Decoding SEBI CSCRF: A Guide (Part 2)

SEBI CSCRF GV.RR Explained: Roles, Responsibilities & Authorities for Cyber Resilience

Building on our fortress foundation from Part 1, we now equip the guards with clear orders.

⚔️ The Battle for Cyber Resilience

Imagine waking up to news that your organization’s sensitive data has been breached, with attackers demanding a ransom. In the chaos, fingers are pointed, but no one knows who was truly responsible for what. This scenario is all too real in today’s cyber landscape hence Having a clear chain of command isn’t just beneficial; it’s essential. I’m here to unpack why GV.RR is critical, how it works, and what it means for your organization. Let below statement sink in.

“To build a truly secure organization, every individual’s role, responsibility, and authority must be communicated clearly—and understood by everyone”

🛡️ The Essence of GV.RR in Cybersecurity

Imagine your organization as a fortress. You've built strong walls (your cybersecurity controls), installed sophisticated alarms (threat detection systems), and placed sentries (security teams) at each entry point. But ask yourself:

• Who commands these guards?
• Who authorizes reinforcements?
• Who takes responsibility when breaches occur?

Without clear answers, your fortress is vulnerable—no matter how advanced your defenses appear.

This is exactly what GV.RR addresses. The core objective of GV.RR is:

“Cybersecurity roles, responsibilities, and authorities to foster accountability, performance assessment, and continuous improvement are established and communicated.”

In simpler terms:

• Define who decides, who does, and who reports.
• Why it’s important: It builds accountability (“I own this”), enables performance tracking (“Are we meeting our goals?”), and drives a culture of continuous security improvement.

📌Clarifying Core Terms

Let’s clear up two crucial—but often confused—terms in security. They’re not interchangeable when protecting an organization i.e Accountability & Responsibility

CSCRF assumes organizations understand these terms, yet confusion persists. SEBI CSCRF does not explicitly define them, so we rely on industry best practices

• Responsibility is about the tasks you perform—and you can hand those tasks off to someone else.
• Accountability is about the outcome you answer for—and that never transfers, no matter who does the work.
• Authority is Formal right to make decisions, allocate resources, or enforce policies.

🔍 Deep Dive: Decoding GV.RR Standards

1. GV.RR.S1: Leadership Accountability

• What It Says: " Leadership is responsible and accountable for cybersecurity risk and must foster a risk-aware, cybersecurity-conscious culture"
• What It Means: Leaders own cyber-risk outcomes and promote a security-first mindset.
• Why It’s Important: Ensures security is a board-level priority, aligning funding and strategy.

Let’s unpack this further. One of the key lessons the cybersecurity industry has learned over time is that security can only succeed when it aligns with an organization’s strategic goals and objectives. At the heart of this alignment lies accountability. In any enterprise, accountability for cybersecurity—and by extension, for protecting organizational value—rests with the board of directors and the CEO. Their core responsibility is to safeguard and grow the organization's value.

But who truly owns security? While the CEO cannot personally manage every asset across a complex enterprise, ultimate accountability still remains at the top. In practice, this is distributed:

• The board and CEO retain overall accountability for cybersecurity posture.
• Senior leaders are accountable for the specific assets and operations under their purview (e.g., the VP of Finance is accountable for the financial systems).

This layered accountability ensures that security ownership is embedded across the leadership landscape—not isolated at the top

2.GV.RR.S2: Defined Roles and Responsibilities

• What It Says: Cybersecurity roles, responsibilities, and authorities must be developed, communicated, understood, and enforced.
• What It Means: Every security role and its duties must be documented and known.
• Why It’s Important: Eliminates blind spots, ensuring everyone knows their responsibilities.

Example: A RACI matrix can clarify who handles incident response versus vulnerability management, preventing overlaps or gaps. Let’s explore this standard a bit further.

Most security professionals will agree— we have long emphasized that “security is everyone’s responsibility.” And while that’s absolutely true, the way this message is delivered makes all the difference.

Too often, this message originates solely from the security team, which limits its effectiveness. For security to truly become part of the organizational culture, it must be championed by upper management—ideally by the CEO or the board of directors. When leadership consistently reinforces this principle, it sets the tone across the enterprise and embeds security into daily operations.

Imagine the cultural shift if the CEO regularly stated that security is a shared responsibility. The message would carry far more weight—and more importantly, it would stick.

That said, while responsibility can be shared, accountability cannot be delegated. Those at the top—executive leadership—remain ultimately accountable for the organization’s security outcomes. And that distinction is not just important—it’s foundational to effective governance and long-term resilience.

3. GV.RR.S3: Designated Security Authority

• What It Says: A CISO or designated officer must be appointed and report to a designated authority (e.g., board or CEO).
• What It Means: A named security leader with direct executive access is required.
• Why It’s Important: Ensures security is strategic, with clear leadership and accountability.

