Cybersecurity Governance Frameworks: Global Measures and the Lessons for India
Introduction
The Data Security Council of India’s India Cyber Threat Report 2025 calculates that a staggering 702 potential attacks happened per minute on average in the country in 2024. Recent alleged data breaches on organisations such as Star Health, WazirX, Indian Council of Medical Research (ICMR), BSNL, etc. highlight the vulnerabilities of government organisations, critical industries, businesses, and individuals in managing their digital assets. India is the second most targeted country for cyber attacks globally, which warrants the development and adoption of cybersecurity governance frameworks essential for the structured management of cyber environments. The following global models offer valuable insights and lessons that can help strengthen cybersecurity governance.
Overview of Global Cybersecurity Governance Models
Cybersecurity governance frameworks provide a structured strategy to mitigate and address cyber threats. Different regions have developed their own governance models for cybersecurity, but they all emphasize risk management, compliance, and cross-sector collaboration for the protection of digital assets. Four such major models are:
- NIST CSF 2.0 (U.S.A): The National Institute of Standards and Technology Cyber Security Framework provides a flexible, voluntary, risk-based approach rather than a one-size-fits-all solution to manage cybersecurity risks. It endorses six core functions, which are: Govern, Identify, Protect, Detect, Respond, and Recover. This is a widely adopted framework used by both public and private sector organizations even outside the U.S.A.
- ISO/IEC 27001: This is a globally recognized standard developed jointly by the International Organization for Standardization (ISO) and the International Electrotechnical Commission (IEC). It provides a risk-based approach to help organizations of all sizes and types to identify, assess, and mitigate potential cybersecurity threats to Information Security Management Systems (ISMS) and preserve the confidentiality, integrity, and availability of information. Organizations can seek ISO 27001 certification to demonstrate compliance with laws and regulations.
- EU NIS2 Directive: The Network and Information Security Directive 2 (NIS2) is an updated EU cybersecurity law that imposes strict obligations on critical services providers in four overarching areas: risk management, corporate accountability, reporting obligations, and business continuity. It is the most comprehensive cybersecurity directive in the EU to date, and non-compliance may attract non-monetary remedies, administrative fines up to at least €10 million or 2% of the global annual revenue (whichever is higher), or even criminal sanctions for top managers.
- GDPR: The General Data Protection Regulation (GDPR)of the EU is a comprehensive data privacy law that also has major cybersecurity implications. It mandates that organizations must integrate cybersecurity into their data protection policies and report breaches within 72 hours, and it prescribes a fine of up to €20 million or 4% of global turnover for non-compliance.
India’s Cybersecurity Governance Landscape
In light of the growing nature of cyber threats, it is notable that the Indian government has taken comprehensive measures along with efforts by relevant agencies such as the Ministry of Electronics and Information Technology, Reserve Bank of India (RBI), National Payments Corporation (NPCI) and Indian Cyber Crime Coordination Centre (I4C), CERT-In. However, there is still a lack of an overarching cybersecurity governance framework or comprehensive law in this area. Multiple regulatory bodies in India oversee cybersecurity for various sectors. Key mechanisms are:
- CERT-In Guidelines: The Indian Computer Emergency Response Team, under the Ministry of Electronics and Information Technology (MeitY), is the nodal agency responsible for cybersecurity incident response, threat intelligence sharing, and capacity building. Organizations are mandated to maintain logs for 180 days and report cyber incidents to CERT-In within six hours of noticing them according to directions under the Information Technology Act, 2000 (IT Act).
- IT Act & DPDP Act: These Acts, along with their associated rules, lay down the legal framework for the protection of ICT systems in India. While some sections mandate that “reasonable” cybersecurity standards be followed, specifics are left to the discretion of the organisations. Enforcement frameworks are vague, which leaves sectoral regulators to fill the gaps.
- Sectoral regulations: The Reserve Bank of India (RBI), the Insurance Regulatory and Development Authority of India (IRDAI), the Department of Telecommunications, the Securities Exchange Board of India (SEBI), National Critical Information Infrastructure Protection Centre (NCIIPC) and other regulatory bodies require that cybersecurity standards be maintained by their regulated entities.
Lessons for India & Way Forward
As the world faces unprecedented security and privacy threats to its digital ecosystem, the need for more comprehensive cybersecurity policies, awareness, and capacity building has perhaps never been greater. While cybersecurity practices may vary with the size, nature, and complexity of an organization (hence “reasonableness” informing measures taken), there is a need for a centralized governance framework in India similar to NIST2 to unify sectoral requirements for simplified compliance and improve enforcement. India ranks 10th on the World Cybercrime Index and was found to be "specialising" in scams and mid-tech crimes- those which affect mid-range businesses and individuals the most. To protect them, India needs to strengthen its enforcement mechanisms across more than just the critical sectors. This can be explored by penalizing bigger organizations handling user data susceptible to breaches more stringently, creating an enabling environment for strong cybersecurity practices through incentives for MSMEs, and investing in cybersecurity workforce training and capacity building. Finally, there is a scope for increased public-private collaboration for real-time cyber intelligence sharing. Thus, a unified, risk-based national cybersecurity governance framework encompassing the current multi-pronged cybersecurity landscape would give direction to siloed efforts. It would help standardize best practices, streamline compliance, and strengthen overall cybersecurity resilience across all sectors in India.
References
- https://cdn.prod.website-files.com/635e632477408d12d1811a64/676e56ee4cc30a320aecf231_Cloudsek%20Annual%20Threat%20Landscape%20Report%202024%20(1).pdf
- https://strobes.co/blog/top-data-breaches-in-2024-month-wise/#:~:text=In%20a%20large%2Dscale%20data,emails%2C%20and%20even%20identity%20theft.
- https://www.google.com/search?q=nist+2.0&oq=nist+&gs_lcrp=EgZjaHJvbWUqBggBEEUYOzIHCAAQABiPAjIGCAEQRRg7MgYIAhBFGDsyCggDEAAYsQMYgAQyBwgEEAAYgAQyBwgFEAAYgAQyBwgGEAAYgAQyBggHEEUYPNIBCDE2MTJqMGo3qAIAsAIA&sourceid=chrome&ie=UTF-8
- https://www.iso.org/standard/27001
- https://nis2directive.eu/nis2-requirements/
- https://economictimes.indiatimes.com/tech/technology/india-ranks-number-10-in-cybercrime-study-finds/articleshow/109223208.cms?from=mdr