India’s fintech industry has solved the problem of scale. The harder challenge now is keeping that scale secure. Fintech companies are connecting applications, APIs, cloud platforms, payment systems, banks, NBFCs, securities platforms, third-party vendors, AI systems, and vast amounts of customer data.
At the same time, regulatory expectations are becoming more detailed.
RBI is strengthening expectations around IT governance, cybersecurity, technology risk, resilience, third-party risk, and Information Systems Audit. SEBI’s Cybersecurity and Cyber Resilience Framework (CSCRF) brings requirements around VAPT, cyber audits, SOC, logging, asset management, cloud security, patching, and data protection into sharper focus for applicable regulated entities.
India’s Digital Personal Data Protection Act and 2025 Rules add another layer of accountability around personal-data processing and protection. And banks and financial institutions are increasingly asking their technology partners a very practical question:
“Show us that your environment is actually secure.”
That changes the conversation. A policy document is not enough. A compliance certificate is not enough. A vulnerability scan is not enough.
Fintechs increasingly need to demonstrate that their security controls are implemented, configured correctly, tested, monitored, and capable of responding to real threats.
Key Takeaways
- RBI’s IT Governance Directions and Cybersecurity Requirements place greater emphasis on governance, cyber risk, IT controls, resilience, third-party risk, and Information Systems Audit for applicable regulated entities.
- RBI’s cyber-resilience requirements for non-bank PSOs cover security testing, APIs, cloud, vendor risk, data security, patching, incident response, and digital payment security.
- SEBI CSCRF introduces a structured cybersecurity and resilience framework covering VAPT, cyber audits, SOC, asset management, logging, cloud, patch management, data security, and third-party risk.
- Bank and financial-institution audits can extend beyond policies into operational security, configuration, evidence, access controls, endpoint protection, monitoring, and incident readiness.
- DPDPA adds data-governance and protection obligations that fintechs need to incorporate into their security programs.
- Fintechs should validate whether security technologies such as MDM, DLP, EDR, SIEM, IAM, firewalls, and vulnerability-management platforms are correctly configured and actually working.
- Accorian’s cybersecurity experts and vCISOs can help fintechs move from documented compliance to demonstrable operational security.
The New Fintech Security Question: “Is It Actually Working?”
For years, cybersecurity programs often focused on having the right policies, certifications, tools, and documentation. That approach is becoming harder to defend. Consider a fintech that has:
- An information security policy
- A vulnerability management policy
- An incident response plan
- An EDR platform
- A DLP solution
- A SIEM
- An MDM platform
- MFA
- Cloud security tools
On paper, the organization may look secure. But what happens when someone asks:
- Is EDR deployed across every critical endpoint?
- Are high-risk alerts reaching the SOC?
- Are SIEM logs being collected from all critical systems?
- Are retention settings appropriate?
- Is DLP actually preventing sensitive information from leaving the environment?
- Are mobile devices enrolled in MDM and governed according to policy?
- Are privileged accounts protected by appropriate controls?
- Are critical vulnerabilities being remediated within defined timelines?
- Can you produce evidence that these controls are operating effectively?
This is where operational security testing and configuration assessment become critical.
As fintech becomes more connected and automated, regulatory and customer expectations are also becoming more operational. RBI and SEBI requirements, DPDPA obligations, and security audits by banks and enterprise customers increasingly require fintechs to demonstrate that controls are implemented, configured, monitored and tested, not simply documented.
RBI Cybersecurity Is Moving Beyond Policy
The RBI Cyber Security Framework for banks established a strong foundation for cybersecurity governance and risk management.
But the regulatory landscape has evolved.
RBI’s Master Direction on Information Technology Governance, Risk, Controls and Assurance Practices, 2023 consolidates requirements around IT governance, information security, cyber security, business continuity, disaster recovery, third-party arrangements, and Information Systems Audit. It applies to several categories of regulated entities, including scheduled commercial banks, small finance banks, payments banks, NBFCs, credit information companies, and All India Financial Institutions.
The direction also expects regulated entities to establish appropriate IT governance and cybersecurity oversight, periodically assess IT risks, maintain operational resilience, and conduct risk-based Information Systems Audits. It even notes that organizations may consider continuous auditing for critical systems.
For non-bank Payment System Operators, RBI’s 2024 Master Directions go into even more operational detail.
They address:
Inventory Management → IAM → Network Security → Application Security → Security Testing → Vendor Risk → Data Security → Patch Management → Incident Response → BCP → APIs → Cloud Security → Digital Payment Security.
