Privacy · Data governance · AI advisory +91 97162 99280Mohit.gupta@qanalyx.com

AI you can explain to a regulator, a court and a board.

We help organisations take stock of where AI is used, assess each use against the law and against how it is built, and put contracts and oversight around it.

New · 4 Nov 2026 CERT-In issues AI Security Auditing Guidelines →
Illustration: a layered neural network with one node under a review ring
Two lenses

Most AI risk is a data and contract question first.

Indian obligations come from existing law and from guidance. We map them to each use case.

Legal lens

What the law and guidance ask

  • DPDP Act applies where personal data is used to train, tune or run a model
  • IT Act and IT Rules, including the 2026 amendment on synthetically generated content for intermediaries
  • Sector guidance, such as the RBI FREE-AI report for financial services
  • MeitY’s India AI Governance Guidelines and their seven principles
  • Vendor contracts: data use, indemnity, intellectual property and liability
Technical lens

What the systems must do

  • An inventory of AI use cases, each with an owner and a risk tier
  • Data provenance for training and retrieval sources
  • Testing for accuracy, bias and robustness before and after release
  • Human oversight with clear points of review and escalation
  • Logging and change control for models, prompts and data
  • Hosting choices, including local deployment where data must not leave
The landscape

Guidance is arriving faster than statute.

Four developments we track for clients.

4 Nov 2026CERT-In issues the AI Security Auditing Guidelines v1.0: four risk tiers, nine audit domains and independent audits for higher tiers.
5 Nov 2025MeitY releases the India AI Governance Guidelines, built on seven principles.
13 Aug 2025RBI’s FREE-AI committee report sets out 7 principles and 26 recommendations for AI in financial services.
10 Feb 2026IT Amendment Rules 2026 notified, in force from 20 Feb 2026, covering labelling of synthetically generated content.

Sources: CERT-In, AI Security Auditing Guidelines v1.0 · The Tribune on the India AI Governance Guidelines · RBI press release on the FREE-AI report · Business Today on the IT Amendment Rules 2026. Check the notified text before relying on a date or a provision.

CERT-In AI Security Auditing Guidelines

India now has a national method for auditing AI systems.

On 4 November 2026 CERT-In issued version 1.0 of its guidelines, prepared by Sub-group 03 of its working group on Indian standards for cybersecurity auditing. They give auditors and organisations one risk-based way to assess the security and governance of AI across its whole lifecycle.

4 risk tiersLow, Moderate, High and Critical, set by scoring each system on eight risk factors.
9 audit domainsFrom governance and data to model risk, security, monitoring, human oversight and third parties.
7 principlesSecurity by design, human oversight, transparency, fairness, privacy, auditability and resilience.
5 maturity levelsFrom ad hoc to optimising, to benchmark and plan improvement in AI governance.
What each tier requires, at a minimumFour tiers, scored on eight factors
Tier 1 · LowScore 8–12

Self-assessment or a basic internal review, with documented evidence.

Tier 2 · ModerateScore 13–19

Documented internal audit. Independent audit by a CERT-In empanelled auditing organisation at least annually.

Tier 3 · HighScore 20–26

Periodic independent third-party audit by a CERT-In empanelled organisation, more often when changes or incidents warrant.

Tier 4 · CriticalScore 27–32

Independent audit by a CERT-In empanelled organisation, with continuous monitoring.

The eight factors are impact severity, autonomy, data sensitivity, scale and exposure, reversibility, sector criticality, adversarial exposure, and complexity and auditability. Tiers must be reassessed at least yearly and before a material change goes live. A system can be escalated above its score, for example where it acts autonomously on safety-critical matters or cannot be reliably interrupted.

Nine core audit domainsWhat an audit looks at
Nine core audit domains

What an audit looks at

  • AI governance and accountability
  • Data lifecycle, quality and privacy
  • Model risk management
  • Ethics, bias and fairness
  • Explainability and transparency
  • Security, adversarial resilience and incident reporting
  • Continuous monitoring, drift and validation
  • Human oversight and decision accountability
  • Third-party and AI supply-chain assurance
Advanced AI

Extra requirements for newer systems

  • Covered: generative AI, retrieval-augmented generation, agentic, multimodal and multi-agent AI, and autonomous or cyber-physical AI
  • Threats named: prompt injection, sensitive-information disclosure, excessive agency, data and model poisoning, and supply-chain risk
  • Also named: vector and embedding weaknesses, unsafe tool use, persistent-memory risk, multimodal attacks, misinformation and improper output handling
  • Alignment: MeitY’s India AI Governance Guidelines, ISO/IEC 42001, ISO/IEC 27001, NIST AI RMF, MITRE ATLAS and OWASP guidance
Where does your AI governance stand today?Five-level maturity model

The guidelines include a five-level maturity model. Organisations use it to assess themselves before an audit and to plan improvement. It gives context only: it never changes how severe an audit finding is.

