statement 5.3.1, and STQC is an attached office of MeitYGovernment websites, web applications, portals and mobile apps, at go-liveNothing. These are audit and certification bodies, not incident authoritiesNot applicableNot incident reporting channels, and not interchangeable with CERT-In empanelment. They are two of the four classes that may issue an audit clearance certificate under 5.3.1, and a CERT-In empanelled laboratory is a third.

A CERT-In filing does not discharge the DPDP duty, and a DPDP intimation does not discharge the CERT-In one. They come from different statutes, are owed to different bodies, and are triggered by different facts. A ransomware event that touched no personal data is a CERT-In incident and not a personal data breach. A misconfigured bucket that exposed customer records with no attacker involvement is plainly a personal data breach under the DPDP Act’s definition, and is also a data leak under Annexure I item (xii). Most serious incidents are both, and the six-hour clock is the one that runs first. Build the decision into your incident process as two independent questions asked at the same moment, not as one question with two answers.

One caution about this table, in the spirit of the rest of the page. What each sectoral regulator requires is published by that regulator, and the version circulating in vendor summaries is frequently out of date. The only statement this page will make about sectoral regulators and CERT-In empanelment is the one the guidelines actually make, at section 12.1(i): the snapshot information CERT-In publishes should be used by organisations or sectoral regulators to identify and select auditing organisations. Anything stronger than that — a named regulator mandating a CERT-In empanelled auditor — should be read in that regulator’s own circular before it goes into a bid.

CERT-In empanelment and the empanelled auditor list

Empanelment, in one page

CERT-In has created a panel of IT security auditing organisations for auditing — including vulnerability assessment and penetration testing — of computer systems, networks and applications of various organisations of the Government, critical infrastructure organisations and those in other sectors of the Indian economy. That wording is CERT-In’s own, from its RFC 2350. The durable rule for applicants is simple: new applications are accepted only in windows CERT-In advertises on its empanelment page, and a window closes absolutely rather than tapering.

Time-bound facts · as at 18 September 2026

Everything else on this page is durable. These are not, and they are stamped so that a reader — or a machine quoting this page — can see how old they are. Read from cert-in.org.in on 18 September 2026: new applications for empanelment will be accepted from 1st July 2026 till 5:30 PM of 30th September 2026. Applications received after 5:30 PM of 30th September 2026 will not be accepted by CERT-In under any circumstances. The empanelment page is the only authority for the current cycle. If you are reading this after that date, the window has changed and this block has not.

Step 1

Documentation Review Round

The application and its annexures are assessed on paper. This is where a thin declared bench or an undocumented methodology ends an application before anyone touches a keyboard.

Step 2

Offline Practical Skill Test (OFFPST)

A practical assessment of the organisation’s technical people rather than of its brochure. Empanelment is an assessment of demonstrated capability, which is why it cannot be bought the way a certification can.

Step 3

Vulnerability Assessment / Penetration Testing Practical Skill Test (VA/PT PST)

A hands-on VAPT test. The skills being tested are the skills the empanelment covers — which is why the CERT-In list is the reference an Indian buyer reaches for when the requirement is testing rather than paperwork.

Step 4

Personal Interaction Session at CERT-In

The final stage, conducted at CERT-In. These four are the steps the empanelment page publishes, each linked to its own document. Anything beyond them that a vendor describes should be traced to a CERT-In page or notice before it is believed.

Empanelment is not a one-time gate. CERT-In requires each empanelled organisation to keep its snapshot information and point-of-contact details current, to deploy only manpower declared to CERT-In on that snapshot, to obtain a no-objection certificate or relieving letter when hiring from another empanelled organisation and to update the snapshot accordingly, and to share the audit report and audit metadata for every audit with CERT-In within five days of completion, in the format CERT-In prescribes from time to time. Section 11(ii) also reserves CERT-In’s right to seek or audit information from an auditing organisation about any project done within the empanelment period, and section 11(i) lets it join an audit team as a quality-assurance measure — the clause set out in full further up this page. Clause 8.1 of the empanelment terms and conditions adds the blunt version: continued empanelment status depends on the quality of auditing services rendered.

How to check whether an auditor is still CERT-In empanelled

Not by asking for the letter. Empanelment runs for a period and can be suspended or withdrawn inside it under the graded framework below, and none of those events is announced to the market. Four steps, in order.

  • 01 Open the list of empanelled information security auditing organisations published by CERT-In on cert-in.org.in, today, and find the legal entity name that will appear on your contract — not the trading name, not the group.
  • 02 Open that organisation’s snapshot information and read what section 12.1(ii) says it is there for: manpower and skillsets, relevant experience, categories of audit conducted, audits carried out in the last twelve months by sector, category-wise counts, technical manpower deployed with details, and tools used. Match it against the audit you are actually buying.
  • 03 Check the individuals proposed for your engagement against the declared manpower in that snapshot. Section 9.5(iii) says the report may be signed only by manpower declared to CERT-In, so a name on your engagement that is absent from the declaration is a problem before the audit starts, not after.
  • 04 Re-check before the report is signed, not only at procurement. A status that lapses mid-engagement takes the signature you were buying with it, which is why the contract should say who tells you, within how many days, and what happens to the work product.

A PDF of the list forwarded by the vendor proves what was true on the day the vendor saved it. A letter proves what was true on the day it was written. Neither is the check.

Deter and punish

What happens to an auditor that falls short

Section 19 of the 2025 policy guidelines publishes a graded matrix of consequences, triggered by adverse reports, violation of the guidelines and the terms and conditions of empanelment, and poor quality of audits. The grades and the indicative parameters below are transcribed from that matrix. Auditee feedback to CERT-In is one of the inputs, and section 11(iv) says actions under the Deter and Punish framework may be taken without any reminder or notice.

GradeIndicative triggersAction
Watch list, with warning and written commitmentInadequate closure of Non Compliances (NCs) — the guidelines define non-conformity and non-compliance as one term at section 5(vi). Lack of relation between the noting and the issues raised. Inadequacy of sample details, issues covered, improper conclusions. Violating CERT-In terms and conditions having minor impact. A first adverse report including missing of a maximum of two vulnerabilities. Conflict with an auditee. A first instance of non-compliance with CERT-In’s data collection framework.CERT-In issues a show cause, obtains a corrective action report from the auditing organisation, and issues a warning with a written commitment.
SuspensionAdverse feedback from an auditee on technical competency or auditor attributes. Repeated failure in audit planning or audit coverage highlighted in CERT-In’s analysis. Issues appearing soon after the conduct of an audit. Major violations of the terms and conditions. Multiple adverse reports of missed vulnerabilities. Multiple instances of non-compliance with the data collection framework.Suspension, revoked only on satisfactory submission of corrective actions and, if needed, witnessing.
Withdrawal of empanelmentAuditing malpractices, substandard services, failure to cover the scope of work.Action under the General Financial Rules and Department of Expenditure O.M. No. F.1/20/2018-PPD dated 2 November 2021 — debarment and de-empanelment.
Penal and legal actionBreach of trust, digital break-in, damage or attempted damage to the auditee’s interests and infrastructure.As per applicable penal and legal acts and laws.

Read the first row again from the auditee’s side. “Inadequate sample details, issues covered, improper conclusions” and “lack of relation between noting and issues raised” are quality failures that you, holding the report, are in the best position to notice. The feedback mechanism exists because CERT-In cannot read every report, and the graded consequences only work if somebody says something.

Scope of engagements

What a CERT-In audit actually covers

“CERT-In audit” is usually said as though it meant one thing — a web application penetration test ending in a certificate. It does not. Section 6 of the 2025 policy guidelines lists twenty-six classes of audit and assessment that fall within scope, numbered (i) to (xxvi), and opens by saying they are included “but not limited to” — so the list is a floor rather than a ceiling. Auditee organisations, it continues, “are expected to ensure a comprehensive audit covering all aspects of their Information and Communication Technology (ICT) systems at least once a year”, and may opt for additional assessments and audits during the year. The roman numeral against each entry below is section 6’s own, but the grouping into five families is ours, for reading. Four of these definitions are printed twice in the instrument, word for word: vulnerability assessments, penetration testing and red team assessment appear at section 5(xxi), 5(xxii) and 5(xxiii) in the definitions as well as at 6(iii), 6(iv) and 6(xvi) here, so a scope of work may cite either pair.

Testing the attack surface

(iii)

Vulnerability assessments

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.

(iv)

Penetration testing

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 those vulnerabilities can be exploited to compromise the application, access sensitive data, or affect the underlying infrastructure and environment.

(xvi)

Red team assessment

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.

(viii)

Information security testing

The process of validating the effective implementation of security controls for information systems and networks, based on the organisation’s security requirements.

(xiv)

Wireless security testing

Evaluating the security measures of a wireless network by simulating attacks, to identify potential vulnerabilities and ensure the network is protected against unauthorised access and data breaches.

(xv)

Physical security testing

Assessing and evaluating the physical security measures that protect an organisation’s assets, including its facilities, equipment and personnel, from unauthorised access, theft, damage or other physical threats.

Applications and code

(xii)

Application security testing — web applications, mobile applications and APIs

Assessing an application’s architecture, components and configuration to identify security vulnerabilities. The guidelines name web applications, mobile applications and APIs inside a single scope item, which closes the gap left by a scope of work written only against a browser-facing front end.

(xiii)

Mobile application security auditing

A structured evaluation of mobile apps to identify security vulnerabilities, assess data protection, and ensure compliance with secure development practices.

(ix)

Source code review

Examining an application’s source code to identify security vulnerabilities, coding errors and inefficiencies, ensuring adherence to best practices, coding standards and regulatory requirements. Section 13.1.3 adds that critical applications call for both DAST and SAST, and that SAST by the developer or system integrator should be required in RFPs and tenders.

(xxvi)

SBOM, QBOM and AIBOM auditing

Evaluation of the Software, Quantum and Artificial Intelligence Bills of Materials to ensure transparency, traceability and integrity of components used in software, quantum computing and AI systems — identifying known vulnerabilities, licensing issues and supply chain risks in open-source and third-party components, and verifying adherence to secure development lifecycle practices and regulatory compliance.

Infrastructure and platform

(v)

Network infrastructure audits

Comprehensive review of network components — hardware such as firewalls, endpoint devices, servers, routers, network switches, IPS and IDS, together with software, configurations, access controls and security measures — to identify vulnerabilities, inefficiencies and areas for improvement.

(xviii)

Cloud security testing

Evaluating and assessing the security measures, configurations and vulnerabilities of cloud-based systems, applications and infrastructures. Section 8(ii) separately names the CSA Cloud Controls Matrix as the comprehensive framework to work from for cloud security.

(xxii)

Endpoint security assessment

Evaluating the security posture of endpoint devices — desktops, laptops, mobile devices — by assessing configurations, patching, malware protection, encryption, access controls and monitoring mechanisms.

