Cybersecurity training for NBFC employees is no longer simply an HR awareness initiative or an IT department activity. RBI’s current framework expressly requires NBFCs to maintain an ongoing information-security training and awareness programme and to measure whether that training is actually effective.
The Reserve Bank of India (Non-Banking Financial Companies – Cybersecurity, Technology: Risk, Resilience and Assurance Framework) Directions, 2026, issued on 31 July 2026, create a consolidated framework covering cybersecurity, technology risk, resilience, IT governance, incident management, assurance and related responsibilities for NBFCs. The Directions came into force immediately and apply across the NBFC sector, with differentiated requirements depending on regulatory layer and asset size.
For Chief Compliance Officers, CROs, CISOs, Internal Audit Heads and HR/L&D teams, this has an important implication: cyber training should be treated as part of the NBFC’s regulatory control environment, not merely as an annual awareness presentation.
1. What Does RBI Require from NBFCs on Cybersecurity Training?
The training provisions in RBI’s 2026 cybersecurity framework are unusually clear.
The Directions require the NBFC to establish and implement a robust, ongoing information-security training and awareness programme for all users. The programme must also be periodically reviewed and updated to remain aligned with changing technology, emerging cyber threats and the institution’s own information-security framework.
RBI goes beyond requiring employees to attend training. It also requires the NBFC to:
- maintain a formal mechanism for measuring training effectiveness;
- use periodic assessments or testing;
- track training and awareness status; and
- maintain an up-to-date repository covering all users.
This distinction matters.
A traditional compliance approach may demonstrate:
500 employees attended cybersecurity awareness training.
The stronger RBI-aligned approach should also be capable of demonstrating:
500 employees were assigned training, 487 completed it, knowledge was assessed, identified gaps were followed up, and current training status is available for supervisory or assurance review.
Training delivery and training effectiveness are therefore two different control requirements.
For HR and L&D teams in NBFCs, this makes the LMS, assessment methodology, completion records and refresher process much more important than simply organising a session once a year.
2. Cyber Risk Is Not Only an IT Department Responsibility
Financial institutions increasingly depend on digital lending platforms, APIs, cloud environments, mobile applications, third-party vendors and interconnected systems. However, many cyber incidents still begin with ordinary employee behaviour.
Examples include:
- clicking a phishing link;
- sharing credentials;
- approving an unusual request without verification;
- mishandling customer information;
- using weak authentication practices;
- failing to escalate a suspected incident;
- providing excessive system access;
- responding incorrectly to social-engineering attempts.
RBI’s earlier NBFC IT framework explicitly recognised the human element in information security and required initial and ongoing awareness training. It also emphasised awareness among employees, top management and the Board. The 2026 Directions strengthen this into a more measurable training obligation.
This means an NBFC’s cybersecurity capability needs to operate across several lines.
All employees need basic cyber hygiene and threat awareness.
IT and Information Security teams require deeper technical and control knowledge.
Risk and Compliance need to understand cyber risk governance, regulatory obligations, escalation and oversight.
Internal Audit needs sufficient capability to test whether controls and cyber governance arrangements are actually operating.
Senior Management and the Board need enough understanding to challenge risk exposure, resource allocation, material incidents and resilience arrangements.
Cybersecurity training for NBFCs should therefore be role-based rather than identical for everyone.
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3. What Should an NBFC Cybersecurity Training Programme Cover?
A useful programme should connect employee behaviour with governance, technology risk and regulatory responsibility.
For general employees, training should focus on practical situations they are likely to encounter rather than highly technical cybersecurity concepts.
Important areas include:
- phishing and spear-phishing;
- suspicious emails, links and attachments;
- social engineering and impersonation;
- credential and password security;
- multi-factor authentication;
- safe handling of customer and organisational data;
- secure remote working;
- mobile-device risks;
- inappropriate data sharing;
- cyber incident identification; and
- immediate escalation procedures.
For Risk, Compliance, Internal Audit and IT governance teams, the training needs to go deeper.
These teams may need to understand:
- information-security governance;
- access-control risk;
- privileged access;
- vulnerability management;
- technology change risk;
- vendor and cloud exposure;
- API vulnerabilities;
- incident response;
- cyber resilience;
- business continuity;
- disaster recovery;
- cyber assurance;
- reporting and escalation; and
- Board-level cyber-risk reporting.
RBI’s 2026 Directions cover a broad technology-risk framework including Board-approved policies, information security, IT risk, application and network security, vulnerability assessment, business continuity, IT outsourcing, information-systems audit and incident response.
The training architecture should reflect that breadth without attempting to turn every employee into a cybersecurity specialist.
4. Training Should Be Measured, Tested and Evidenced
One of the most important practical implications of the 2026 RBI framework is the emphasis on effectiveness.
An attendance sheet proves that training was delivered.
It does not prove that employees understood the material.
An NBFC can strengthen its training evidence through a combination of:
- pre-training or post-training assessments;
- MCQ-based tests;
- phishing simulations;
- scenario exercises;
- completion tracking;
- refresher assignments;
- targeted retraining for weaker groups; and
- periodic reporting to relevant management functions.
For example, suppose 300 employees complete an information-security programme.
