Description

BSE clarifies criteria for determining registered clients and categorization of proprietary trading members under SEBI's CSCRF guidelines

Summary

BSE has issued clarifications regarding the implementation of SEBI’s Cybersecurity and Cyber Resilience Framework (CSCRF) for regulated entities. The clarifications address two key areas: the methodology for determining the number of registered clients based on Unique PAN, and the categorization criteria for trading members engaged in both clientele and proprietary trading.

Key Points

  • Registered clients shall be counted based on Unique PAN including both active and inactive status
  • Clients marked as ‘Closed’ in UCC database shall be excluded from the count
  • Trading members with clientele trading turnover less than 10% of proprietary trading turnover shall be categorized as proprietary stockbrokers
  • Clarifications apply to all trading members implementing CSCRF guidelines

Regulatory Changes

The circular clarifies existing SEBI CSCRF requirements rather than introducing new regulations. It provides specific interpretation of how to calculate registered clients for categorization purposes and defines the threshold for proprietary trading member classification.

Compliance Requirements

Trading members must:

  • Calculate registered clients based on Unique PAN including active and inactive status
  • Exclude closed clients from their registered client count
  • Determine their categorization as proprietary traders if clientele trading is less than 10% of proprietary trading turnover
  • Apply these clarifications for CSCRF implementation and compliance

Important Dates

  • Circular Date: September 2, 2025
  • Reference Period for Trading Turnover: April 1 to March 31 (Financial Year)
  • Previous related circulars: August 20, 2024; December 31, 2024; March 28, 2025; April 30, 2025; August 28, 2025
  • FAQ dated: June 11, 2025

Impact Assessment

This clarification impacts how trading members categorize themselves under CSCRF, potentially affecting their compliance obligations. Members engaged primarily in proprietary trading with minimal client business may be subject to different cybersecurity requirements. The clarification ensures consistent interpretation and implementation of CSCRF guidelines across all BSE trading members.

Impact Justification

Important compliance clarification affecting trading member categorization and client counting methodology under CSCRF