(xxi)

Log management and maintenance audit

Assessing the effectiveness and completeness of system and security log generation, retention, integrity and monitoring practices, ensuring logs are maintained in accordance with organisational policies and regulatory requirements to support detection, investigation and response. This is also the scope item under which compliance with the 180-day log direction gets tested.

(xix)

Industrial control systems and operational technology security testing

Evaluating the cyber security posture of ICS and OT networks, designed to identify vulnerabilities and potential threats that could disrupt critical industrial processes, impacting safety, production and overall system availability within a facility.

(xx)

IoT and IIoT security testing

Evaluating and validating the security posture of connected devices within an IoT network, particularly in industrial settings, by identifying vulnerabilities and potential attack vectors.

Emerging domains

(xxiii)

Artificial intelligence system audits

Evaluation of AI systems for security, ethical alignment, transparency, data integrity and resilience to adversarial manipulation. This is the scope item that sits behind AI red teaming as a national audit concern — and Annexure I item (xx) of the 2022 Directions already makes an incident affecting AI and machine learning systems mandatorily reportable.

(xxv)

Blockchain security audit

A structured assessment of blockchain systems, including smart contracts and infrastructure, to identify vulnerabilities, verify cryptographic integrity, evaluate access controls and consensus mechanisms, and ensure compliance with security best practices and regulatory requirements.

(xvii)

Digital forensic readiness assessment

Evaluating an organisation’s preparedness to effectively collect, preserve and analyse digital evidence in the event of a security incident. Section 18(vi) adds the consequence: where a forensic investigation is constrained by unavailable or inadequate evidence or logs, the audit report should explicitly bring that out and recommend the log details that should be captured.

Governance, process and third parties

(i)

Compliance audits

Evaluation of an organisation’s security practices to ensure they adhere to relevant industry standards, regulations and policies. Section 8(iv) adds that guidelines and directions issued by CERT-In and regulators are to be included as part of the scope of audit by default.

(ii)

Risk assessments

Identifying and evaluating risks arising from cyber threats, vulnerabilities and potential cyberattacks that could impact organisational operations, organisational assets, individuals and connected entities, including the likelihood and impact of various incidents.

(vi)

Operational audits

Evaluation of an organisation’s cyber security operations, processes and controls to assess their efficiency, effectiveness and alignment with security objectives.

(vii)

IT security policy review

Review and assessment of policy against security best practices. Section 8(vi) makes it an auditor duty rather than an optional deliverable: the auditing organisation must verify existing policies against industry standards and best practices and suggest the necessary improvements.

(x)

Process security testing

Evaluating the security measures and controls within an organisation’s operational processes to identify vulnerabilities and ensure that sensitive information, systems and applications are protected from security threats.

(xi)

Communications security testing

Evaluating the security measures implemented on communication channels to identify vulnerabilities and ensure that information transmitted over those channels is protected from unauthorised access, interception, modification or disruption.

(xxiv)

Vendor risk management audits

Assessment of third-party and vendor cyber security practices to identify supply chain risks and ensure alignment with organisational security policies. Section 13.1.1 separately requires third-party, vendor and supply-chain risk to be inside the audit scope rather than treated as an optional extra.

What is VAPT, and what CERT-In means by it

VAPT stands for vulnerability assessment and penetration testing, and in India it is the ordinary term for the thing a CERT-In empanelled organisation does. It is worth noticing that CERT-In treats the two halves as separate scope classes with separate definitions, not as one acronym. A vulnerability assessment, at item (iii), is the examination of a system or product to determine the adequacy of security measures, identify security deficiencies, provide data from which to predict the effectiveness of proposed measures, and confirm their adequacy after implementation. A penetration test, at item (iv), actively tests individual components or the application as a whole to identify and exploit potential vulnerabilities, with the objective of determining whether they can be exploited to compromise the application, access sensitive data, or affect the underlying infrastructure and environment. The first tells you what is wrong. The second tells you what an attacker could do with it.

A red team assessment, at item (xvi), is a third thing again: 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. The distinction that matters commercially is objective. A penetration test is scoped to a system and asks how far an attacker gets into it. A red team assessment is scoped to an outcome and asks whether the organisation — including the people and the detection — would notice and stop it. The 2018 auditor guidelines use “red team” in a narrower internal sense as well, requiring an auditing organisation to deploy a verification team to check the work of its own audit team, and section 15.2.5(iii) of the 2025 guidelines restates that as a maker-checker requirement. Two meanings, one phrase, and a scope of work that does not say which one it means is a scope of work with a hole in it.

What the guidelines require of a VAPT specifically: the type of audit must be named before commencement under section 13.2.3(i)(a), which lists VAPT, external attack penetration testing, device level audit, configuration audit, process audit, mobile application security audit, web application security audit, API security audit and compliance audit as separate things you can buy. Testing must not be solely tools-based. Written permission is needed before DoS, DDoS or flood testing over the internet. Severity comes from CVSS, supplemented by EPSS, and every observation is mapped to a CWE and a CVE. And the environment tested — test, development, UAT, pre-production or production — must be stated in the report.

What AI red teaming is, and why an AI incident is already reportable in India

AI red teaming is adversarial testing of an AI system: attempting, as an adversary would, to make a model or the application around it produce harmful output, disclose data it should not, or take actions it should not, and then reporting what worked. It is the red team assessment of item (xvi) pointed at the system class of item (xxiii).

The Indian position on this is stronger than most people realise, and it does not depend on anything new. Item (xx) of Annexure I to the CERT-In Directions of 28 April 2022 makes attacks or malicious or suspicious activities affecting systems, servers, software and applications related to artificial intelligence and machine learning a mandatorily reportable incident class, on the six-hour clock. That was written into a 2022 instrument, before the current wave of deployment. It is on the official incident reporting form as a tick-box. An AI incident in India is not a novel regulatory question. It is item twenty.

On the audit side, section 6(xxiii) of the 2025 guidelines makes AI system audits a named scope class: evaluation of AI systems for security, ethical alignment, transparency, data integrity and resilience to adversarial manipulation. That last phrase is the one that carries red teaming. Section 6(xxvi) adds AIBOM — the artificial intelligence bill of materials — alongside SBOM and QBOM, and CERT-In publishes technical guidelines on the bill-of-materials family at version 2.0 covering SBOM, QBOM, CBOM, AIBOM and HBOM.

Where the distinction matters in a scope of work: an AI system audit is an assessment against criteria — is the system transparent, is the data pipeline sound, are the controls in place. AI red teaming is an attempt to break it. You can pass the first while failing the second, which is exactly why CERT-In’s own SAMVAAD 2026 programme carried presentations on AI-driven red teaming methodologies as a distinct topic. And the two obligations run on different clocks: the audit is annual, and the incident report is six hours.

What a CERT-In cloud security audit covers

Section 6(xviii) defines cloud security testing as evaluating and assessing the security measures, configurations and vulnerabilities of cloud-based systems, applications and infrastructures. Section 8(ii) then names the framework: the CSA Cloud Controls Matrix for cloud security, alongside ISO/IEC standards and the rest — and expressly not the OWASP Top 10 or SANS Top 25, which the guidelines say should not be considered standards or references for audits.

Cloud is not confined to one scope item. Section 13.1.1 puts cloud inside the general audit scope alongside web and mobile applications, APIs, OT and ICS, databases and hosting infrastructure. Annexure I item (xviii) of the 2022 Directions makes attacks and suspicious activity affecting cloud computing systems, servers, software and applications reportable — by you, for your tenancy, not merely by your provider. And direction (iv)’s log obligation lands hardest here, because a cloud estate is where logs most often leave the country by default.

One cloud-specific answer worth having in writing, because it comes up in every scoping call. CERT-In’s FAQ of May 2022 addresses time synchronisation in cloud environments at Q42: customers in cloud environments may use the native time services offered by the cloud, or set up their own NTP server within their cloud environment. Entities relying on native cloud time services may continue to use them. And where an entity runs its own NTP service synchronising with something other than native cloud time, the NTP servers of NPL, NIC or another accurate and standard source may be used as long as accuracy is maintained and the source does not deviate from NPL and NIC. That is a more workable answer than the bare text of direction (i) suggests, and it is CERT-In’s own.

Three consequences of that list being this long

A VAPT is a scope, not a synonym. The guidelines require the type of audit to be stated explicitly before commencement — VAPT, external attack penetration testing, device level audit, configuration audit, process audit, mobile application security audit, web application security audit, API security audit, compliance audit. A purchase order that says only “VAPT” has not yet specified what is being bought, and the difference surfaces when an API or a mobile client turns out to have been outside the tested surface.

The scope is supposed to come from an asset inventory, not from a wishlist. The guidelines say the scope must be derived from the organisation’s consolidated and updated asset inventory, vetted by the internal audit team in consultation with the CISO, and that assets in testing, UAT, development and production environments should all be included. Section 13.2.3(ii)(b) adds the detail that makes it checkable: the auditing organisation may advise the auditee to state explicitly the date up to which the scope or asset inventory has been updated, and “this date must be reflected in the audit reports”. An audit scoped from memory has a hole in it, and that date in the report is where the hole becomes visible.

Top-ten lists are not the standard. This surprises people, so it is worth quoting: limited lists such as the OWASP Top 10 and SANS Top 25 “should not be considered as standards or references for audits”. Audits should instead discover all known vulnerabilities against comprehensive frameworks — ISO/IEC standards, the Cyber Security Audit Baseline Requirements, the CSA Cloud Controls Matrix for cloud, OSSTMM3, the OWASP Web Security Testing Guide, the OWASP Application Security Verification Standard, the OWASP Mobile Security Testing Guide, and the OWASP DevSecOps Maturity Model for CI/CD pipeline security — along with applicable regulatory frameworks and the directions and guidelines issued from time to time by CERT-In, Government and regulators. Solely tools-based testing is to be discouraged, because a tool-driven audit tends to cover the automatable parts of an estate and miss the rest.

There is also a baseline that applies specifically to government work. For audits of critical applications, databases or platforms of Ministries, Departments, Secretariats and Offices where sensitive personally identifiable information is involved, the auditing organisation must verify compliance with the Comprehensive Audit Program Checklist — Cyber and Information Security Audit, set out in the Guidelines on Mandatory Features of Cybersecurity Architecture to be Ensured in all Ministries and Departments issued by the Cyber Security Division of the Ministry of Electronics and Information Technology. That checklist comprises 282 control points and forms the default mandatory audit scope for such entities. If you run a departmental application holding PII, that number is your floor, not your ceiling — see GIGW compliance before go-live for how it sits alongside the pre-production audit requirement.

CERT-In direction vs guideline vs advisory

Direction, guideline or advisory: which one is on your desk

CERT-In produces six recognisable kinds of output, and they carry completely different obligations. The mistake that costs the most is treating a direction as an advisory. The mistake that costs the second most is treating an advisory as noise.