What Does This Mean for Fintechs?
It means security cannot stop at:
“We have a policy for that.”
The question increasingly becomes:
“Show me how the control is implemented, configured, monitored, tested, and evidenced.”
And this is where many organizations discover gaps.
SEBI CSCRF Raises the Bar for Securities-Focused Fintechs
Fintechs operating in the securities ecosystem face another significant development. SEBI’s Cybersecurity and Cyber Resilience Framework (CSCRF) establishes cybersecurity and resilience expectations for applicable SEBI-regulated entities. The framework covers areas including:
- Governance and CISO responsibilities
- Critical asset identification
- Asset inventory
- VAPT
- Patch management
- Cyber audits
- Cyber Capability Index
- SBOM
- Outsourcing
- Cloud services
- COTS product testing
- Log management
- Data security
- SOC and security monitoring
SEBI’s framework also explicitly addresses cybersecurity audit, configuration audit, implementation audit, change-management audit, and VAPT.
The message is clear:
Cybersecurity is not just about owning security tools. It is about demonstrating that those tools and controls are correctly implemented and functioning as intended.
Bank Audits Are Becoming Another Security Pressure Point
A fintech may not always be directly regulated by RBI or SEBI. That does not mean it escapes the security expectations of the financial ecosystem.
If a fintech provides technology, APIs, SaaS, payment infrastructure, lending infrastructure, KYC services, cloud services, or other technology to a bank or financial institution, the organization may face customer-led security assessments and audits. Banks and financial institutions may evaluate areas such as:
- Information security governance
- Access control
- Privileged access
- Vulnerability management
- Penetration testing
- Patch management
- Endpoint security
- Data protection
- DLP
- EDR
- SIEM
- Logging and monitoring
- Incident response
- Business continuity
- Disaster recovery
- Cloud security
- Third-party risk
- Security policies and evidence
This creates an uncomfortable reality for fintechs:
Your biggest cybersecurity assessment may come from your customer before it comes from your regulator.
A bank may ask for evidence.
A large enterprise customer may demand a security assessment.
A partner may require VAPT results.
A procurement team may ask for audit reports.
And suddenly, weaknesses in security-tool configuration or operational processes become business blockers.
Operational Security Testing: Where the Real Gaps Surface
This is where fintech security programs need to go beyond traditional compliance assessments. Operational security testing examines whether security controls are actually implemented and operating effectively.
For example:
MDM
- Are corporate and mobile devices enrolled?
- Are security policies enforced?
- Are unauthorized devices blocked?
- Are encryption and screen-lock controls enforced?
- Can lost or compromised devices be remotely managed?
DLP
- Are sensitive data repositories identified?
- Are DLP policies correctly configured?
- Are sensitive files being detected?
- Are policies preventing or alerting on unauthorized transfers?
- Are exceptions controlled?
EDR
- Are all relevant endpoints covered?
- Are agents healthy?
- Are policies appropriately configured?
- Are detections being generated?
- Are alerts being investigated?
- Can compromised endpoints be isolated?
SIEM
- Are critical logs actually reaching the SIEM?
- Are authentication, endpoint, firewall, application, cloud, and privileged-access events being collected?
- Are correlation rules working?
- Are alerts being monitored?
- Are logs retained according to requirements?
- Can the organization reconstruct an incident from available evidence?
IAM and Privileged Access
- Are privileged accounts identified?
- Is MFA enforced?
- Are excessive privileges removed?
- Are dormant accounts disabled?
- Are access reviews performed?
Vulnerability Management
- Are critical assets included in scans?
- Are vulnerabilities prioritized based on business risk?
- Are remediation timelines being followed?
- Are exceptions documented and approved?
This is the difference between having cybersecurity controls and having effective cybersecurity controls.
How Accorian Helps Fintechs Validate Operational Security
Accorian’s cybersecurity experts and vCISOs can assess the actual operating effectiveness of a fintech’s security environment, not just whether policies exist.
Our assessments can include reviews of:
- MDM configuration: Device enrollment, policy enforcement, encryption, access restrictions, compliance posture, and device-management controls.
- DLP configuration: Data classification, policy configuration, detection mechanisms, alerting, blocking, exceptions, and sensitive-data protection.
- EDR configuration: Endpoint coverage, agent health, policy settings, detection capabilities, alert handling, response actions, and isolation capabilities.
- SIEM configuration: Log sources, ingestion, correlation rules, alerting, monitoring, retention, use cases, and incident investigation capabilities.
