Service providers and intermediaries
Every service provider and intermediary in the sense of the IT Act, including platforms that host or transmit content and data for users. Edtech platforms, LMS and online-exam providers fall here.
CERT-In 2022
CERT-In is India's national agency for cyber incident response. On 28 April 2022 it issued binding Directions under Section 70B(6) of the Information Technology Act, 2000. They are short, and they are strict: report specified cyber incidents within 6 hours of noticing them, keep logs of all ICT systems for a rolling 180 days within Indian jurisdiction, synchronise system clocks to Indian time sources, and name a Point of Contact who answers CERT-In.
The Directions have been in force since mid-2022, with extra time for MSMEs and for some cloud and data-centre obligations until 25 September 2022. As at our last review, CERT-In's Directions page lists no amendment to them. For institutions they sit alongside the DPDP Act: a ransomware attack on a student information system is both a CERT-In incident (6 hours) and, from 13 May 2027, a personal data breach to report to the Data Protection Board (72 hours).
Campuses are attractive targets: large user bases, open networks, legacy servers and valuable identity data. The Directions are the minimum floor for being able to detect, prove and respond.
Every service provider and intermediary in the sense of the IT Act, including platforms that host or transmit content and data for users. Edtech platforms, LMS and online-exam providers fall here.
Any data centre, including an on-campus server room that hosts services for others. Data centres also carry the 5-year subscriber-record duty described below.
A "body corporate" is any company, and includes a firm, sole proprietorship or other association of individuals engaged in commercial or professional activities (CERT-In FAQ 25, citing Section 43A of the IT Act). Private universities and school groups run by companies are covered. CERT-In's FAQ states the Directions are applicable to any entity whatsoever in the matter of cyber incidents, so we advise trust- and society-run institutions to comply in full. The position of a trust or society that is not a company has not been confirmed by counsel on this page.
Ministries, departments and government organisations, which in practice includes central and state universities, state boards and government-run colleges and schools.
Data centres, Virtual Private Server providers, cloud service providers and VPN service providers must also keep validated subscriber records for 5 years. CERT-In's FAQ clarifies that "VPN service provider" means a provider of internet proxy-like VPN services to the public, not an institution's own enterprise VPN.
The Directions reach any entity, Indian or foreign, in the matter of cyber incidents affecting India (FAQ 26). Foreign SaaS used by Indian campuses is expected to maintain logs in Indian jurisdiction (FAQ 36). Individual citizens are not covered (FAQ 7).
Report any of the 20 incident types in Annexure I within 6 hours of noticing the incident or of it being brought to your notice. They include targeted scanning of critical systems, compromise of critical systems, unauthorised access to IT systems or data, website defacement, malware and ransomware, attacks on servers and network devices, identity theft and phishing, DoS and DDoS, attacks on applications, data breaches and data leaks, attacks on cloud systems and on AI/ML systems. Report by email to incident@cert-in.org.in, phone 1800-11-4949 or fax 1800-11-6969, using the CERT-In reporting format.
Direction (ii); Annexure I
If the full reporting form cannot be completed within 6 hours, report the information available and send the rest later within a reasonable time (FAQ 30). Where an incident hits a vendor's systems but your data, whoever notices it must report; the duty cannot be transferred or contracted away (FAQ 13).
FAQs 13 and 30
Enable logs on all ICT systems and keep them securely for a rolling 180 days within Indian jurisdiction, to be produced with any incident report or on CERT-In's direction. Examples in the FAQ: firewall, IPS, SIEM, web, database, mail, proxy, VPN, SSH, application and critical-system event logs. CERT-In's FAQ says copies may also be stored abroad as long as logs can be produced to CERT-In in reasonable time.
Direction (iv); FAQs 35 to 37
Connect all ICT systems to the NTP servers of the National Informatics Centre (NIC) or National Physical Laboratory (NPL), or to NTP servers traceable to them. Multi-region infrastructure may use another accurate source that does not deviate from NIC and NPL. Record the time zone with each timestamp.
Direction (i); FAQs 40 and 41
Name a Point of Contact to interface with CERT-In and send their details (name, designation, organisation, address, email, mobile, office phone and fax) in the Annexure II format to info@cert-in.org.in. Keep it updated; all CERT-In directions will be sent to this person.
Direction (iii); Annexure II
When CERT-In orders it, take action or provide information or assistance within the format and timeframe specified, which may be up to near real-time. Missing the timeframe is treated as non-compliance.
Direction (iii)
Register and keep, for 5 years or longer after a subscription ends, validated customer names, period of hire, IPs allotted, the email, IP and timestamp used at registration, the purpose of hiring, validated address and contact numbers, and the ownership pattern of the customer.
Direction (v)
CERT-In's Comprehensive Cyber Security Audit Policy Guidelines (Version 1.0, 25 July 2025) state that auditee organisations are expected to ensure a comprehensive audit covering all aspects of their ICT systems at least once a year, carried out under the guidelines by CERT-In empanelled auditing organisations. How far these guidelines bind an institution that is not otherwise required by a regulator to commission such an audit has not been confirmed by counsel on this page.