SEBI’s decision to include a dedicated standard for appointing a CISO isn’t arbitrary—it’s a strategic move grounded in years of industry insight. Let’s unpack why this matters. Mandating the appointment of a CISO is SEBI’s way of ensuring that cybersecurity is led by an empowered, independent authority. Defining roles alone isn’t enough—without this requirement, security leaders can be sidelined by broader IT agendas, their warnings overlooked, and their accountability blurred.By requiring the CISO to report directly to the board or CEO, SEBI guarantees that cybersecurity holds a strategic seat at the table. This structure ensures:

• An Independent Voice: The CISO operates beyond the boundaries of IT, allowing security priorities to stand apart from infrastructure pressures.
• Unfiltered Executive Access: Direct reporting channels ensure that critical risks reach senior leadership without delay or dilution.
• Clear Accountability: The CISO’s performance is visible at the highest level, reinforcing security as a business-critical function.
• Effective Resource Advocacy: With board-level visibility, the CISO can champion funding and resources aligned with real threats—not just IT wish lists.
• Strategic Business Integration: Sitting alongside other C-suite leaders, the CISO weaves cybersecurity into enterprise-wide decisions, from digital transformation to regulatory compliance.

In short, cybersecurity must report directly to the CEO or board—not to the CIO or CTO.

4. GV.RR.S4: Budgetary Alignment

• What It Says: "Budgeting must align with security objectives, allocating resources based on risk strategy."

GV.RR.S4 makes it clear: your cybersecurity budget must not be an afterthought. It should directly reflect your security and privacy objectives, with funding decisions driven by real, documented risks—not by outdated IT wish lists. This approach promotes transparency and accountability. Executives can clearly trace every security dollar to a specific control, compliance mandate, or known vulnerability.

By aligning budgets with risk strategy, you avoid the reactive “band-aid” fixes that undermine long-term resilience. Instead, you enable sustained investment—supporting both daily operations and forward-looking initiatives. With the board and CEO maintaining visibility over security spending, controls can evolve in step with an ever-changing threat landscape—never falling behind due to underfunding.

5. GV.RR.S5: Access Agreements

• What It Says: Employees and third-party providers must sign confidentiality and integrity agreements before accessing systems.
• What It Means: Only vetted individuals with clear obligations can access systems.
• Why It’s Important: Reduces insider risk and provides legal protection.

Before granting system access to any employee or third-party vendor, a signed confidentiality and integrity agreement is essential. This isn’t just a formality—it sets clear expectations, reinforces accountability, and provides legal recourse in the event of misuse.

By formalizing these obligations from day one, organizations establish a strong foundation of trust, clarity, and enforceability—ensuring that everyone who interacts with sensitive systems understands their responsibilities without ambiguity.

6. GV.RR.S6: Cybersecurity in HR Training

• What It Says: Cybersecurity must be included in HR training programs.
• What It Means: Regular, role-specific security training is embedded in employee development.
• Why It’s Important: Builds a security-aware workforce, reducing human error.

We’ve already established that security is everyone’s responsibility—but simply saying it isn’t enough.

Security awareness isn’t a one-time presentation or a checkbox exercise. It must be embedded into every stage of HR training. Regular, role-specific sessions equip employees to recognize risks, respond appropriately, and reinforce secure behavior as second nature.

When training is continuous and contextual, security becomes a habit—not a reminder. That’s how awareness evolves into real, organization-wide resilience.

🔗 Putting It All Together: Cyber Resilience Goals – Anticipate & Evolve

By embedding clear Roles, Responsibilities & Authorities (GV.RR), you directly reinforce two of SEBI CSCRF’s most vital goals:

🔍 Anticipate – Spot threats before they materialize:

🔑 GV.RR.S1 – Leadership Accountability When executives own cyber-risk outcomes, they set a proactive tone—prioritizing early detection over reactive firefighting.

⚔️ GV.RR.S2 – Defined Roles Well-documented duties ensure every team member understands their monitoring and reporting responsibilities—minimizing blind spots.

🛡️ GV.RR.S3 – Designated Authority A CISO with board access can escalate emerging risks immediately, preventing small issues from snowballing into major incidents.

🔁 Evolve – Adapt and improve continuously:

💰 GV.RR.S4 – Budget Alignment Risk-based funding ensures you can invest in next-gen tools and defenses as threat landscapes shift.

🤝 GV.RR.S5 – Access Agreements Enforceable user/vendor pledges create strong accountability loops—driving clarity and prompt anomaly reporting.

📚 GV.RR.S6 – Embedded Training Ongoing, role-specific education helps teams internalize lessons from incidents, fostering a culture of continuous learning and adaptive resilience.

✅ Master GV.RR, and you go beyond checking the SEBI compliance box—you build an organization that can foresee threats and continuously evolve faster than attackers.

📅 What’s Next? In Part 3, we’ll explore the next two pillars of SEBI’s CSCRF: Policy (GV.PO) and Oversight (GV.OV)—and unpack why they’re critical to sustainable cyber resilience.

Thank you for reading! 🙏 I’d love to hear your thoughts—please share any feedback or questions in the comments.

If you haven’t already, check out Part 1 for the full context: https://www.linkedin.com/pulse/decoding-sebi-cscrf-guide-part-1-eknath-thakur-routf/