KindIssued underBinding?What to doHow to recognise it
DirectionSection 70B(6)BindingComply. Non-compliance may invite punitive action under section 70B(7) and other laws as applicable. Read the effective date, and read it for a later order extending it: the 2022 Directions became effective 60 days after 28 April 2022 generally, but a separate order of 27 June 2022 moved that to 25 September 2022 for MSMEs and, for all four provider classes, for the validation limb of direction (v)(a) and (v)(f).Carries a file number in the form No. 20(3)/2022-CERT-In, names the classes of entity it applies to, and states that it is issued under sub-section (6) of section 70B.
GuidelineSection 70B(4)(e)Binding on those it names, and otherwise the standard you will be measured againstRead who it binds. The 2025 audit policy guidelines say in terms that they are binding on all CERT-In empanelled auditing organisations and auditee entities covered under the relevant provisions. Others should treat them as the expected standard of care.Published as a versioned document with a date — “Version 1.0 | 25.07.2025” — and carries an “Authority for Issuance of Guidelines” section setting out the statutory chain.
AdvisorySection 70B(4)(b) and (e)Not binding in itselfTriage and act on risk. Advisories are not directions — but section 15.2.1(v) of the 2025 audit policy guidelines says CERT-In updates, advisories and vulnerability notes should be incorporated in audit practices, and section 9.1(iv) tells auditee organisations to follow cyber security auditing related advisories and directions issued by CERT-In. An ignored advisory can therefore still reach you as an audit observation.Distributed to subscribers from advisory@cert-in.org.in, keyed to a product, version or threat rather than to a class of entity.
Vulnerability noteSection 70B(4)(b)Not bindingMatch it against your asset inventory and patch on your own severity model, scoring with CVSS and EPSS if you want the result to line up with how an audit will score it.Product-specific, with affected versions and, usually, a CVE reference.
WhitepaperSection 70B(4)(e)Not bindingUse as design input. Several — the secure application design guidelines, the audit baseline requirements — are cited by the binding documents, which lifts them from reading matter to the criteria your audit programme is expected to be built on.Thematic rather than incident-driven, published on cert-in.org.in without an effective date.
An order for informationSection 70B(6)Binding, and often urgentRespond through the designated point of contact. Direction (iii) sets the standard and the consequence — see the Directions section above.Arrives addressed to the point of contact you filed under Annexure II. If nobody in your organisation can say who that is, this is the gap to close first.

One caution that belongs here rather than anywhere else. Material circulates online that is attributed to CERT-In and is not from CERT-In — summaries with invented deadlines, consultancy blogs restating requirements that were never issued, and social posts announcing platform features with dates attached. The check is mechanical and takes a minute: the document is on cert-in.org.in, or it is on meity.gov.in or pib.gov.in, or it is not a CERT-In document. A reference number, an issue date and a statement of the provision it is issued under are the three things a genuine instrument always carries.

How to report a cyber incident to CERT-In

The six-hour clock, hour by hour

The single most consequential CERT-In obligation for an ordinary Indian company is direction (ii), and it fails for procedural reasons far more often than for technical ones. Below is what compliance looks like as a sequence rather than as a rule.

T+0

Somebody notices

The clock in direction (ii) starts on noticing the incident, or on being brought to notice about it — not on confirming it, not on completing triage, and not on the security team finishing its analysis. In practice the earliest defensible T+0 is the timestamp on the alert, the customer email or the vendor notification that first raised it.

T+0 to T+1h

Classify against Annexure I, not against your own severity scale

The question is not how bad it is. The question is whether it falls within one of the twenty types in Annexure I. Unauthorised access, data breach, data leak, ransomware, website defacement, DDoS, attacks on cloud systems and attacks affecting AI and machine learning systems are all in the list, at any severity. An internal “P3” can be a reportable incident.

T+1h to T+4h

Assemble what is known, and mark what is not

What was observed, when, on which systems, what is affected, what has been contained, and what remains unknown. A first report that is honest about its own gaps is a compliant report. Holding the filing until the picture is complete is how organisations miss the window while believing they are being careful.

By T+6h

File, through the named channels

incident@cert-in.org.in, phone 1800-11-4949, or fax 1800-11-6969, with the incident reporting form published on cert-in.org.in. File from the designated point of contact, so the correspondence thread and the Annexure II filing agree with each other.

T+6h onwards

Stay reachable

The point-of-contact direction is not a one-time filing, and the demand for information can run continuously alongside the investigation. An unmonitored role mailbox during an active incident is a second failure layered on the first.

Throughout

Preserve the logs

Direction (iv) requires 180 rolling days of logs for all ICT systems, maintained within Indian jurisdiction. During an incident those logs are simultaneously your investigation material, your evidence of what happened, and the record against which your own reporting timeline will be checked.

What the filing actually has to contain

A page that tells you to file within six hours and never says what a filing looks like has not helped you. There are two artefacts, and both are short. The first is the one to send today, and the second is the one you will send under pressure.

Artefact one · the Annexure II point of contact

Annexure II to the 2022 Directions is a form with eight fields, sent by email to info@cert-in.org.in, and updated from time to time. All communications from CERT-In seeking information and providing directions for compliance are sent to the point of contact you designate. You can complete this this afternoon, and there is no reason not to.

  • Name
  • Designation
  • Organisation Name
  • Office Address
  • Email ID
  • Mobile No.
  • Office Phone
  • Office Fax
Copy this, fill the brackets, send it

To: info@cert-in.org.in Subject: Designation of Point of Contact under direction (iii), CERT-In Directions dated 28.04.2022 — [entity name] Under direction (iii) of the CERT-In Directions dated 28.04.2022 (No. 20(3)/2022-CERT-In) and the format at Annexure II thereto, [entity name] designates the following Point of Contact to interface with CERT-In. Name: [ ] Designation: [ ] Organisation Name: [ ] Office Address: [ ] Email ID: [ ] Mobile No.: [ ] Office Phone: [ ] Office Fax: [ ] We will communicate any change in the above information to CERT-In as and when it occurs.

Then keep three things, because the filing alone only proves you did it once. Keep the sent item and its date, which is the artefact an auditor asks for. Keep evidence that the named mailbox is monitored — a rota, an alerting rule, or a test message with a recorded response time, refreshed quarterly. And write down the re-filing trigger: the person leaves or changes role, the mobile number changes, the office moves. Direction (iii) requires the information to be updated from time to time, and a three-year-old filing naming someone who left is the failure mode, not the absence of a filing.

Artefact two · the incident report

CERT-In publishes an incident reporting form on cert-in.org.in, and its own note on that form is the most useful sentence in the whole reporting regime: it is not mandatory to fill and/or sign this form. Incidents may also be reported by providing relevant information in the communication itself or in any other readable form. An email containing the right facts is a compliant report. The form matters because it tells you what the right facts are.

Who is reporting

Whether you are the affected entity or reporting an incident affecting another entity. Name and role or title. Whether you are an individual or an organisation. Organisation name. Contact number. Email. Address.

Which entity was affected

The affected entity, if it is not the reporting entity — the field that exists precisely because the party that notices and the party that was hit are often not the same.

Incident type

A tick-box against the twenty Annexure I classes, plus an “Other (please specify)” line. This is the field that makes classification unavoidable: you cannot file without deciding which class you are claiming.

Criticality

Whether the affected system or network is critical to the organisation’s mission, with brief details.

Basic information of the affected system

Domain or URL. IP address. Operating system. Make, model or cloud details. Affected application details. Location of the affected system including city, region and country. Network and name of ISP. The form says to provide information that is readily available.

The two timestamps

Occurrence date and time, and detection date and time, both to the minute. The second is the one the six-hour clock runs from, and it is the field that later proves whether you met the window.

A first report that is compliant, and one that is not

Compliant

“Reporting a cyber security incident affecting [entity], under direction (ii) of the CERT-In Directions of 28.04.2022. Incident type claimed: Annexure I item (iii), unauthorised access of IT systems/data. Detected 14:12 IST on 12 September 2026, by an alert from our identity provider. Occurrence time under investigation. Affected system: [application], a customer-facing web application hosted in [region]. Domain, IP, OS and version details attached. The system is critical to our service delivery. Known: three administrative sessions were created from an unrecognised IP range. Contained: those sessions terminated, credentials rotated, the IP range blocked. Unknown at this time: whether customer data was accessed, and the initial access vector. Logs are being preserved and are available on request. Point of contact: [name, designation, mobile, email], as filed under Annexure II.”

Not compliant

A complete, well-written incident report, with root cause analysis, confirmed scope of data access, a timeline reconstructed from logs and a remediation plan — sent forty hours after detection, because the team wanted to be sure before it said anything. Every fact in it is better than every fact in the report on the left. It is late, and the obligation was to report within six hours of noticing. The second failure mode is subtler: a first report that omits the Annexure I class, so that nothing on the CERT-In side records which of the twenty types you believe you are reporting.

One more thing the FAQ settles, at Q30. Asked what to do if the full information on the form is not available within six hours, CERT-In answers that entities may provide information to the extent available at the time of reporting, and that additional information may be reported later within reasonable time. The same answer then names the categories that should certainly be reported inside the six-hour window. Incidents of a severe nature such as denial of service, distributed denial of service, intrusion or the spread of a computer contaminant including ransomware on any part of the public information infrastructure including backbone network infrastructure. Data breaches or data leaks. Large-scale or most frequent incidents such as intrusion into a computer resource or website. And cyber incidents impacting the safety of human beings.

Worth noting that the incident obligation and the audit obligation converge. An empanelled auditor is required to test compliance with the 2022 Directions in every assignment, and the testing of incident response capability is named in the guidelines as something an auditee should include in scope. Whether your six-hour process works is therefore not a question you get to answer only to yourself.

CERT-In AMBAK and SAMVAAD 2026

AMBAK, and CERT-In SAMVAAD 2026

There are two official accounts of the launch, and between them they settle more than most commentary allows. On 29 April 2026 the Press Information Bureau published a release on CERT-In SAMVAAD 2026 and the launch of AMBAK. CERT-In then published its own conference proceedings — 666 pages, on cert-in.org.in — in which section 7.1 is the fullest published description of AMBAK that exists. It is worth separating carefully what those two documents actually say from what has accumulated around them.

