SEBI Compliance | CERT-In | Post-Quantum | CBOM

SEBI-regulated entities are sitting on invisible cryptographic risk. Here is what CBOM is, why regulators are demanding it, and how to get compliant fast.

June 2025 | 12 min read | O3 Security Research

In This Article:
1. What Is a Cryptographic Bill of Materials (CBOM)?
2. Why SEBI-Regulated Entities Must Care
3. The Regulatory Landscape: CERT-In, RBI, SEBI
4. The Quantum Threat: Why Time Is Running Out
5. What a CBOM Covers: The Complete Asset Inventory
6. How O3 Security’s CBOM Solution Works
7. Getting Started: Your CBOM Journey
8. Try O3 Security Free for 14 Days

1. What Is a Cryptographic Bill of Materials (CBOM)?

Definition: A Cryptographic Bill of Materials (CBOM) is a structured, machine-readable inventory of all cryptographic assets deployed across an organization—their type, strength, lifecycle status, quantum vulnerability, and where they are used across source code, containers, APIs, databases, and live infrastructure.

Just as a strong Software Bill of Materials (SBOM) catalogs every software component in an application, a strong Cryptographic Bill of Materials (CBOM) catalogs every cryptographic asset—algorithms, keys, certificates, protocols, libraries, and secrets—used across an organization’s technology stack.

Think of it as a cryptographic X-ray of your entire organization. Without it, security teams are flying blind—unable to answer basic questions like:
– Are we using RSA-1024 anywhere?
– Which certificates expire next month?
– Are any of our algorithms vulnerable to quantum attack?

Key Statistics:
– 76% of organizations cannot fully inventory their cryptographic assets
– 40% of enterprise certificates expire without warning each year
– 2030 is the estimated year quantum computers could break RSA encryption
– 8-10 years is the average time required to complete a cryptographic migration

The concept of CBOM emerged from the broader supply-chain security movement championed by NIST, ENISA, and now India’s own CERT-In. It answers a question that regulators are increasingly asking: Do you know what cryptography you are using, and is it safe?

2. Why SEBI-Regulated Entities Must Care

The Securities and Exchange Board of India (SEBI) oversees one of the world’s fastest-growing capital markets. Brokers, depositories, asset management companies, clearing corporations, and stock exchanges all handle data of enormous sensitivity—trade records, PAN details, portfolio holdings, settlement accounts.

Cryptography is the foundation of trust in all of these transactions. TLS protects data in transit. AES and RSA secure data at rest. Digital signatures authenticate orders. Certificates validate counterparties. When any of these cryptographic controls fail—due to weak algorithms, expired certificates, or compromised keys—the consequences for market participants and investor trust can be severe.

The Risk Today: Most SEBI-regulated entities have no centralized visibility into their cryptographic posture. Cryptographic assets are scattered across trading platforms, APIs, risk engines, compliance systems, and cloud infrastructure—often managed by different teams with no unified inventory or governance.

What Happens Without a CBOM?

1. Undetected Weak Algorithms: Legacy MD5, SHA-1, or RSA-1024 implementations persist in production because no one has a complete list of what is deployed.

2. Certificate Outages: Expired TLS certificates cause trading platform outages, impacting settlement deadlines and client trust.

3. Quantum Exposure: RSA and ECC-based encryption—used everywhere in Indian financial infrastructure—will be broken by quantum computers within this decade.

4. Regulatory Non-Compliance: CERT-In and RBI have issued explicit CBOM mandates. SEBI’s cybersecurity frameworks increasingly reference these standards, putting non-compliant entities at risk of audit findings.

5. Harvest Now, Decrypt Later Attacks: Nation-state adversaries are already harvesting encrypted financial data today, planning to decrypt it once quantum capability matures. Data encrypted today with RSA may be plaintext to an adversary in 5-7 years.

3. The Regulatory Landscape: CERT-In, RBI, SEBI

India has moved decisively on cryptographic governance. Here is the current state of regulatory requirements that directly impact SEBI-regulated entities:

CERT-In: CBOM Mandate
CERT-In has defined minimum required elements for a CBOM, covering cryptographic assets, vulnerabilities, algorithm properties, key attributes, and certificate fields.