CERT-In Comprehensive Cyber Security Audit Policy Guidelines, 2025, section 6
| When | Requirement | Notes |
|---|---|---|
| 28 April 2022 | Directions No. 20(3)/2022-CERT-In issued under Section 70B(6) of the IT Act. | |
| Late June 2022 | Directions effective 60 days after issue for most entities. | The Directions say "after 60 days from the date on which it is issued". |
| 25 September 2022 | Effective for MSMEs, and for the validated-name and validated-address requirements on data centres, VPS, cloud and VPN providers. | CERT-In extension order dated 27 June 2022. |
| Within 6 hours | Report an Annexure I cyber incident to CERT-In, counted from noticing it or it being brought to your notice. | |
| Rolling 180 days | Retention of logs of all ICT systems, within Indian jurisdiction. | The DPDP Rules separately require processing logs for at least one year from 13 May 2027, so a one-year policy covers both. |
| At all times | ICT system clocks synchronised to NIC or NPL NTP servers, or sources traceable to them. | |
| Now, and on every change | Point of Contact details sent to CERT-In in the Annexure II format, and updated whenever the person changes. | |
| 5 years or longer | Data centres, VPS, cloud and VPN providers: retain validated subscriber records after cancellation or withdrawal of the registration. | |
| Within the time CERT-In specifies | Information, action or assistance ordered by CERT-In, in the format it specifies, up to near real-time. | |
| At least once a year | Comprehensive cyber security audit of all ICT systems, as expected by CERT-In's audit guidelines of 25 July 2025. |
| Breach | Maximum |
|---|---|
| Failure to provide information called for, or non-compliance with a direction under Section 70B(6), including these Directions (Section 70B(7) of the IT Act) | Imprisonment up to one year, or a fine up to ₹1 lakh, or both |
| How CERT-In says it will use this power (FAQ 23) | To be exercised reasonably, and on occasions when the non-compliance is deliberate |
| The same incident involving personal data, from 13 May 2027 (DPDP Act) | Separate DPDP penalties apply, up to ₹200 crore for failing to notify a breach and up to ₹250 crore for inadequate safeguards. See the DPDP page. |
A detection-to-report workflow with pre-filled CERT-In reporting forms, an on-call rota and decision rules for which events count as Annexure I incidents. We run tabletop drills each term so the first real report is not the first attempt.
Central log collection from firewalls, servers, LMS, ERP, mail and VPN into tamper-evident storage in India, retained for a full year so it also covers the DPDP Rules, and searchable when CERT-In asks.
We map every ICT asset on campus and in the cloud, point each one at NIC or NPL-traceable NTP, and keep the inventory current, because you cannot log or report on systems you do not know you have.
CIO-as-a-service support to name and register your Point of Contact, draft the incident response policy for your governing body, and fold CERT-In duties into vendor contracts so suppliers alert you in time for the 6-hour clock.
Bit2Bit is not a CERT-In empanelled auditor. We prepare your institution for audit and coordinate the comprehensive audit with a CERT-In empanelled auditing organisation of your choice, then track the remediation through to closure. An empanelled audit partner is not named on this page.
Immutable, 3-2-1 backups and recovery drills, so an attack becomes a reporting duty and a restore, not a lost semester.
They are not limited to tech companies. They name service providers, intermediaries, data centres, body corporates and government organisations. Government universities and schools are government organisations; institutions run by companies are body corporates; and any institution hosting services for others may also be a service provider or data centre. CERT-In's FAQ says the Directions apply to any entity in the matter of cyber incidents. Our advice is to comply in full whatever your legal form. The position of a trust or society that is not a company has not been confirmed by counsel on this page.
From when you notice the incident or it is brought to your notice, for example by a vendor, a student or a security researcher. It is not counted from when the attack began, and not from when the investigation ends. Report what you know within 6 hours and add detail later (FAQs 24 and 30).
Whoever notices the incident must report it, and that duty cannot be passed to someone else by contract (FAQ 13). In practice both you and the vendor may need to report. Make sure your contract obliges the vendor to tell you immediately, so your own 6-hour clock and, from May 2027, your DPDP breach duties can be met.
The Directions require logs to be maintained within Indian jurisdiction. CERT-In's FAQ adds that copies may also be stored outside India as long as logs can be produced to CERT-In in reasonable time. The safest course for an institution is to keep the primary log store in India, which is what a sovereign Indian cloud gives you.
No. CERT-In's FAQ says the VPN provider duty is for entities offering internet proxy-like VPN services to the general public, not enterprise or corporate VPNs used by staff and students (FAQ 34). If you run a data centre or rent servers or cloud capacity to outside customers, the 5-year subscriber-record duty may apply to that part of your operations.
Identity theft, spoofing and phishing attacks are listed in Annexure I. CERT-In's FAQ indicates that the 6-hour window applies to incidents of a severe nature and to data breaches and data leaks. A successful phishing attack that leads to account compromise or data exposure should be reported; for routine blocked spam, record it internally and take advice. The current CERT-In position on reporting thresholds for unsuccessful phishing is not restated beyond that FAQ summary. Check the current FAQ before you rely on a threshold.
A senior consultant reviews your data, systems and regulatory position with your team and gives you a written gap report. There is no cost and no obligation to buy anything.
A senior consultant reviews your data, systems and regulatory position with your team and gives you a written gap report, at no cost.