Confirmed by the official accounts

  • AMBAK stands for Audit Monitoring, Benchmarking, Analysis and Kinetic Interventions. Both official accounts give the same expansion, and CERT-In’s conference proceedings also list it in their abbreviations annexure.
  • “Platform” is CERT-In’s own word for it. The proceedings record the launch of “AMBAK (Audit Monitoring, Benchmarking, Analysis and Kinetic Interventions) Platform” at the inaugural ceremony.
  • CERT-In’s own gloss of “Kinetic Interventions” is “targeted interventions”. Section 7.1 of the proceedings says AMBAK was launched “to support audit monitoring, benchmarking, analysis and targeted interventions” — the only official gloss of that fourth component that exists anywhere.
  • It was launched at CERT-In SAMVAAD 2026, a three-day national annual conference held from 27 to 29 April 2026 at the BITS Pilani K. K. Birla Goa Campus, in association with BITS Pilani, Goa, with over 500 delegates.
  • The theme was “Securing Digital Bharat through Future-Ready Audits: Adapting, Assuring, Advancing”.
  • The conference was conceived and executed under Dr. Sanjay Bahl, Director General, CERT-In, with a keynote by Shri S. S. Sarma, Senior Director, CERT-In, and was inaugurated by Dr. Pramod Sawant, Chief Minister of Goa.
  • Also launched: progress reports by the Working Groups on emerging domains, and — with BIRD and NABARD — an advanced cybersecurity certification course for Rural Financial Institutions.
  • Over 87 presentations were selected from more than 200 submissions, on topics including the cyber security of space assets such as UAVs and satellites, emerging tools for automated audits, IoT, AI-driven cyber risks including emerging frontier AI models with advanced cyber capabilities, blockchain, quantum communication and post-quantum cryptography, SBOM, CBOM, QBOM and HBOM implementation, AI-driven red teaming methodologies, supply chain audits, and the auditing of cloud systems, APIs and operational technology.

Circulating, but in neither official account

Two claims about AMBAK appear widely in vendor posts and social commentary: that AMBAK is blockchain-enabled, and that security audit reports and audit certificates become verifiable through AMBAK from a specific date in July 2026. Neither appears in the Press Information Bureau release, and neither appears in CERT-In’s own 666-page conference proceedings. The word “blockchain” occurs in the proceedings only in the list of conference discussion topics and in paper titles, never connected to AMBAK. No verification service, portal, access rule or commencement date is described anywhere. The July 2026 date does not appear in connection with AMBAK at all — in a document whose own file metadata records it as produced after that date.

Both accounts were read in full, and both negative findings are stated as at 18 September 2026. A negative finding is only as good as the date attached to it, so check CERT-In directly if you are reading this much later. Neither claim is asserted here, and neither should be asserted in a bid document, a customer assurance pack or a board paper on the strength of a vendor blog. What the official accounts support is the name, its expansion, CERT-In’s own framing of the purpose, the fact of the launch and the occasion. The operational detail is still being published. A fuller treatment is in CERT-In AMBAK, and the conference itself in CERT-In SAMVAAD 2026.

The more useful signal in the release is the agenda. The topics selected from more than two hundred submissions are the Government’s own statement of what the national audit ecosystem is now concerned with: space assets including UAVs and satellites, automated audit tooling, IoT, AI-driven cyber risk including frontier models with advanced cyber capabilities, blockchain, quantum communication and post-quantum cryptography, the SBOM, CBOM, QBOM and HBOM family, AI-driven red teaming methodologies, supply chain audits, and the auditing of cloud systems, APIs and operational technology. Several of those map directly onto named scope classes in section 6 of the 2025 policy guidelines — AI system audits at (xxiii), blockchain at (xxv), red team assessment at (xvi), SBOM, QBOM and AIBOM auditing at (xxvi), cloud security testing at (xviii), application security testing including APIs at (xii), and ICS and OT at (xix). Others, including space assets and post-quantum cryptography, appear in the conference programme without a corresponding scope entry, and the CBOM and HBOM members of the bill-of-materials family sit in CERT-In’s separate technical guidelines rather than in section 6. The direction of travel is not subtle, and it lines up with the technology estates Indian companies are actually building. A fuller account sits at CERT-In AMBAK.

Buying an audit

Fourteen checks before you sign

Every item below comes from CERT-In’s own guidelines, and every one of them is a clause you are entitled to insist on. Most audit disputes in India are not disagreements about findings. They are disagreements about things that were never agreed in the first place.

Confirm empanelment at source

The list of empanelled information security auditing organisations is published by CERT-In on cert-in.org.in. Read it there, in the current version, rather than accepting a PDF forwarded by the vendor. Empanelment runs for a period and is not permanent.

Read the snapshot information before you shortlist

CERT-In publishes snapshot information on the skills and competence of empanelled organisations, and the 2025 guidelines tell auditees and sectoral regulators to use it to match their requirements against an organisation’s competence: manpower and skillsets, relevant experience, categories of audit conducted, audits carried out in the last twelve months by sector, technical manpower deployed, and tools used.

Interview the people, not the firm

The guidelines expect auditees to interview and select the resources put forward, verify their technical credentials against CERT-In’s qualification requirements, and verify identity, official identity cards and designations. They also state plainly that auditing organisations should not field freelancers, interns, freshers, moonlighters, third-party consultants or employees serving notice — and that the auditee should verify compliance.

Check the names against the declared manpower

An auditing organisation must only deploy manpower declared to CERT-In in its snapshot information form, and audit reports may be signed only by that declared manpower. A name on your engagement that does not appear in the declaration is a problem before the audit starts, not after.

Do not tie payment to the outcome

The independence principle is explicit: payments should not be contingent on the outcome of the audit, favourable or unfavourable, nor tied to the submission or approval of any closure report. Fees should be based on predefined scope, deliverables and timelines. A milestone named “on issue of clean certificate” compromises the assessment.

Write the follow-up audit into the scope

The scope of work should specify follow-up audits, and the final report is to be issued after closure of vulnerabilities and completion of the follow-up audit on the production environment. Buying only the first pass is how a project discovers in month four that nobody is contracted to verify the fixes.

Require revalidation of the previous cycle

The auditing organisation must revalidate observations from the previous audit cycle, and unresolved items must be recorded as repeat observations in the current cycle. A clean report that is silent about last year’s findings has skipped a required step.

Fix the severity language up front

Observations must be categorised using CVSS for severity and supplemented with EPSS for likelihood of real-world exploitation, and every observation must be mapped to a CWE and a CVE number. Agree this in the engagement letter and the report format ceases to be negotiable at the end.

Name the environment in writing

The report must state the environment tested — test, development, UAT, pre-production or production. For a website the auditor is required to test on the staging or testing environment provided by the hosting service provider before issuing the audit certificate, and application hash values and version numbers must be obtained from the auditee and included in the report. If the scope was limited to staging, the report must say so explicitly.

Ask for the working notes and the evidence appendix

Auditees are told to seek working notes on completion, with provision for it in the audit contract, and to ask for the audit evidence collected during the assessment to be submitted as an appendix to the final report. This is the single clause that separates a report you can act on from a PDF you can only file.

Check the signing chain

The report is signed by the auditors who conducted the audit, reviewed and signed by a designated reviewer from mid-management who was not part of the audit team, and then authorised and signed by the head of the auditing organisation — a director, partner or CEO. The audit certificate must be signed by both the lead auditor and the head of the auditing organisation.

Settle data handling and residency

Auditee data is to be stored only on systems located in India, kept encrypted on auditor laptops during the engagement, and wiped afterwards — with a formal certificate issued to the auditee confirming irreversible deletion. Data is not to be shared with any overseas entity or partner unless specifically authorised in writing by the auditee. Where no retention period is agreed, the auditing organisation retains data for one year from completion.

Agree the escalation matrix and the entry and exit conferences

An escalation matrix belongs in the audit contract. The auditing organisation is expected to present its understanding of scope, methodology and timelines to the board and senior management at onboarding, and to present findings, overall security posture and associated risks at the exit conference.

Expect the CERT-In reporting obligation to be disclosed to you

Auditing organisations must inform the auditee, before the assignment commences, that audit metadata and the audit report will be shared with CERT-In within five days of completion of the audit. An auditor who has not raised this has skipped a planning requirement.

And three things the guidelines put on you, not on the auditor

The audit process cannot be delegated. The guidelines state that the complete audit process of the information infrastructure must be undertaken by the auditee organisation itself — defining the scope, selecting the auditing organisation, providing access, and ensuring closure of all observations — and that this responsibility must not be delegated. External support may be engaged for specialised expertise, but full ownership and accountability for the security of the infrastructure stays with the owner. A department that hands the whole exercise to a systems integrator has not complied with that, however good the integrator is.

Risk acceptance is a decision for the head of the organisation. Treatment of any reported vulnerability or observation — retain, avoid, transfer or reduce — must be authorised and accepted by the head of the auditee organisation, and any exception to a reported vulnerability in an application must be authorised by the head of the organisation who owns the application. That is a named human being signing a risk acceptance, not a spreadsheet column.

Do not change the code after the certificate. The guidelines ask developers to avoid making code changes to the audited application or infrastructure after issue of the audit certificate, and recommend that hash values, versions and timestamps be captured and featured prominently in the certificate and reports. A major change must undergo a cyber security audit before implementation, while minor changes go through normal change management without one. The classification decision is therefore a compliance control, and it belongs in your change process rather than in someone’s judgement on the day — see how long a certificate stays valid and how to verify a CERT-In audit certificate.

Failure modes

Eight ways this goes wrong, and how to catch each one

None of these are exotic. Each one is a thing a competent team does for a sensible reason, and each one shows up in evidence in a way that is easy to detect in advance and expensive to discover during an incident or an audit. Four beats each: what it looks like from the inside, how it shows up in evidence, how to catch it first, and what it costs to fix now rather than later.

Waiting for certainty before filing

From inside

A competent security team spends the first day establishing what actually happened, because that is what a competent security team does, and files on day two with a complete account.

In evidence

The incident register shows a detection timestamp on Monday and a CERT-In acknowledgement on Wednesday. The gap is arithmetic, and it is the first thing an auditor computes.

Catch it first

Run the arithmetic yourself, quarterly, across every incident in the register. If detection-to-filing exceeds six hours anywhere, the process is the finding, not the incident.

Cost now vs later

Free to fix now — it is a decision about when to press send. Mid-incident it costs you the defence, because CERT-In’s FAQ already answered the objection at Q30: entities may provide information to the extent available at the time of reporting, and additional information may be reported later within reasonable time.

Classifying on your own severity scale

From inside

Triage says “P3, no customer impact”, the ticket closes, and nobody with reporting responsibility ever sees it.

In evidence

Tickets closed at low severity that map to an Annexure I class on their face — an unauthorised access is item (iii) whatever the impact assessment said, and a probe against a critical system is item (i).

Catch it first

Put the twenty Annexure I classes into the triage form as a mandatory field, parallel to severity and independent of it. The CERT-In reporting form makes you tick a class anyway, so make your own tooling ask the same question first.

Cost now vs later

A form field now. Later it is an auditor reconstructing your register against the Annexure I list and finding incidents you never classified.

A point of contact nobody maintains

From inside

The Annexure II form was filed once, by someone who has since changed roles, naming a mailbox nobody watches.

In evidence

The filing date is years old, the named individual is not in the current directory, and nobody can produce a test message that was answered.