RBI: Cryptographic Governance
RBI’s IT risk frameworks require regulated entities to maintain inventories of cryptographic controls and demonstrate lifecycle management of keys and certificates.

SEBI: Cybersecurity & Cyber Resilience Framework (CSCRF)
SEBI’s CSCRF mandates that regulated entities maintain robust cryptographic controls and align with national cybersecurity standards—including CERT-In guidelines.

NIST: Post-Quantum Cryptography Standards
NIST finalized its first post-quantum cryptography standards in 2024 (FIPS 203, 204, 205), setting the global baseline for quantum-safe migration planning.

CERT-In Minimum Elements for CBOM:
CERT-In requires documentation of:
– Cryptographic Assets
– Vulnerabilities
– Algorithm Names
– Asset Types, Primitives, Modes
– Crypto Functions
– Classical Security Levels
– OIDs
– Key Names, IDs, Sizes
– Creation & Activation Dates
– Protocol Names
– Certificate Subject/Issuer Names
– Validity Periods
– Signature Algorithm References
– Certificate Formats
– Certificate Extensions

The convergence of CERT-In, RBI, and SEBI frameworks means that cryptographic visibility is no longer optional for Indian financial institutions. It is a compliance requirement.

4. The Quantum Threat: Why Time Is Running Out

“The question is not whether quantum computers will break today’s encryption. The question is whether you will be ready when they do.”

Quantum computing threatens the foundational algorithms that secure virtually all financial transactions today. Shor’s algorithm, running on a sufficiently powerful quantum computer, can break RSA and ECC encryption in polynomial time—rendering the public-key infrastructure of the entire financial system vulnerable.

Quantum Vulnerability Assessment: Common Financial Cryptography

– RSA-2048: Quantum-Vulnerable
– ECC P-256: Quantum-Vulnerable
– AES-128: Weakened (2x attack complexity)
– AES-256: Quantum-Safe
– ML-KEM (FIPS 203): Post-Quantum Safe
– ML-DSA (FIPS 204): Post-Quantum Safe

The challenge for SEBI-regulated entities is that a cryptographic migration of this scale—replacing RSA and ECC across trading systems, APIs, digital signature infrastructure, and certificate authorities—takes 8-10 years on average. Organizations that have not yet begun their inventory and migration planning are already behind schedule.

You cannot migrate what you cannot see. A CBOM is the essential first step: know what you have, identify what is quantum-vulnerable, and build a prioritized remediation roadmap.

5. What a CBOM Covers: The Complete Asset Inventory

A mature CBOM solution must discover and catalog cryptographic assets across every layer of the technology stack. Here is what that means in practice:

Importantly, this discovery must span all surfaces where cryptography is deployed: source code repositories, container images, CI/CD pipeline artifacts, runtime environments, databases, cloud configurations, and live network infrastructure.

Sample CBOM entry in CycloneDX format:
{
"type": "cryptoAsset",
"name": "RSA-2048",
"cryptoProperties": {
"assetType": "algorithm",
"algorithmProperties": {
"primitive": "PKE",
"classicalSecurityLevel": "112",
"nistQuantumSecurityLevel": "0"
},
"vulnerabilities": ["quantum-vulnerable", "migration-required"]
}
}

6. How O3 Security’s CBOM Solution Works

O3 Security’s CBOM module delivers end-to-end cryptographic visibility—from automatic discovery to compliance reporting—in a single, unified platform built for Indian regulatory requirements.

Key Capabilities:

Automated Discovery: No Manual Surveys
O3 Security automatically scans source code repositories, container images, CI/CD pipelines, and live infrastructure. There is no need for manual asset surveys or spreadsheet inventories. Every cryptographic asset is discovered, classified, and analyzed automatically.

Continuous CBOM Generation
As your code changes, your CBOM updates. O3 Security integrates directly with your CI/CD pipelines so that every build produces an updated, auditable CBOM. Cryptographic drift—when new weak algorithms are introduced—is detected immediately.

Quantum Vulnerability Scoring
Every discovered algorithm is scored for quantum vulnerability using NIST’s quantum security levels. You get a clear, prioritized view of which assets need immediate migration versus which are already quantum-safe.

CERT-In & RBI Compliance Reporting
Generate compliance reports mapped directly to CERT-In’s minimum element requirements and RBI’s IT risk framework—ready for regulatory submission or internal audit.

