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Navigating Cloud Adoption for SEBI-Regulated Entities in India

By Shamanth K posted Thu January 22, 2026 07:12 AM

  

Introduction 

India’s capital markets are undergoing rapid digital transformation, and cloud computing is at the heart of this evolution. However, for entities regulated by the Securities and Exchange Board of India (SEBI), cloud adoption must be carefully aligned with stringent compliance mandates. 

Regulated Entities (REs) include: 

  • Market Infrastructure Institutions (MIIs) such as stock exchanges, depositories, and clearing corporations. 
  • Intermediaries such as Merchant Bankers, Mutual Funds and AMCs, Credit Rating Agencies, Research Analysts etc. 

IBM Cloud stands out as a strategic partner, offering AI-powered, secure, and compliant cloud solutions tailored for SEBI-regulated entities. With deep regulatory alignment, hybrid cloud flexibility, and support for India’s data sovereignty laws, IBM Cloud enables innovation without compromising compliance.

SEBI’s Regulatory Frameworks for Cloud Adoption 

SEBI has issued two cornerstone frameworks that govern how regulated entities (REs) can adopt cloud services while maintaining cybersecurity and operational resilience:  

This framework applies to all SEBI-regulated entities, including MIIs, stock exchanges, depositories, and intermediaries. It mandates a comprehensive cybersecurity posture with the following key requirements: 

  • Inventory and Classification of critical and non-critical systems
  • Vulnerability Assessment and Penetration Testing (VAPT) with defined frequency
  • Software Bill of Materials (SBOM) for all critical applications
  • Threat Intelligence Sharing and integration with Market-SOC (M-SOC)
  • Disaster Recovery (DC-DR) Drills and business continuity planning \
  • CISO Governance: The Chief Information Security Officer must report directly to the MD/CEO
  • Incident Response and Recovery protocols with defined SLAs
  • ISO 27001 Certification is encouraged for alignment with global standards. 

This framework provides specific guidance for cloud adoption by SEBI REs, focusing on: 

  • Data Classification: Segregation of sensitive and non-sensitive data
  • Encryption: Mandatory for data at rest and in transit
  • Vendor Risk Management: Due diligence, SLAs, and exit strategies
  • Auditability: Cloud providers must support traceability and log retention
  • Data Residency: Sensitive data must reside within India
  • Cloud Governance: Defined roles, responsibilities, and approval processes.
  • Business Continuity Planning (BCP), Disaster Recovery & Cyber Resilience
  • Concentration Risk Management (Explore Multi Cloud solutions)   

How IBM Cloud helps Regulated entities meet SEBI requirements

IBM Cloud is designed to support organizations operating in highly regulated environments by providing foundational cloud capabilities that emphasize security, governance, and operational oversight. Rather than offering regulator-specific compliance solutions, IBM Cloud focuses on embedding security and governance capabilities directly into the cloud platform, enabling organizations to design and operate architectures aligned with applicable regulatory principles and risk management expectations. 

For financial services workloads, IBM Cloud offers IBM Cloud for Financial Services, an industry-specific cloud environment built on IBM Cloud infrastructure. This offering is underpinned by the IBM Cloud Framework for Financial Services, a standardized control framework developed in collaboration with global financial institutions and industry risk experts. The framework establishes baseline security and risk controls intended to support sensitive and regulated workloads. 

The controls defined within the IBM Cloud Framework for Financial Services are derived from widely recognized industry standards, including NIST SP 800-53, and are mapped to the Cloud Security Alliance (CSA) Cloud Controls Matrix (CCM). This alignment allows organizations to adopt cloud services using familiar control structures and governance models, supporting consistency across hybrid and multi-cloud environments. 

IBM Cloud also provides integrated security and compliance tooling such as the IBM Cloud Security and Compliance Center Workload Protection, which enables organizations to monitor security posture, assess configuration compliance, and collect evidence across cloud workloads. These capabilities support continuous oversight and reporting, aligning with regulatory expectations for ongoing governance, audit readiness, and operational resilience rather than one-time compliance assessments. 

In addition, IBM Cloud supports hybrid and multi-cloud deployment models through technologies such as Red Hat OpenShift, enabling organizations to deploy and manage workloads across on-premises, cloud, and edge environments. This architectural flexibility allows regulated entities to make informed decisions based on workload sensitivity, resilience requirements, and data governance considerations, including data residency and business continuity planning. 

Taken together, these capabilities provide regulated entities with a cloud foundation that supports governance, security, and operational controls. While regulatory compliance remains the responsibility of each regulated entity, IBM Cloud offers technical capabilities and industry-aligned frameworks that organizations can leverage when designing cloud environments aligned with regulatory expectations such as those outlined by SEBI. 

Architectural Foundation for Regulatory Alignment 

The IBM Cloud Framework for Financial Services is built on widely recognized security practices and control frameworks used across the financial services industry. The controls in the framework are developed in collaboration with industry experts and, as documented by IBM, are aligned with industry standards and mapped to the Cloud Security Alliance (CSA) Cloud Controls Matrix (CCM) to help organizations implement consistent governance and security controls across cloud workloads. These control alignments draw from established frameworks such as NIST SP 800-53, providing a structured basis for risk and security control implementation that organizations can reference in their architectures. 