Catch it first

Review it on the same cycle as your access reviews, and send a test message to the filed address once a quarter with a recorded response time. Re-file on any change — direction (iii) requires the information to be kept updated.

Cost now vs later

Ten minutes a quarter. The alternative is an order for information arriving at a dead mailbox, and failure to furnish information when ordered is itself non-compliance.

Logs enabled, but not across the whole asset inventory

From inside

Logging was configured thoroughly at some point. Then services shipped, a region was added, a managed database replaced a self-hosted one, and none of it was added to the pipeline.

In evidence

The gap appears the moment anyone reconciles the log sources against the asset inventory — which is exactly the reconciliation an auditor performs, because direction (iv) says “logs of all their ICT systems”.

Catch it first

Make the reconciliation a scheduled job rather than an audit activity: asset inventory in, log sources out, difference alerted. If the inventory is not good enough to do that, the inventory is the first finding.

Cost now vs later

A recurring job now. Mid-incident it is the six weeks you cannot see, in the systems that turn out to matter.

An incident register that does not reconcile to the filings

From inside

Incidents live in the ticketing system, filings live in somebody’s sent items, and no one object joins them.

In evidence

Two lists of different lengths. Under-reporting shows up here before it shows up anywhere else, and the reconciliation is the first thing an auditor performs once section 15.2.1(iv) puts the 2022 Directions into the assignment.

Catch it first

One field on the incident record: “reported to CERT-In — yes, no, not applicable, with reference”. Then a report that lists every Annexure I-classified incident where the field is blank.

Cost now vs later

A field and a saved query. Section 15.2.2(i) of the audit policy guidelines requires high-risk findings such as discovered breaches to be reported immediately to the auditee organisation and to CERT-In — so this one does not necessarily stay between you and your auditor.

Subscriber fields collected but never validated

From inside

Signup captures a name, an address and a phone number, and stores them. Direction (v) requires validated names and validated address and contact numbers.

In evidence

There is no verification step to point at, and no artefact of verification retained against the record. The registration forms, the onboarding terms and the retention schedule are where an auditor looks, because that is where the obligation either exists or does not.

Catch it first

Ask one question of your own onboarding flow: for each of the seven fields, what checked it, and where is the output of that check stored?

Cost now vs later

A change to onboarding, and a backfill decision for existing subscribers. Cheaper before an audit than after one, and cheaper still than after a records request you cannot answer.

An audit bought without a retest

From inside

The scope of work covers the assessment. The findings arrive. Remediation happens, or partly happens, and nobody validates it because no one paid for a second pass.

In evidence

A final report issued before closure, which section 16.3(v) says should not have happened: the final audit report should be issued after closure of vulnerabilities and completion of the follow-up audit on production.

Catch it first

Read the scope of work for the words “follow-up audit”. Section 9.3(iv) requires it to be included in the scope or the RFP proposal. If it is in neither, you are buying half a cycle.

Cost now vs later

A line item at procurement. Afterwards it is a separate engagement, a separate approval, and a certificate you cannot issue.

A certificate invalidated by a post-certificate code change

From inside

The certificate is issued, the release train resumes, and a change goes out that nobody classified.

In evidence

The hash values, versions and timestamps that section 9.5(i) expects to be captured and featured prominently in the certificate and reports no longer match what is running.

Catch it first

Put the classification decision in the change process, not in somebody’s judgement on the day. Section 13.1.2(iii) defines a major change by risk rather than size — a configuration adjustment affecting sensitive data or critical infrastructure counts — and requires the audit before implementation.

Cost now vs later

A field in your change record now. Later it is a re-audit, at the worst moment, with a live production estate whose certificate no longer describes it.

CERT-In terms, explained

Twelve terms, defined as CERT-In defines them

This subject has a controlled vocabulary that almost nobody is introduced to before they have to use it in a tender. The middle column below is what each term means in CERT-In’s own documents. The right-hand column is the thing it is most often confused with, which is usually where the money goes wrong.

TermWhat it means in CERT-In’s own documentsWhat it is confused with
Auditee organisationThe organisation that owns or operates the systems, processes and infrastructure being evaluated by a CERT-In empanelled auditing organisation. Section 4(ii) says the guidelines are intended for organisations in both the public and private sectors.“The client”. The guidelines put duties on the auditee directly, not only on its auditor.
Auditing organisationA firm CERT-In has empanelled to undertake audits, including vulnerability assessment and penetration testing, of computer systems, networks and applications. It contracts with you commercially and signs the report.“CERT-In”. The auditor is empanelled by CERT-In, but it is not CERT-In, and it is not acting on CERT-In’s behalf.
EmpanelmentInclusion on CERT-In’s published panel of information security auditing organisations, following a four-step assessment, for a period, subject to continuing obligations.“CERT-In certified”. There is no such status for an auditee. Empanelment attaches to the auditing organisation and does not transfer to anyone it audits.
Snapshot informationThe information CERT-In publishes about each empanelled organisation. Section 12.1(ii) lists what it lets you evaluate: manpower and skillsets, relevant experience, categories of audit conducted, audits in the last twelve months by sector, category-wise counts, technical manpower deployed with details, and tools used.A capability statement from the vendor. The snapshot is also the roster your report may be signed by, under section 9.5(iii).
Declared manpowerThe people named to CERT-In in the snapshot information form. Section 10.2(vi) says an auditing organisation must only deploy them, and section 9.5(iii) says only they may sign.Whoever turns up. Section 12.2(iii) is blunt: auditing organisations should not field freelancers, interns, freshers, moonlighters, third-party consultants or employees serving notice, and the auditee should verify compliance.
Audit metadataThe information about an audit that the auditing organisation must send CERT-In within five days of completion, in CERT-In’s prescribed format, along with the audit report.Something you can decline. Clause 3.1.7 of the empanelment terms says empanelled organisations shall provide audit reports and data to CERT-In without the auditee’s explicit permission.
Audit clearance certificateThe artefact GIGW statement 5.3.1 requires before a government website, web application, portal or mobile app is hosted in the production environment, issued by NIC, STQC, an STQC empanelled laboratory or a CERT-In empanelled laboratory.The audit report. They are different documents with different signatories: the certificate is signed by the lead auditor and the head of the auditing organisation.
Safe-to-host certificateThe operational name for that certificate. It is official language: GIGW’s new-features page says 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”.A CERT-In certificate. CERT-In issues none. The empanelled organisation issues it on its own letterhead, under its own signatures.
Working notesInternal documentation created by auditors during the audit — activities, methodologies, evidence gathered, preliminary findings — serving as the record that substantiates conclusions. Section 5(iv) requires adherence to the Policy Guidelines for Handling Audit related Data.The report. Section 18 tells auditees to seek the working notes on completion, with provision for it in the contract. Most never ask.
Observation, and non-conformityAn observation is a documented finding identifying either conformity or deviation, supported by objective, verifiable evidence. A non-conformity is a condition where a process, control or practice fails to meet prescribed standards, regulatory requirements or internal policies.Each other. Not every observation is a failure — section 5(v) says an observation may record conformity, and the 2018 auditor guidelines expect reports to state all states of security found, not only the failed ones.
Closure reportThe report generated at the conclusion of the audit indicating that all observations, findings and issues have been addressed, remediated or closed, and that the engagement has met its objectives.A payment milestone. Section 7 forbids exactly that: payments should not be tied to the submission or approval of any closure report.
Conflict of interestDefined at section 5(xvii) to include scenarios where the same entity is involved in both the implementation of controls and their subsequent audit, or conducts audits while also being responsible for remediation activities. The guidelines call these inherent conflicts that undermine the independence of the audit process.A disclosure formality. It is a structural test, and it is the reason the party that helps you fix findings should not be the party attesting that the fixing worked.

If one row earns its place it is the third. “CERT-In certified” is the phrase that travels furthest and means least, and it turns up in tender language, in vendor marketing and in customer security questionnaires. The correct construction for a bid is factual and slightly longer: name the CERT-In empanelled organisation that performed the audit and signed the report, name the certificate and its date, and let those do the work. That formulation is also the only one an empanelled auditor is itself permitted to use about its own status.

References

The primary sources, named and linked

A page that tells you thirty times to check the source should hand you the sources. These are the documents every statement above traces to, each named with its issuing body, its version and its date, and each annotated with the specific clauses this page relies on. All were read directly and last checked on 18 September 2026. Where a later version exists, it supersedes what is written here.