- IAM and privileged access: MFA, access controls, privileged accounts, role assignments, dormant accounts, and access-review processes.
- Security infrastructure: Firewalls, network segmentation, secure configurations, remote access, and other critical security controls.
The assessment can then identify:
Configured correctly → Configured incorrectly → Missing → Ineffective → Not evidenced
This gives leadership a much more realistic picture of the organization’s cyber posture.
DPDPA Adds Another Layer of Risk
Security and privacy are increasingly connected. Fintechs process sensitive personal information through:
KYC → Onboarding → Lending → Payments → Fraud Detection → Customer Service → Account Management
The Digital Personal Data Protection Act, 2023, and the Digital Personal Data Protection Rules, 2025, establish India’s evolving framework for processing and protecting digital personal data. For fintechs, this means understanding:
- What personal data is collected
- Why it is collected
- Where it is stored
- How it moves
- Who can access it
- Which third parties process it
- How it is protected
- How retention and deletion are managed
- How incidents involving personal data are handled
How Accorian Helps With DPDPA Readiness
Accorian helps fintechs translate privacy requirements into practical operational controls. Our approach can include:
- DPDPA readiness and gap assessments
- Data-flow assessments
- Data processing reviews
- Privacy and security control assessments
- Third-party data-access reviews
- Data protection assessments
- Incident and breach-readiness reviews
- Security testing of systems processing sensitive data
- Alignment with broader security and privacy frameworks
The objective is to connect what the privacy program says with what the technology actually does.
Frameworks Fintechs Should Be Looking At
There is no single framework that covers every fintech. The right combination depends on the organization’s business model, regulatory status, technology environment, customers, and data. Depending on the organization, the security program may need to consider:
RBI
- RBI Cyber Security Framework
- RBI IT Governance, Risk, Controls and Assurance Practices
- RBI IT Outsourcing requirements
- RBI Cyber Resilience and Digital Payment Security Controls for non-bank PSOs
- Applicable Information Systems Audit requirements
SEBI
- SEBI Cybersecurity and Cyber Resilience Framework
- VAPT requirements
- Cyber audit
- SOC and logging
- Cloud and outsourcing requirements
Privacy and Data Protection
- DPDPA
- Digital Personal Data Protection Rules
- Applicable contractual and customer data-protection requirements
Industry and Security Standards
Depending on the fintech’s business and customers:
The goal should not be to collect frameworks. The goal should be to build one security program that satisfies multiple applicable requirements without creating duplicated work.
AI Creates Yet Another Security Layer
AI is rapidly moving into fraud detection, underwriting, customer service, risk analysis, compliance, and financial decision-making. Agentic AI introduces additional risk because systems can potentially:
Access data → Invoke APIs → Interact with applications → Execute actions
Fintechs therefore need to ask:
- What can the AI access?
- What can it change?
- What permissions does it have?
- Can prompts manipulate its behavior?
- Can sensitive data leak through inputs or outputs?
- Can an AI vendor access customer information?
- Are consequential actions subject to human approval?
- Can AI activity be logged and investigated?
How Accorian Helps Secure AI
Accorian can assess AI applications, LLMs, agents, integrations, and governance controls for risks including:
- Prompt injection
- Data leakage
- Excessive permissions
- Insecure integrations
- AI application vulnerabilities
- Third-party AI risk
- Model misuse
- Inadequate monitoring
- Governance gaps
Accorian can also support AI risk assessments, AI red teaming, AI governance, ISO 42001 advisory, and NIST AI RMF alignment. The objective is not to slow AI adoption. It is to make AI adoption defensible.
Third-Party Risk Is Now a Core Fintech Security Issue
Fintechs rarely operate alone. Their ecosystems may include:
Banks → Payment processors → Cloud providers → KYC vendors → SaaS platforms → AI providers → APIs → Data processors
One weak third party can create risk across the entire chain. RBI’s PSO framework specifically addresses risks arising from linkages with unregulated entities such as payment gateways, third-party service providers, and vendors.
How Accorian Helps
Accorian helps organizations establish risk-based TPRM programs covering:
Vendor onboarding → Classification → Security assessment → Risk scoring → Remediation → Continuous monitoring
GORICO can help centralize vendor information, assessments, evidence, risks, and remediation activities.
The goal is simple:
Your third-party ecosystem should not become your biggest security blind spot.
From Compliance Readiness to Continuous Security Assurance
The biggest challenge for fintech security teams is no longer just passing an assessment.
It is staying ready.
A fintech may complete a VAPT today. Six months later:
- A new API has been deployed.