Level 1Initial, ad hoc

No AI policy or named owner, no inventory, no bias testing or monitoring.

Level 2Developing

A policy exists but is incomplete. Basic inventory, some bias testing, and human oversight for high-impact decisions.

Level 3Defined

Full policy suite, tiered inventory, an AI governance committee and an ISO/IEC 42001-aligned system. Can show compliance for its tier.

Level 4Managed, measured

Fairness, drift and incident-response metrics tracked, with automated alerting and board-level reporting.

Level 5Optimising, leading

Continuous improvement, automated compliance checks, and a voice in standards and industry forums.

From MeitY’s seven principles to audit checksPrinciple mapping

MeitY’s India AI Governance Guidelines say what good AI governance should look like. CERT-In’s guidelines say how to check it. This is the mapping CERT-In itself draws.

MeitY principle (sutra)CERT-In audit principleWhat the audit checks
1. Trust is the FoundationAll seven principles togetherTrust is shown through verified security, accountability, transparency, fairness, privacy, auditability and resilience.
2. People FirstAccountability and human oversightHuman-in-the-loop review by tier, ways to contest and override AI decisions, and cross-functional accountability.
3. Innovation over RestraintResilience and continuous assuranceObligations scaled to risk tier, with lighter paths for small businesses and start-ups.
4. Fairness and EquityFairness and bias managementBias metrics, screening for proxy variables, ongoing fairness monitoring and counterfactual testing.
5. AccountabilityAccountability; auditability and traceabilityResponsibility matrix, AI governance policy and impact assessment, finding classification and remediation tracking.
6. Understandable by DesignTransparency and explainabilityModel documentation, decision logging and explanations suited to users and regulators.
7. Safety, Resilience and SustainabilitySecurity by designAdversarial testing, incident reporting to CERT-In, infrastructure hardening, drift detection and re-validation.

Maturity levels: CERT-In guidelines, section 13. Principle mapping: CERT-In guidelines, section 15.2. We have shortened both for readability.

How we help you prepareOur engagement

Tier every system

Score each AI use case on the eight factors, record the reasoning, and flag the ones that need escalation. The tier goes into your AI register.

Close the gaps before the audit

Check evidence against the nine domains: policy, data provenance, testing, human review, vendor terms, logging and incident handling. Fix what is missing first.

Line up the independent audit

Where your tier needs an independent audit, it is carried out by a CERT-In empanelled auditing organisation. We prepare the documents, the evidence and the management responses.

Source: CERT-In, AI Security Auditing Guidelines v1.0, 4 November 2026 · CERT-In guidelines page. This is our summary. The published guidelines are the authority, and whether they bind you depends on your regulator and your contracts.

Deliverable

An AI register with a legal and technical test for each use.

Every use case is assessed against the same checklist before it is approved, and the result is kept where an auditor can find it.

  • One register for the organisation. Owner, purpose, data used, risk tier and status for each use case.
  • A legal touchpoint for each use. The provisions and guidance that apply, so counsel can see the basis.
  • A technical checklist. Provenance, testing, human review, vendor terms and logging.
Illustrative deliverable
AI Use-case Register · CERT-In tiers
Illustrative deliverable
RegisterRisk tiersAssessmentsVendorsOversight
AI use cases17▲ 4 this quarter
Using personal data93 high risk
Tier 3 and above3independent audit due
Assessments pending52 overdue
Register 6 of 17 use cases
Use caseOwnerPersonal dataCERT-In tierLegal touchpointsStatus
Customer support assistantServiceYesTier 2DPDP s.5–6, s.8Assessed
Résumé screeningHRYesTier 3DPDP s.8; fairness reviewIn review
Contract summariserLegalYesTier 2DPDP s.8(5); confidentialityAssessed
Demand forecastingPlanningNoTier 1Model risk onlyAssessed
Credit pre-screeningLendingYesTier 3DPDP; RBI FREE-AI; CERT-InPending
Marketing copy generatorMarketingNoTier 1IT Rules labelling; IPAssessed
Assessment checklist Résumé screening
Lawful basis and noticeDone
Training and retrieval data provenanceDone
Bias and accuracy testingIn progress
Human review point definedDone
Vendor terms and data locationIn progress
Logging and change controlOpen
Each use case is assessed on the same legal and technical checklist before it is approved.
Engagements

What we do in this area.

From a first inventory to a standing review process.

Inventory and tier

Find where AI is already in use, including in vendor products, and tier each use against the CERT-In risk factors.

Assess and contract

Legal and technical assessment of each use, audit readiness against the nine CERT-In domains, and vendor terms for data, liability and audit.

Govern

A policy, a review board and reporting, so new uses pass the same checks as the first ones.

Contact us

Start with an inventory.

Most organisations use more AI than they have listed. We find it, tier it and say what to do first.