  • Information Technology Act, 2000 (21 of 2000), as amended — published text on indiacode.nic.in. Sections 43A (body corporate), 70A (national nodal agency for CII protection), 70B(1)–(8) (CERT-In, its functions, the power to call for information and give directions, the penalty and the cognizance gate), 75 (extra-territorial application) and 81 (overriding effect). indiacode.nic.in
  • Directions under sub-section (6) of section 70B of the Information Technology Act, 2000, No. 20(3)/2022-CERT-In, CERT-In, 28 April 2022, with Annexures I, II and III. The six directions, the twenty mandatorily reportable incident types at Annexure I, the point-of-contact format at Annexure II, the KYC standards at Annexure III, and the 60-day effective date. cert-in.org.in
  • Extension of timelines for enforcement of the Cyber Security Directions of 28th April 2022, No. 20(3)/2022-CERT-In, CERT-In, 27 June 2022. The second and third effective dates: 25 September 2022 for MSMEs classified under MSME notification S.O. 1702(E) of 1 June 2020, and 25 September 2022 for the validation limb of direction (v)(a) and (v)(f) for data centres, VPS, cloud and VPN service providers. cert-in.org.in
  • CERT-In, FAQs on Cyber Security Directions of 28.04.2022, May 2022. Q7 (the addressee list, and individual citizens excluded), Q13 (the obligation is not transferable), Q22 (it overrides a confidentiality clause), Q23 (deliberate non-compliance), Q26–Q29 (foreign entities and the point of contact), Q30 (partial information inside six hours), Q31 (data in a third party’s systems), Q34 (enterprise VPNs are out of direction (v)), Q35–Q38 (log storage, residency, what to log, and who may requisition), Q42 (time synchronisation in cloud environments). cert-in.org.in
  • CERT-In Incident Reporting Form. The fields a filing is expected to carry, the Annexure I tick-box, the two timestamps, and CERT-In’s own note that the form is not mandatory and an incident may be reported in any readable form. cert-in.org.in
  • CERT-In, Comprehensive Cyber Security Audit Policy Guidelines, version 1.0, 25 July 2025. Binding on empanelled auditing organisations and covered auditees. §2 (the authority chain, and the quoted words of rule 9 of the 2013 Rules), §5 (definitions, including non-conformity at 5(vi) and conflict of interest at 5(xvii)), §6 (the twenty-six scope classes), §7 (independence), §8 (standards, and the checklist at 8(v)), §9 (auditee duties, including the signature rule at 9.5(iii)), §10 (auditor duties, including the five-day rule at 10.6), §11 (quality control), §12 (selecting an auditor), §13.1.1 (scope), §13.1.2 (annual audit and major change), §13.1.5 (hosted on another’s server), §13.2.3 (pre-commencement communication), §15.2.1(iv) (verification of the 2022 Directions in every assignment), §15.2.2 (secure and ethical testing), §16 (reporting), §18 (evidence) and §19 (the deter-and-punish matrix). cert-in.org.in
  • CERT-In, Empanelment of Information Security Auditing Organisations — Terms and Conditions for Empanelment, version 7.2, April 2024. Clause 2.1 (CERT-In is not a party to your contract), 3.1.4 (access and CERT-In association), 3.1.7 (reports go to CERT-In without the auditee’s permission), 3.1.10 (the model NDA), 3.2.1 and 3.2.2 (the five-day filing and the unfixed-critical-vulnerability filing), 4.1 and 4.2 (the logo restriction and the one permitted sentence) and 8.1 (continued empanelment depends on quality). cert-in.org.in
  • CERT-In, Guidelines for CERT-In Empanelled Information Security Auditing Organizations, version 3.0, May 2018. The conduct rules: background checks and the NOC on movement between empanelled organisations, manpower declared to CERT-In, methodology over tooling, the verification-team expectation, the prohibited test classes, the expectation gap, and the branding restriction. cert-in.org.in
  • CERT-In, RFC 2350 — CERT-In description, version 1.0, 17 March 2022. The agency’s own self-description: the address at Electronics Niketan, the Director General as head, around 100+ officers, the constituency, the service lines, the mailboxes and help desk numbers, the PGP keys, CVE Numbering Authority status, full membership of FIRST and operational membership of APCERT since 2006, listed team in TF-CSIRT since 24 June 2021, the stakeholder list, and §3.9 — “CERT-In is designated as the National Nodal Agency for Incident Response under Section 70(B)”. cert-in.org.in
  • CERT-In, “Empanelment of Information Security Auditing Organisations by CERT-In” — the empanelment page. The four assessment steps — documentation review, offline practical skill test, VA/PT practical skill test, personal interaction session at CERT-In — and the current application window, quoted and date-stamped on this page. cert-in.org.in
  • CERT-In, published list of empanelled information security auditing organisations, with snapshot information for each. The document against which every empanelment and declared-manpower check on this page is performed. cert-in.org.in
  • National Security Council Secretariat, Cyber Security Audit Baseline Requirements, Publication NSCS-46-16 Rev 1.0, October 2020 — hosted on cert-in.org.in. Its own abstract: the minimum security assurance baseline expected across the cyber information infrastructure of organisations, forming the criterion for the conduct of cyber security audits. Named at §8(iii) of the audit policy guidelines as the basis for an audit programme. Note the issuer — NSCS, not CERT-In. cert-in.org.in
  • CERT-In, Guidelines for Secure Application Design, Development, Implementation & Operations. The secure-development expectations behind §8(viii) — an application developed without secure design and development practices should not be considered for assessment and audit, and the auditee is to be told so in writing with a copy marked to CERT-In. cert-in.org.in
  • CERT-In, Technical Guidelines on SBOM, QBOM & CBOM, AIBOM and HBOM, version 2.0, dated 9 July 2025. The bill-of-materials family. Read alongside scope item (xxvi) of the audit policy guidelines, which names the BOM types without citing this document. cert-in.org.in
  • Guidelines for Indian Government Websites and Apps (GIGW 3.0), guideline 5.3.1 — National Informatics Centre with STQC and CERT-In. The four bodies permitted to issue an audit clearance certificate before production hosting, the evaluator action that the certificate must be valid, and the developer action requiring re-audit at least once a year or on any change to the source code, whichever is earlier. guidelines.india.gov.in
  • Digital Personal Data Protection Act, 2023 (22 of 2023), section 8(6) — Gazette of India, published by MeitY. The separate personal-data-breach duty: intimation to the Board and to each affected Data Principal, in such form and manner as may be prescribed. meity.gov.in
  • Press Information Bureau, Government of India, Ministry of Electronics & IT, release ID 2256581, “CERT-In SAMVAAD 2026”, 29 April 2026. The first official account of the AMBAK launch, the conference figures and the topic list. pib.gov.in
  • CERT-In, CERT-In Samvaad 2026 — Conference Proceedings, 2nd edition, 666 pages. The second and fuller official account. Section 7.1 is the fullest published description of AMBAK that exists, and the source of “Platform” as CERT-In’s own word and “targeted interventions” as its own gloss of “Kinetic Interventions”. cert-in.org.in
  • CERT-In, Directions under section 70B — the landing page carrying the Directions, the extension order and the FAQ. The single page to check first if you want to know whether any of the 2022 instruments has moved since this page was last reviewed. cert-in.org.in

Named by the guidelines, but not retrievable. Section 15.2.1(iv) of the audit policy guidelines points auditors at a document called “Method of verifications to compliance with CERT-In Directions issued on 28.04.2022” and gives a URL for it on cert-in.org.in. As at 18 September 2026 that URL does not serve the document. It returns a short page reading “The requested URL is not found.” This page therefore cites the document as the guidelines name it and asserts nothing about its contents. The Information Technology (The Indian Computer Emergency Response Team and Manner of performing functions and duties) Rules, 2013 are in the same position: they are quoted here as CERT-In itself reproduces rule 9 in the authority section of the 2025 guidelines, because we could not retrieve the notified text from an official source on that date.

This page also states several negative findings — that no register of prosecutions is published, that no verification portal has been described, that two widely circulated AMBAK claims appear in neither official account. Each is stamped 18 September 2026 where it appears. A negative finding is only as good as the date attached to it: if you are reading this well after that date, check the CERT-In sources above before relying on one. If the position has moved, we would rather be told and correct the page than be quoted accurately on something that has changed.

