Skip to content
Funds

SaaS-Based Solutions — SEBI's Advisory for Financial Sector Organisations Explained

SEBI has issued an advisory for financial sector organisations regarding Software as a Service (SaaS) based solutions, emphasising the need for complete protection and seamless control over critical systems. This article explains the advisory and the compliance requirements.

23 Jul 20263 min read

SaaS-Based Solutions — SEBI's Advisory for Financial Sector Organisations Explained

SEBI has issued an advisory for financial sector organisations regarding Software as a Service (SaaS) based solutions, emphasising the need for complete protection and seamless control over critical systems. The advisory, issued through SEBI Circular SEBI/HO/MIRSD2/DOR/CIR/P/2020/221 dated November 3, 2020, was based on an advisory from the Indian Computer Emergency Response Team (CERT-In). This article explains the advisory and the compliance requirements.

The Regulatory Basis

The Ministry of Electronics & Information Technology, Government of India (MoE&IT) issued an advisory for Financial Sector organizations to improve their cyber Security Posture by availing Software as a Service (SaaS) based solution for managing their Governance, Risk & Compliance (GRC) functions. The advisory was forwarded to SEBI for bringing the same to the notice of financial sector organization.

Key Requirements of the Advisory

Complete Protection

Stock brokers are advised to ensure complete protection over the critical systems at their organizations. This includes:

  • Continuous Monitoring: Through direct control and supervision protocol mechanisms.
  • Data Security: Keeping the critical data within the legal boundary of India.
  • Seamless Control: Ensuring seamless control over critical systems at all times.

Critical Data Protection

The advisory emphasises that critical data should be kept within the legal boundary of India. This means that:

  • Data should not be stored or processed outside India.
  • Data should be subject to Indian laws and regulations.
  • Data should be accessible to Indian regulatory authorities.

Compliance Requirement

The compliance of the advisory shall be reported in the half yearly report by stock brokers to stock exchanges with an undertaking:

"Compliance of the SEBI circular for Advisory for Financial Sector Organizations regarding Software as a Service (SaaS) based solutions has been made."

Why the Advisory Matters

Increasing Cyber Threats

Financial sector organizations are increasingly targeted by cyber-attacks. SaaS-based solutions, while offering benefits, also introduce new risks if not properly managed.

Data Localisation

Keeping critical data within India ensures that it is subject to Indian laws and regulations, and accessible to Indian regulatory authorities.

Regulatory Oversight

The advisory ensures that financial sector organizations maintain adequate oversight over their SaaS-based solutions, even when the solutions are provided by third-party vendors.

How We Help

At Anuj Desai & Associates, we help stock brokers and other financial sector organisations understand and comply with the SaaS advisory, implement appropriate controls, and report compliance to stock exchanges. If you need assistance with SaaS compliance, reach out to our regulatory compliance desk.

SEBI SaaS advisorySEBI SaaS guidelinesSaaS compliance IndiaSoftware as a Service SEBISEBI HO MIRSD2 DOR CIR P 2020 221SEBI circular November 3 2020SaaS advisory for financial sector organisationsfinancial sector SaaS advisoryCERT-In SaaS advisoryCERT-In guidelines SaaScyber security advisory SEBISaaS governanceSaaS risk managementSaaS compliance frameworkSaaS security complianceSaaS security IndiaSaaS cybersecuritySaaS governance risk and complianceGRC SaaS solutionsGovernance Risk and Compliance softwareGRC compliance Indiacloud governance SEBIcloud compliance for stock brokersstock broker SaaS compliancestock broker cyber securitystock broker technology complianceSEBI regulated entitiesSEBI compliance for brokerscybersecurity compliance Indiacyber resilience frameworkcyber security policycyber resilience for stock brokersfinancial services cybersecurityfinancial sector cyber securityfinancial sector complianceSaaS vendor risk managementSaaS vendor due diligenceSaaS third party riskthird party technology riskoutsourcing compliance SEBItechnology outsourcing compliancecloud data localisation IndiaSEBI data localisationIndia data residencycritical data protectioncritical systems protectiondata protection Indiafinancial data securitycloud security compliancecloud security Indiacloud regulatory compliancecloud governance frameworkcloud risk assessmentcloud monitoringcontinuous monitoring cyber securitycyber risk managementcyber compliance checklistIT governance SEBIIT governance for brokerscyber governance frameworkSaaS controlsSaaS auditSaaS audit checklistSaaS compliance checklistSaaS implementation complianceSaaS vendor assessmentSaaS regulatory requirementsSaaS legal complianceSaaS policySaaS compliance reportinghalf yearly compliance reportstock exchange compliance reportingSEBI reporting requirementscompliance undertaking SEBIcyber audit compliancecyber security auditinformation security complianceinformation security frameworkcloud security best practicesgovernance risk compliance softwaremanaged GRC solutionscyber security for financial institutionstechnology risk managementoperational resiliencedigital risk managementregulatory technology IndiaRegTech complianceSEBI cyber advisoryMinistry of Electronics and Information TechnologyMeitY cyber advisoryIndian Computer Emergency Response TeamCERT-In complianceCERT-In guidelines for financial sectorsoftware compliance Indiacloud adoption complianceSaaS risk assessmentcloud vendor governancecyber security controlstechnology controls for brokersfinancial sector IT compliancestock broker compliancesecurities market compliancesecurities law compliancecompliance consulting Indiaregulatory advisorycyber compliance advisorycloud advisorySaaS advisory IndiaAnuj Desai & AssociatesSEBI Master Circular Stock Brokerscyber resilience compliancecyber governance Indiasoftware risk managementfinancial technology complianceIT compliance for regulated entitiesdigital infrastructure complianceIndia financial regulationscyber security obligationsSaaS data securitySaaS data localisationSaaS regulatory frameworkcyber compliance for stock brokerscloud and SaaS compliancetechnology compliance consultantSEBI technology regulationsfinancial services technology riskcyber risk assessmentIT risk managemententerprise cyber governancecloud security for financial servicesSaaS governance frameworksoftware as a service complianceIndian securities regulationsregulatory compliance India
Share

Related insights

Work with ADA

Ready to talk to an advisor?

Book a consultation and get a clear, considered view from a team that handles audit, tax, regulatory and cross-border work under one roof.