- A cloud environment has changed.
- A new vendor has been onboarded.
- An endpoint policy has changed.
- A SIEM rule has stopped working.
- A new vulnerability has emerged.
- A new AI application has entered production.
The security posture has changed. This is why fintechs need continuous assurance.
How GORICO Helps
GORICO Accorian’s AI-enabled GRC tool, can centralize:
- Controls
- Evidence
- Risk assessments
- Compliance requirements
- Remediation
- Third-party risk
- Security workflows
- Continuous readiness activities
Instead of managing multiple frameworks through disconnected spreadsheets and evidence folders, organizations can create a centralized view of what controls exist, what evidence supports them, where risks remain, and what needs remediation.
Compliance becomes an ongoing security process, not an annual fire drill.
What Should Fintechs Do Now?
Fintech leaders should not wait for the next regulatory assessment or bank audit. Start with these seven actions:
1. Determine Which Requirements Apply: Map your regulatory status, customers, services, data, and technology dependencies against applicable RBI, SEBI, DPDPA, PCI DSS, ISO, SOC 2, and other requirements.
2. Perform a Cybersecurity Gap Assessment: Identify gaps across governance, technology, people, processes, third parties, and resilience.
3. Conduct Operational Security Testing: Do not only review policies. Test the configuration and effectiveness of MDM, DLP, EDR, SIEM, IAM, firewalls, logging, vulnerability management, and other critical security controls.
4. Test the Attack Surface: Perform VAPT, API testing, application testing, mobile testing, cloud assessments, and red teaming where appropriate.
5. Validate Resilience: Test incident response, backup recovery, disaster recovery, business continuity, and cyber-crisis processes.
6. Strengthen Third-Party Risk: Assess critical vendors and technology dependencies based on access, data, business impact, and regulatory exposure.
7. Build Continuous Assurance: Centralize evidence, controls, risks, remediation, and monitoring so the organization is always ready, not just audit-ready.
How Accorian Helps Fintechs Build a Defensible Security Program
Accorian brings together cybersecurity assessments, operational security validation, regulatory readiness, vCISO expertise, and continuous GRC.
- RBI & Regulatory Readiness: Accorian can assess applicable RBI cybersecurity, IT governance, technology-risk, resilience, and assurance requirements and identify gaps that need remediation.
- SEBI CSCRF Readiness: For applicable SEBI-regulated organizations, Accorian can support VAPT, cyber audit readiness, configuration assessment, implementation reviews, logging and monitoring assessments, cloud security, and other CSCRF-related controls.
- Bank & Customer Security Audits: Accorian can help fintechs prepare for security assessments conducted by banks and enterprise customers by validating controls and evidence before the customer asks for them.
- Operational Security Testing: Accorian’s vCISOs can review whether critical security technologies are implemented, configured, monitored, and operating effectively, including MDM, DLP, EDR, SIEM, IAM, Firewalls, Vulnerability Management, Logging & Monitoring
- Application & API Security: Accorian performs expert-led penetration testing across applications, APIs, mobile applications, infrastructure, and other critical environments.
- Cloud Security: Assess cloud configurations, access controls, exposed services, identities, workloads, and security architecture.
- AI Security: Assess AI applications, agents, integrations, data exposure, permissions, prompt injection, and AI governance.
- DPDPA Readiness: Assess personal-data processing, data flows, safeguards, third-party access, and privacy-security controls.
- Third-Party Risk Management: Establish risk-based vendor assessment, remediation, and continuous monitoring.
- vCISO Advisory: Accorian’s vCISOs can provide strategic cybersecurity leadership across governance, regulatory readiness, security architecture, technology controls, risk management, audits, incident preparedness, and continuous improvement.
- Continuous GRC Through GORICO: GORICO brings controls, evidence, risks, assessments, remediation, and compliance workflows into one environment to help organizations maintain continuous readiness.
The Real Fintech Cybersecurity Question for 2026
The fintech industry is entering a phase where having cybersecurity controls is no longer enough. Organizations need to demonstrate that those controls:
Exist → Are configured correctly → Are monitored → Are tested → Generate evidence → Improve over time
A fintech can have an EDR solution and still have unprotected endpoints.
- It can have a SIEM and still fail to collect critical logs.
- It can have DLP and still have sensitive data leaving through unmanaged channels.
- It can have MDM and still have non-compliant devices.
- It can have a vulnerability-management program and still have critical vulnerabilities sitting unresolved.
- It can have an incident-response plan that has never been tested.