Frequently Asked Questions

What is CERT-In?
CERT-In is the Indian Computer Emergency Response Team, the agency of the Government of India appointed under sub-section (1) of section 70B of the Information Technology Act, 2000 by a notification dated 27 October 2009, to serve as the national agency for cyber security. It functions under the administrative control of the Ministry of Electronics and Information Technology and is headed by a Director General, whom section 70B(2) requires the Central Government to provide. The thing most descriptions leave out is the shape of the job: CERT-In runs a 24x7 incident response help desk, publishes alerts and advisories, operates a cyber forensic laboratory and the Cyber Swachhta Kendra botnet cleaning centre, empanels the organisations that perform information security audits in India, and issues binding directions. It does not certify companies and it does not audit them.
What is the full form of CERT-In?
Indian Computer Emergency Response Team. CERT-In and ICERT are both used — CERT-In’s own audit policy guidelines note that the agency appointed by the 2009 notification “is now referred as CERT-In or ICERT” — and CERT-In is the form used throughout the Directions and guidelines. Section 70B of the Information Technology Act, 2000 is the provision that creates it and designates it as the national agency for incident response.
What are the functions of CERT-In?
Six, set out at sub-section (4) of section 70B: (a) collection, analysis and dissemination of information on cyber incidents, (b) forecast and alerts of cyber security incidents, (c) emergency measures for handling cyber security incidents, (d) coordination of cyber incidents response activities, (e) issue of guidelines, advisories, vulnerability notes and whitepapers relating to information security practices, procedures, prevention, response and reporting of cyber incidents, and (f) such other functions relating to cyber security as may be prescribed. The sixth clause is the one under which the Rules of 2013 prescribed information security assurance and audit to CERT-In, at rule 9 — which is the origin of the empanelment scheme.
Is CERT-In a certification body? Does CERT-In certify companies?
No. Nothing in section 70B empowers CERT-In to certify organisations, and it does not do so. There is no CERT-In certificate issued to a company, no CERT-In accreditation of a business, and no register of CERT-In-certified organisations. What exists is empanelment of information security auditing organisations: CERT-In assesses and lists the firms that are competent to perform audits. Those firms issue the audit report and, where one applies, the audit clearance certificate, under their own signatures. Empanelment attaches to the auditing organisation and does not transfer to the organisation being audited.
Does CERT-In audit my company?
Not in the ordinary course. Your audit is performed by an empanelled auditing organisation that you select and contract with. CERT-In reserves the right, under the 2025 Comprehensive Cyber Security Audit Policy Guidelines, to be part of the audit team of an auditing organisation at any point in order to assess the quality and maturity of the audit — and where it does, the auditing organisation must communicate that clearly and in writing to the auditee. CERT-In also conducts episodic security audits of key organisations, which is a national assurance activity rather than a service you can commission. And it is not a party to your contract: the guidelines instruct auditing organisations to ensure that CERT-In is not made or projected to be a part of any contract between an auditee and an auditing organisation.
What is CERT-In empanelment?
A scheme under which CERT-In maintains a panel of IT security auditing organisations for auditing — including vulnerability assessment and penetration testing — of computer systems, networks and applications of various organisations of the Government, critical infrastructure organisations and those in other sectors of the Indian economy. New applications are accepted only in windows CERT-In advertises on its empanelment page, and are assessed in four steps: a documentation review round, an offline practical skill test, a vulnerability assessment and penetration testing practical skill test, and a personal interaction session at CERT-In. Empanelment carries continuing obligations — only declared manpower deployed and signing, current snapshot and point-of-contact information, audit metadata and reports shared with CERT-In within five days of every audit — and can be suspended or withdrawn under the graded framework at section 19 of the 2025 policy guidelines.
Does Tranquility Cybersecurity deliver CERT-In audits?
Yes. We deliver CERT-In audits, end to end, with our CERT-In empanelled partners.
When was CERT-In established?
Two dates circulate and both are correct. CERT-In states on its own website that it “is operational since January 2004” — that is when the national CSIRT began work, before there was a section of the Act to place it in. Its statutory footing came later: section 70B was inserted into the Information Technology Act, 2000 by the Information Technology (Amendment) Act, 2008, which the published Act records as coming into force with effect from 27 October 2009, and CERT-In’s own instruments describe the agency as appointed under sub-section (1) “vide notification dated 27th October 2009 published in the official Gazette”. So: operational from January 2004, statutory from 27 October 2009. A source giving you only one of the two is answering half the question. For compliance purposes the 2009 date is the one that matters, because every obligation traces to the statute rather than to the help desk.
How do I contact CERT-In?
Match the channel to the job, because sending the right message to the wrong desk costs time in the hour you can least afford it. For an incident: incident@cert-in.org.in, phone 1800-11-4949 (toll free) or +91-11-24368572, fax 1800-11-6969 (toll free) — the 24x7 incident response help desk, and the channels named in direction (ii) of the 2022 Directions. For alerts, technical questions, and to file your Annexure II point of contact: info@cert-in.org.in. Advisories go out from advisory@cert-in.org.in, and subscription is through subscribe@cert-in.org.in. Vulnerability disclosure goes to vdisclose@cert-in.org.in. Empanelment matters and the auditee feedback form go to empanelment@cert-in.org.in. The postal address in CERT-In’s RFC 2350 is Electronics Niketan, 6 CGO Complex, Lodhi Road, New Delhi – 110003. CERT-In publishes PGP keys for the incident, information and vulnerability-disclosure addresses. Fetch them before you need them.
Is CERT-In a government body? Is it a regulator?
It is a government body, and calling it a regulator is close enough to be useful but loose enough to mislead. Section 70B(1) requires the Central Government to appoint “an agency of the Government”, and CERT-In’s RFC 2350 confirms it functions under the administrative control of the Ministry of Electronics and Information Technology. What makes “regulator” imprecise is the shape of the remit. CERT-In is the national nodal agency for incident response, and its six functions at 70B(4) are operational ones — collection and analysis of incident information, forecasts and alerts, emergency measures, coordination, and publication. It has a genuine regulatory edge: sub-section (6) lets it call for information and issue binding directions, sub-section (7) attaches a penalty, and it empanels and polices the organisations that perform information security audits. But it licenses no business, approves no product, certifies no company and adjudicates no dispute. The useful formulation is that CERT-In regulates the audit market and directs incident reporting, but it does not regulate you as a sector regulator would.
Where is the CERT-In empanelled auditor list?
On cert-in.org.in, published by CERT-In itself, alongside snapshot information for each organisation. Read it there in the version published today rather than accepting a PDF or a letter forwarded by a vendor — empanelment runs for a period and can be suspended or withdrawn inside it under the graded framework at section 19 of the 2025 policy guidelines, and a suspension does not come with a press release. Section 12.1(ii) sets out what the snapshot is there to let you evaluate: manpower and skillsets, relevant experience, categories of audit conducted, audits carried out in the last twelve months by sector, category-wise counts, technical manpower deployed with details, and tools used. Two further checks while you are in it. Find the legal entity name that will appear on your contract, not the trading name or the group. And check the individuals proposed for your engagement against the declared manpower, because section 9.5(iii) says the report may be signed only by manpower declared to CERT-In in that snapshot.
Do the CERT-In Directions apply to startups and small companies?
Yes. The Directions name “body corporate” as an addressee, and the Explanation to section 43A of the IT Act defines that as “any company”, including “a firm, sole proprietorship or other association of individuals engaged in commercial or professional activities”. Size is not a threshold for applicability, and there is no revenue, headcount or funding floor anywhere in the instrument. Size did affect timing, once: the extension order of 27 June 2022 provided that the Directions became effective on 25 September 2022 for Micro, Small & Medium Enterprises classified under MSME notification S.O. 1702(E) of 1 June 2020 — a later start date, not an exemption, and long past. What a ten-person company owes is what everyone else owes: clock synchronisation to NIC or NPL, reporting of the twenty Annexure I incident types within six hours of noticing, a designated point of contact filed under Annexure II, and 180 rolling days of logs held within Indian jurisdiction. The one to do this afternoon is the point of contact. The only entity the Directions exclude is the individual: FAQ Q7 ends, “Individual citizens are not covered by these Directions.”
What are the CERT-In Directions of 28 April 2022?
Six binding directions issued under sub-section (6) of section 70B, reference No. 20(3)/2022-CERT-In: NTP synchronisation, six-hour incident reporting, a designated point of contact, 180 days of logs held within Indian jurisdiction, five years of validated subscriber records for data centre, VPS, cloud and VPN providers, and five years of KYC and transaction records for virtual asset providers. The detail that decides most arguments is the addressee list, and CERT-In’s own FAQ at Q7 gives it in full: service providers, intermediaries, data centres, body corporate, Virtual Private Server providers, Cloud service providers, VPN Service providers, virtual asset service providers, virtual asset exchange providers, custodian wallet providers and Government organisations — and then adds that individual citizens are not covered. On timing, there are three effective dates and not one. The Directions took effect 60 days after 28 April 2022 generally. A separate extension order of 27 June 2022, linked from CERT-In’s own Directions page, made them effective on 25 September 2022 for Micro, Small & Medium Enterprises classified under MSME notification S.O. 1702(E) of 1 June 2020, and made the validation limb of direction (v)(a) and (v)(f) — “Validated names of subscribers/customers hiring the services” and “Validated address and contact numbers” — effective on 25 September 2022 for data centres, VPS, cloud and VPN service providers. That order is missing from almost every summary in circulation.
What is the CERT-In six-hour reporting rule?
Direction (ii) of the 2022 Directions requires covered entities to mandatorily report the cyber incidents listed in Annexure I to CERT-In within six hours of noticing them or of being brought to notice about them. The clock runs from noticing, not from confirming and not from completing the investigation. Reports go to incident@cert-in.org.in, by phone on 1800-11-4949 or by fax on 1800-11-6969, with an incident reporting form published on cert-in.org.in. The most common compliance failure is waiting for a complete picture: a first report stating what is known, what is affected and what remains unknown discharges the obligation. A thorough report filed on day two does not.
Which incidents must be reported to CERT-In?
Twenty types, listed at Annexure I, with no severity threshold attached. Targeted scanning or probing of critical networks and systems. Compromise of critical systems or information. Unauthorised access of IT systems or data. Website defacement or intrusion. Malicious code attacks including ransomware and cryptominers. Attacks on database, mail, DNS servers and network devices. Identity theft, spoofing and phishing. DoS and DDoS. Attacks on critical infrastructure, SCADA, operational technology and wireless networks. Attacks on e-governance and e-commerce applications. Data breach. Data leak. Attacks on IoT devices. Incidents affecting digital payment systems. Attacks through malicious mobile apps. Fake mobile apps. Unauthorised access to social media accounts. Attacks affecting cloud computing systems. Attacks affecting big data, blockchain, virtual assets, robotics, 3D and 4D printing, additive manufacturing and drones. Attacks affecting systems related to artificial intelligence and machine learning.
Do the CERT-In Directions apply to private companies?
Yes. The Directions name body corporate among the classes they apply to, alongside service providers, intermediaries, data centres and Government organisations. Any company operating ICT systems in India is inside the reporting perimeter for the twenty Annexure I incident types and subject to the clock synchronisation, point-of-contact and 180-day log obligations. Two of the directions add narrower categories on top: direction (v) for data centre, VPS, cloud and VPN providers, and direction (vi) for virtual asset service providers, virtual asset exchange providers and custodian wallet providers. Those are additive — a cloud provider that also runs a custodian wallet is subject to both.
What is the difference between a CERT-In direction and a CERT-In advisory?
The instrument and the consequence. A direction is issued under sub-section (6) of section 70B, binds the classes of entity it names, and carries punitive consequences under sub-section (7) for non-compliance. An advisory is issued under the function at sub-section (4) — forecast and alerts, and the issue of guidelines, advisories, vulnerability notes and whitepapers — and is not binding in itself. That said, an ignored advisory is not consequence-free: the 2025 audit policy guidelines require CERT-In updates, advisories and vulnerability notes to be incorporated into audit practices, so an advisory you disregarded can still reach you as an audit observation. A genuine instrument of either kind carries a reference number, an issue date and a statement of the provision it is issued under.
What is AMBAK?
AMBAK stands for Audit Monitoring, Benchmarking, Analysis and Kinetic Interventions, and it was launched at CERT-In SAMVAAD 2026 on 27–29 April 2026. Two official accounts of the launch exist — the Press Information Bureau release of 29 April 2026 and CERT-In’s own conference proceedings — and neither describes a verification service, a portal, a commencement date or a blockchain architecture. Claims that AMBAK is blockchain-enabled, or that audit reports and certificates become verifiable through it from a specific date in July 2026, appear in vendor and social commentary and in neither official account. Treat them as unconfirmed and take the current position from CERT-In.
How often does CERT-In expect a cyber security audit?
At least once a year, as a minimum rather than a target. Section 13.1.2 of the 2025 policy guidelines states that a cyber security audit should be conducted at least once in a year, that sectoral regulators may decide to increase the audit frequency based on the size of the organisation, the criticality of the assets being audited and the complexity of the adoption of digital infrastructure, and that this is a minimum frequency, with organisations free to audit more often depending on their risk appetite and the criticality of operations and assets. Separately, every change must go through formal change management and be classified as minor or major: a minor change needs no audit, while a major change — a system overhaul, a technology migration, or a configuration change affecting sensitive data or critical infrastructure — must undergo a cyber security audit before implementation.
What standards does a CERT-In audit test against?