By embedding these controls into cloud services and operational processes, IBM Cloud offers capabilities that support ongoing oversight of workload security and configuration. IBM’s security and compliance tooling — including services such as the IBM Cloud Security and Compliance Center Workload Protection — is designed to help organizations continuously monitor and assess cloud environments against defined controls, detect configuration drift, and collect evidence of compliance posture over time. While regulatory compliance remains the responsibility of each organization, these capabilities provide mechanisms to support resilience testing and audit readiness across hybrid and cloud environments. 

This architectural approach also supports security capabilities such as identity and access management, segregation of duties, and comprehensive logging and policy-based governance across cloud resources. These are design considerations that regulated entities often incorporate into their internal compliance, cybersecurity, and risk management frameworks, including for regulated market infrastructure and financial systems. 

Data Sovereignty, Localization, and India-Specific Considerations 

Data sovereignty and localization have become central themes in India’s regulatory and policy environment for digital services and cloud computing. While SEBI’s cloud adoption frameworks emphasize governance, operational resilience, and data protection, broader Indian policy initiatives — such as those articulated by the Ministry of Electronics and Information Technology (MeitY) — reinforce the strategic focus on ensuring certain categories of data remain under Indian legal jurisdiction or are subject to domestic regulatory oversight. These policy considerations encompass data residency, encryption controls, and supervisory access protocols that organizations need to factor into cloud deployment models. 

While SEBI has provided phased guidance and temporary flexibility around specific data localization timelines, regulatory guidance continues to emphasize sovereign control over critical and sensitive financial data, including requirements around audit logs, encryption key management, and accessibility for supervision. These expectations align with India’s broader regulatory and policy direction that seeks to balance data utility with national and systemic risk considerations. 

IBM is expanding its cloud infrastructure footprint within the country to support customers’ regulatory and governance requirements. As part of a strategic partnership with Bharti Airtel, IBM is establishing two new IBM Cloud Multizone Regions (MZRs) in Mumbai and Chennai. These regions are designed with cloud infrastructure deployed across physically independent availability zones, supporting high availability, fault isolation, and disaster recovery while enabling customers to design architectures that address data locality and residency considerations. This expansion reflects IBM’s continued investment in building cloud infrastructure within India to support regulated and enterprise workloads that require strong governance, resilience, and locality controls. 

IBM’s cloud infrastructure and tooling provide data residency capabilities and options for customers to control where workloads and data are located, including encryption key management features that support cryptographic control and data governance within specified geographies. When combined with hybrid cloud architectures, these capabilities enable regulated entities to design cloud deployment models that take into account India–specific regulatory and policy expectations while still benefiting from cloud scalability and operational innovation. 

Way forward 

IBM Cloud supports regulated and sensitive workloads through a combination of global compliance programs and India-specific regulatory alignment initiatives. IBM Cloud services undergo independent third-party assessments against widely recognized standards such as ISO/IEC 27001, SOC 1 and SOC 2, PCI DSS, HIPAA, and HITRUST, among others. These certifications and attestations provide transparency into IBM Cloud’s control environment and allow organizations to reference validated controls as inputs to their own risk, security, and compliance assessments. While regulatory compliance obligations remain the responsibility of each regulated entity, such globally recognized assurance programs can help streamline compliance planning and reduce duplication of assurance activities. 

In addition to global compliance programs, IBM Cloud is empaneled as a Cloud Service Provider with the Ministry of Electronics and Information Technology (MeitY) under the Government of India’s GI Cloud (MeghRaj) framework. MeitY empanelment involves a formal evaluation and audit process, including security, operational, and data protection requirements assessed by designated government authorities. This empanelment confirms that IBM Cloud services offered from India meet the criteria defined by MeitY for secure and compliant cloud usage by government and public sector organizations, reinforcing IBM Cloud’s alignment with India-specific governance and data residency expectations. 

As India’s capital markets continue to evolve and regulatory expectations mature—particularly around data localization, encryption key management, cybersecurity, and operational resilienceSEBI-regulated entities are required to continually reassess their technology and risk management approaches. IBM Cloud continues to invest in secure cloud infrastructure, governance capabilities, and industry-aligned frameworks that organizations can leverage when designing cloud architectures aligned with applicable regulatory and policy principles, while retaining responsibility for their own compliance decisions. 

Through its hybrid cloud strategy and focus on security, governance, and transparency, IBM Cloud aims to support the modernization of India’s capital market infrastructure. By combining cloud innovation with strong control foundations, regulated entities can pursue digital transformation initiatives while maintaining a strong focus on resilience, risk management, and investor protection. 

Learn more about IBM Cloud Compliance & Support

Authors, 

  • Shamanth Kumar K, Product Manager - IBM Cloud Compliance 
  • Bhushan Kelewadikar, Compliance Product Manager - IBM Public Cloud 
  • Sumit Yadav, Program Director, Product Management - IBM Cloud Compliance
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