That is the gap between compliance on paper and operational security in practice. And that gap is exactly where regulators, banks, enterprise customers, auditors, and attackers are increasingly looking.
The Time to Find Those Gaps Is Before Someone Else Does
India’s fintech opportunity is enormous. But the companies that win the next phase of growth will not simply be those that innovate faster. They will be the companies that can demonstrate:
- Secure technology
- Protected data
- Resilient operations
- Governed AI
- Trusted partners
- Tested controls
Because the next competitive advantage in fintech will not just be innovation at scale. It will be trust that can be proven.
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Frequently Asked Questions
- What is the RBI Cyber Security Framework?
The RBI Cyber Security Framework established cybersecurity governance and risk-management expectations for banks. RBI has subsequently consolidated and expanded technology governance, risk, controls, assurance, business continuity, and Information Systems Audit requirements through its 2023 IT Governance Directions.
- Does RBI cybersecurity regulation apply to fintech companies?
Not uniformly. Applicability depends on the fintech’s regulatory classification and activities. Banks, NBFCs, payment system operators, and other regulated entities may be subject to different RBI requirements. Fintechs serving regulated entities can also face security requirements through customer and third-party assessments.
- What is RBI’s 2023 IT Governance framework?
RBI’s Information Technology Governance, Risk, Controls and Assurance Practices Directions, 2023 establish requirements around IT governance, cybersecurity, IT risk, third-party arrangements, business continuity, disaster recovery, and Information Systems Audit for applicable regulated entities.
- What is SEBI CSCRF?
SEBI’s Cybersecurity and Cyber Resilience Framework establishes cybersecurity and resilience requirements for applicable SEBI-regulated entities, including areas such as VAPT, cyber audits, asset management, patching, SOC, logging, cloud, outsourcing, and data security.
- What is operational security testing?
Operational security testing evaluates whether security controls are actually implemented and functioning effectively. It can include reviewing MDM, DLP, EDR, SIEM, IAM, firewalls, logging, vulnerability management, and other security technologies.
- Why should fintechs review EDR configuration?
Having an EDR platform does not automatically mean endpoints are protected. Organizations should validate endpoint coverage, agent health, policy configuration, detections, alert handling, and response capabilities.
- Why is SIEM configuration important for fintechs?
A SIEM is only useful when critical logs are correctly collected, retained, correlated, monitored, and investigated. Configuration reviews can identify missing log sources, ineffective detection rules, retention gaps, and monitoring weaknesses.
- Why is DLP important for fintechs?
Fintechs process sensitive financial and personal information. DLP helps organizations identify and control inappropriate movement or disclosure of sensitive data across endpoints, networks, applications, and other channels.
- What security audits can fintechs face?
Depending on their business and relationships, fintechs may face regulatory assessments, Information Systems Audits, SEBI cyber audits, bank or financial-institution vendor audits, customer security assessments, contractual assessments, and independent security testing.
- What frameworks should fintechs consider?
Depending on their business model and obligations, fintechs may need to consider RBI requirements, SEBI CSCRF, DPDPA, PCI DSS, ISO 27001, ISO 27701, SOC 2, NIST CSF, CIS Controls, NIST AI RMF, and ISO 42001.
- How can Accorian help with RBI and SEBI cybersecurity requirements?
Accorian can support regulatory readiness through gap assessments, VAPT, cyber audit readiness, configuration and implementation assessments, security-control validation, cloud security, third-party risk assessments, operational security reviews, and vCISO advisory.
- How can Accorian’s vCISOs help fintechs?
Accorian’s vCISOs can evaluate cybersecurity governance and operational controls, including MDM, DLP, EDR, SIEM, IAM, vulnerability management, logging, incident response, resilience, third-party risk, and security policies, while helping leadership prioritize remediation.
- How can GORICO help fintechs?
GORICO can centralize controls, evidence, risks, assessments, remediation, third-party risk, and compliance workflows, helping fintechs move from fragmented, point-in-time compliance toward continuous security and compliance readiness.
- How can fintechs prepare for bank security audits?
Fintechs should perform a proactive security and control assessment, validate technology configurations, conduct VAPT, review policies and evidence, assess third-party risk, test incident response, and identify gaps before the bank or enterprise customer begins its assessment.
- How can Accorian help fintech companies in India?
Accorian helps fintechs strengthen cybersecurity and compliance through RBI and SEBI readiness, VAPT, cyber audits, operational security testing, application and API security, cloud assessments, AI security, DPDPA readiness, TPRM, vCISO advisory, and continuous GRC through GORICO.