Not a vulnerability top-ten list. The guidelines say in terms that limited lists such as the OWASP Top 10 and SANS Top 25 should not be considered standards or references for audits, and that audits should discover all known vulnerabilities against comprehensive frameworks: ISO/IEC standards, the Cyber Security Audit Baseline Requirements, the CSA Cloud Controls Matrix for cloud security, OSSTMM3, the OWASP Web Security Testing Guide, the OWASP Application Security Verification Standard, the OWASP Mobile Security Testing Guide and the OWASP DevSecOps Maturity Model for CI/CD pipeline security, together with applicable regulatory frameworks and the directions and guidelines issued from time to time by CERT-In, Government and regulators. Findings must be scored with CVSS, supplemented with EPSS for likelihood of real-world exploitation, and mapped to CWE and CVE identifiers.
Can an auditor advertise that it is CERT-In approved, or use the CERT-In logo?
No, other than in one prescribed form. An empanelled auditing organisation shall not use the CERT-In logo, nor make any reference to its association with CERT-In on any publicity material, promotional material or product, without the prior written permission of CERT-In. It may use the words “This Organization is empanelled by CERT-In for providing information Security Auditing Service”, and no other words may be used to describe the relationship without prior written permission. If a vendor’s marketing goes beyond that sentence, it either holds a written permission or it is out of line with the guidelines — and a buyer is entitled to ask which.
What happens if you do not comply with a CERT-In direction?
Section 70B(7) of the Information Technology Act, 2000 says it in one sentence: any service provider, intermediary, data centre, body corporate or person who fails to provide the information called for or comply with a direction under sub-section (6) “shall be punishable with imprisonment for a term which may extend to one year or with fine which may extend to one lakh rupees or with both”. Two qualifications matter. Section 70B(8) provides that no court shall take cognizance of an offence under the section except on a complaint made by an officer authorised by CERT-In. And CERT-In’s own FAQ of May 2022 says at Q23 that this power “will be exercised reasonably and on occasions when the non-compliance is deliberate”. In practice the first consequence is an order for information at your point of contact, and the second is a finding in an audit report that goes to CERT-In within five days.
Is CERT-In the same as NIC or STQC?
No, though all three appear in the same sentence in government projects. CERT-In is the national agency under section 70B, and it empanels information security auditing organisations. The National Informatics Centre describes itself as “the technology partner of the Government of India”, with a mandate to design and develop IT systems for the Government, provide ICT infrastructure to the Government, and explore and advise on the use of emerging technologies. STQC — the Standardisation Testing and Quality Certification Directorate — describes itself as an attached office of the Ministry of Electronics and Information Technology and a leading organisation for quality assurance services in electronics and IT, and it operates its own laboratories and empanels laboratories under its scope. For a government website or application, GIGW statement 5.3.1 requires an audit clearance certificate issued by NIC, STQC, an STQC empanelled laboratory or a CERT-In empanelled laboratory — four classes of issuer, of which CERT-In empanelled organisations are one.
Does CERT-In require logs and data to stay in India?
Two separate rules. For logs, direction (iv) of the 2022 Directions requires covered entities to mandatorily enable logs of all their ICT systems, maintain them securely for a rolling period of 180 days, and maintain them within the Indian jurisdiction — and to provide them to CERT-In with any incident report or when ordered. CERT-In’s FAQ at Q35 then adds that logs may be stored outside India as well, as long as the obligation to produce them to CERT-In in a reasonable time is met, while Q36 says any service provider offering services to users in the country needs to enable and maintain logs in Indian jurisdiction. Separately, on the audit side, auditee-related data is to be stored only on systems located in India, encrypted on auditor laptops during the engagement, wiped afterwards with a formal certificate of irreversible deletion issued to the auditee, and not shared with any overseas entity or partner unless specifically authorised in writing by the auditee.
Do the CERT-In Directions apply to foreign companies?
Yes, for incident reporting. CERT-In’s own FAQ of May 2022 puts the question directly at Q26 — do the Directions apply only to Indian companies or also to foreign firms that serve Indian customers — and answers that the Directions “are applicable to any entity whatsoever, in the matter of cyber incidents and cyber security incidents”, referring to sections 1 and 75 of the IT Act. Section 75 applies the Act to an offence or contravention committed outside India by any person irrespective of nationality, where the act involves a computer, computer system or computer network located in India. Q29 adds that service providers, intermediaries, data centres and body corporate offering services to users in the country shall designate a point of contact to liaise with CERT-In, whether or not they have a physical presence in India. Q27 gives the same answer for offshore virtual asset providers catering to Indian users, and Q28 for online gaming companies.
Is a CERT-In audit mandatory?
There is no single statute requiring every Indian company to have one. What exists is a set of specific triggers. A government website, web application, portal or mobile app needs an audit clearance certificate from NIC, STQC, an STQC empanelled laboratory or a CERT-In empanelled laboratory before hosting in production, under GIGW statement 5.3.1. Auditee organisations covered by the 2025 policy guidelines are expected to ensure a comprehensive audit covering all aspects of their ICT systems at least once a year, and to audit a major change before implementation. A sectoral regulator may require more. And a customer or a tender may require one contractually, which is the most common commercial trigger and the one with the least written law behind it. Work out which of those you are standing on before you buy anything.
How long is CERT-In empanelment valid, and how do I check an auditor is still empanelled?
Empanelment runs for a period rather than permanently, and it can be suspended or withdrawn during that period under the graded framework at section 19 of the 2025 policy guidelines. The reliable check is therefore not the duration but the list: CERT-In publishes the current list of empanelled information security auditing organisations on cert-in.org.in, along with snapshot information about each one. Read it there, in the version published today, rather than accepting a PDF or a letter forwarded by the vendor — a suspension does not come with a press release. While you are in the snapshot, check that the individuals proposed for your engagement appear in the declared manpower, because section 9.5(iii) says the report may be signed only by manpower declared to CERT-In in that snapshot.
How long does a CERT-In audit take?
The guidelines do not set a duration, and anyone quoting one without seeing your scope is guessing. What they do set is the shape of the calendar. The timeline of the assessment phase must be communicated to you before commencement, under section 13.2.3(i)(f). Critical and high findings are notified during the audit on an as-and-when-found basis rather than held for the report. Remediation is your work, not the auditor’s, and it is usually the longest phase. And section 16.3(v) fixes the end: the final report is issued after closure of vulnerabilities and completion of the follow-up audit of the application hosted on the production environment. So the realistic answer is that testing is short, remediation is variable, and the report date is set by the retest — which is why a scope of work without a follow-up audit in it produces a certificate you cannot get to.
What is VAPT?
Vulnerability assessment and penetration testing. CERT-In treats the two halves as separate classes with separate definitions. A vulnerability assessment, at section 6(iii) of the 2025 guidelines, is the 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 measures, and confirm their adequacy after implementation. A penetration test, at 6(iv), actively tests individual components or the application as a whole to identify and exploit potential vulnerabilities, to determine whether they can be exploited to compromise the application, access sensitive data or affect the underlying infrastructure. In a scope of work, “VAPT” is one of nine named audit types at section 13.2.3(i)(a), a list the guidelines end with “etc.” — the others named are external attack penetration testing, device level audit, configuration audit, process audit, mobile application security audit, web application security audit, API security audit and compliance audit.
What is AI red teaming, and does CERT-In require it?
AI red teaming is adversarial testing of an AI system — attempting, as an attacker would, to make a model or the application around it produce harmful output, disclose data it should not, or take actions it should not. CERT-In does not name it as a mandatory activity. Two things it does do are more consequential. Annexure I item (xx) of the 2022 Directions makes attacks or malicious or suspicious activities affecting systems, servers, software and applications related to artificial intelligence and machine learning a mandatorily reportable incident class on the six-hour clock — written into a 2022 instrument, and already a tick-box on the official incident reporting form. And section 6(xxiii) of the 2025 guidelines makes AI system audits a named audit scope class, defined as evaluation of AI systems for security, ethical alignment, transparency, data integrity and resilience to adversarial manipulation. An AI system audit asks whether the controls are there, while AI red teaming asks whether they hold. You can pass the first and fail the second.
What is the difference between CERT-In and NCIIPC?
Different sections of the same Act, and different jobs. Section 70A empowers the Central Government, by notification published in the Official Gazette, to designate any organisation of the Government as the national nodal agency in respect of Critical Information Infrastructure Protection, and makes that agency responsible for all measures including research and development relating to the protection of critical information infrastructure. Section 70B appoints CERT-In as the national agency for incident response across the whole economy, with the six functions at 70B(4) and the power to call for information and issue directions at 70B(6). CERT-In’s own RFC 2350 lists “the agency engaged for the protection of critical information infrastructure” among the stakeholders it interacts with, which is the relationship in one line: they are neighbours, not alternatives. If you operate critical information infrastructure you are answering to both, and a CERT-In filing does not discharge whatever that agency requires of you. On the designation itself, this page states the provision rather than the appointment: we could not read the designating gazette notification against an official source when these sources were last checked, and a page that tells you to verify everything should not ask you to take that one on trust.
Do I report a data breach to CERT-In or to the Data Protection Board?
Potentially both, and they are different duties. Data breach and data leak are items (xi) and (xii) of Annexure I to the CERT-In Directions, reportable to CERT-In within six hours of noticing, at any severity, whether or not personal data was involved. Separately, section 8(6) of the Digital Personal Data Protection Act, 2023 provides that in the event of a personal data breach the Data Fiduciary shall give the Board and each affected Data Principal intimation of the breach, in such form and manner as may be prescribed. The triggers differ: a ransomware event touching no personal data is a CERT-In incident and not a personal data breach, while a misconfigured store exposing customer records is both. Neither filing discharges the other. Build the two questions into your incident process as independent checks asked at the same moment, and note which clock is shorter.
Can I keep logs outside India if a copy stays in India?
Direction (iv) says logs of all ICT systems shall be enabled, maintained securely for a rolling period of 180 days, and “maintained within the Indian jurisdiction”. CERT-In’s FAQ of May 2022 then answers the storage question at Q35: “The logs may be stored outside India also as long as the obligation to produce logs to CERT-In is adhered to by the entities in a reasonable time.” Q36 adds that any service provider offering services to users in the country needs to enable and maintain logs and records of financial transactions in Indian jurisdiction. Read together, the defensible architecture is an India-resident copy covering the full 180 days for every in-scope system, plus a demonstrated ability to produce logs quickly — Q38 notes that the requisition may be made by an officer of CERT-In not below the rank of Deputy Secretary to the Government of India. CERT-In has not published a numeric definition of “reasonable time”, so do not adopt one from a vendor.
Who has to designate a CERT-In point of contact, and what does the form ask for?
Direction (iii) of the 2022 Directions requires all service providers, intermediaries, data centres, body corporate and Government organisations to designate a point of contact to interface with CERT-In, in the format at Annexure II, sent by email to info@cert-in.org.in and updated from time to time. All communications from CERT-In seeking information and providing directions for compliance are sent to that point of contact. The form has eight fields: name, designation, organisation name, office address, email ID, mobile number, office phone and office fax. It takes minutes. CERT-In’s FAQ at Q29 confirms that service providers without a physical presence in India who offer services to users in the country must designate one too. The common failure is not the filing but the maintenance — the named person changes role, the mailbox goes unwatched, and the first anyone notices is when an order for information arrives and nobody sees it, which is itself treated as non-compliance.
What is rule 9 of the CERT-In Rules, 2013?
The Information Technology (The Indian Computer Emergency Response Team and Manner of performing functions and duties) Rules, 2013 were notified on 16 January 2014 under sub-section (5) of section 70B, which provides that the manner of performing CERT-In’s functions and duties shall be as prescribed. CERT-In reproduces the operative provision in the authority section of its own 2025 audit policy guidelines, and it is worth having the exact words rather than a paraphrase: “The provision of rule no.9 of these Rules, 2013, inter-alia, prescribes the activity of Information security assurance and audit to CERT-In.” The Rules were made under clause (zf) of sub-section (2) of section 87 read with sub-section (5) of section 70B. That sentence is the legal root of the empanelment scheme, of the audit policy guidelines, and of the whole Indian information security audit ecosystem as it operates today.
Where to go next

If your question is about the binding obligations

The 2022 Directions explained takes the six directions clause by clause, at more length than this page has room for. CERT-In AMBAK separates what the Government has published about the platform from what circulates about it.

If your question is about auditors and empanelment

CERT-In empanelment explained covers how the scheme works and what it does and does not confer. Rules of engagement for an empanelled auditor is the conduct side: what an auditor may and may not do on your systems, and what it may say about its relationship with CERT-In.

If your question is about certificates

What a safe-to-host certificate is, how to get one, how long it stays valid, who can issue one, how it differs from a security audit certificate, how to verify one you have been handed, and why applications fail the first time.

If you are taking a government application live

GIGW compliance before go-live covers the guidelines your evaluator will actually work from, and where the audit clearance certificate sits inside them.

If you are scoping the testing itself

Penetration testing and VAPT is where the scoping conversation starts — web, mobile, API, cloud and network surfaces.

If you need a CERT-In audit

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

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: September 2026 • Content verified by certified lead auditors

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