Standard Format Export
CBOMs are generated and exported in industry-standard CycloneDX and SPDX formats, ensuring interoperability with regulators, auditors, and supply-chain partners.

O3 Security CBOM Operational Features:
– Automated discovery across source code, containers, infrastructure
– Continuous CBOM via CI/CD integration
– Quantum vulnerability scoring (NIST levels)
– CERT-In minimum element coverage
– CycloneDX & SPDX export formats
– Data residency in India
– Role-based access control (RBAC)
– Version control & audit traceability
– Manual CBOM ingestion from third-party tools
– Reporting & visualization dashboards

7. Getting Started: Your CBOM Journey

Implementing CBOM compliance does not require a multi-year transformation program. With the right tooling, you can go from zero visibility to a complete, regulator-ready cryptographic inventory in days. Here is the typical journey:

Step 1: Connect Your Repositories & Infrastructure
Integrate O3 Security with your source code repositories, container registries, and cloud environments. Takes less than an hour.

Step 2: Run Automated Discovery
O3 Security scans your entire stack and builds your first complete CBOM covering algorithms, keys, certificates, protocols, libraries, and secrets.

Step 3: Review Your Cryptographic Risk Posture
Explore the dashboard to see vulnerabilities, quantum exposure, certificate expiry timelines, and deprecated algorithm usage.

Step 4: Generate Compliance Reports
Export CERT-In-aligned CBOM reports in CycloneDX or SPDX format ready for internal audit or regulatory submission.

Step 5: Build Your Quantum Migration Roadmap
Use O3 Security’s prioritized findings to plan your post-quantum migration knowing exactly which systems need attention first.

Key Advantages:
– Made in India
– CERT-In Aligned
– RBI Compliant
– CycloneDX compatible
– SPDX compatible
– Post-Quantum Ready

Frequently Asked Questions

Q: Is CBOM the same as SBOM?
No. An SBOM (Software Bill of Materials) catalogs software components and their dependencies. A CBOM (Cryptographic Bill of Materials) specifically catalogs cryptographic assets—algorithms, keys, certificates, and protocols. They are complementary: SBOM tells you what software you are running; CBOM tells you what cryptography is protecting it and whether it is safe.

Q: Is CBOM mandatory for SEBI-regulated entities?
CERT-In has published formal CBOM minimum element requirements, and SEBI’s Cyber Security & Cyber Resilience Framework (CSCRF) requires alignment with national cybersecurity standards. Practically, CBOM has moved from a recommended best practice to an expected compliance control for regulated financial entities in India.

Q: How long does it take to generate a CBOM?
With O3 Security’s automated discovery, your first CBOM can be generated within hours of connecting your repositories and infrastructure—not months of manual surveys.

Q: What is the quantum threat deadline?
Most experts estimate that cryptographically relevant quantum computers could emerge between 2030 and 2035. However, because cryptographic migrations take 8-10 years for large organizations, the planning must begin now. “Harvest now, decrypt later” attacks are already underway.

Q: Can O3 Security’s CBOM ingest data from other tools?
Yes. O3 Security supports manual ingestion of CBOMs generated by third-party tools, ensuring interoperability with your existing security toolchain and supplier ecosystem.

Conclusion

SEBI-regulated financial institutions face unprecedented cryptographic risk. The convergence of quantum computing threats, regulatory mandates, and the complexity of modern infrastructure means that visibility is no longer a luxury—it’s a necessity.

A CBOM is the foundation of any credible cryptographic governance program. It answers the fundamental question: Do you know what cryptography is protecting your business, and is it safe?

With O3 Security’s CBOM solution, you can move from cryptographic darkness to regulatory compliance in weeks—not years. Start your 14-day free trial today and see your cryptographic risk landscape.

Ready to get started?  contact the team to schedule a personalized demo.

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About O3 Security
O3 Security is an Indian cybersecurity company specializing in cryptographic governance, post-quantum readiness, and CBOM solutions for financial institutions. The platform is built in India, hosted in Indian data centers, and aligned with CERT-In, RBI, and SEBI compliance requirements.

Contact Information:
– Email: siva@meteonic.com
– Free Trial: Start your 14-day trial
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