If 26% of a particular operating team repeatedly fail phishing-awareness questions, the NBFC has learned something important. The correct response is not simply to mark all 300 employees as “trained”. It may indicate a need for additional intervention in that function.
A useful cyber-training dashboard could therefore track:
|
Indicator |
What It Shows |
|
Employees assigned training |
Training population |
|
Completion percentage |
Delivery status |
|
Assessment score |
Knowledge retention |
|
Failed / incomplete assessments |
Capability gaps |
|
Phishing simulation outcome |
Behavioural awareness |
|
Refresher completion |
Remediation |
|
Function-wise status |
Higher-risk groups |
|
Last training date |
Currency of awareness |
This also helps Compliance, Risk, Internal Audit and HR demonstrate that the cybersecurity learning programme is operating as a controlled process.
For Middle Layer NBFCs, where technology dependence and third-party connectivity may be substantial, this evidence can be particularly valuable during internal assurance and supervisory review.
5. Cyber Training Must Connect with Incident Response and Operational Resilience
Cyber-awareness training should not stop at “how to avoid an attack”.
Employees must also know what to do when something has already happened.
A suspicious email, compromised credential, malware alert or unexplained system behaviour can become materially more serious if the employee does not understand the escalation procedure.
Training should therefore answer:
- What constitutes a suspected cyber incident?
- Who should the employee contact?
- What should the employee avoid doing?
- What information should be retained?
- Who determines whether the issue requires further regulatory or management escalation?
RBI’s 2026 framework requires a broader cyber-resilience architecture and introduces requirements around cyber-incident reporting, testing, assurance and operational preparedness. Secondary summaries of the Direction note that reportable cyber incidents are to be reported through RBI’s DAKSH platform within the prescribed timeframe and that comprehensive IT risk assessment is required at least annually.
For training purposes, this means employees do not need to memorise every regulatory reporting field. They do need to understand that delayed internal escalation can prevent the organisation from meeting its external regulatory obligations.
The same principle applies to business continuity.
Cyber resilience involves more than prevention. It also involves the capacity to:
Detect → Contain → Respond → Recover → Review → Strengthen Controls
That requires coordination across IT, Information Security, Risk, Operations, Compliance, Business Continuity and senior management.
Read Now: Cyber Insurance: The Essential Shield Against Modern Cyberattacks → Read the RMAI article
6. Building a Role-Based Cybersecurity Training Calendar for NBFCs
For HR Heads and L&D teams, the practical question is often: who should be trained, on what, and at what depth?
An NBFC can structure the learning architecture around different participant groups.
All Employees
Focus on practical cyber awareness:
- phishing;
- password and credential safety;
- social engineering;
- data protection;
- device security;
- safe digital behaviour; and
- incident escalation.
Compliance, Risk and Internal Audit
Focus on:
- RBI cyber requirements;
- governance and accountability;
- cyber-risk assessment;
- control testing;
- incident escalation;
- third-party exposure;
- resilience; and
- evidence of compliance.
IT and Information Security
Deeper technical and governance coverage may include:
- access-control frameworks;
- vulnerability management;
- network and application security;
- monitoring;
- privileged access;
- incident response;
- technology change management; and
- disaster recovery.
Senior and Middle Management
RBI also requires periodic assessment of IT training requirements to ensure sufficient technical competence and capable resources at senior and middle-management levels. (TrackRBI)
Training at this level should therefore focus on:
- cyber-risk ownership;
- material exposures;
- risk acceptance;
- escalation;
- vendor dependence;
- resilience;
- management reporting; and
- decision-making during incidents.
The annual training calendar should also respond to actual changes in risk. A major technology migration, cloud adoption, new digital lending arrangement, vendor incident or material change in the threat landscape may justify additional training rather than waiting for the next scheduled annual programme.
The governing principle should be:
Train according to regulatory obligation, role, technology exposure and demonstrated capability gap.
Relevant RMAI Training Programmes
For Risk, Compliance, Internal Audit, IT governance and technology leaders who require deeper sector-oriented learning, RMAI offers the Cyber Security & Technology Risk Management in Banking programme through its training arm Smart Online Course. The 7-hour programme covers cyber and technology risk, governance responsibilities, vendor and cloud exposure, API risk, access-control governance, incident response, data privacy oversight and Board-level cyber-risk reporting.
Explore Cyber Security & Technology Risk Management in Banking →
For wider employee populations that require a shorter foundational intervention, the Cybersecurity: Protect Yourself in a Digital World programme provides a 1-hour practical awareness module covering phishing, personal and financial data protection, secure passwords, safer browsing and digital-identity protection. (Smart Online Course)
Explore the Cybersecurity Awareness programme →
An NBFC can use the two programmes differently: a short awareness programme for the broader employee population and deeper technology-risk training for Compliance, Risk, Audit, IT governance and oversight functions.
Looking for an NBFC-Specific Cybersecurity Training Programme?
The RBI’s 2026 framework makes it important for NBFCs to move beyond one-time cyber awareness and build an ongoing, measurable and documented information-security learning programme.
The Risk Management Association of India (RMAI) can support NBFCs with:
- employee-wide cybersecurity awareness programmes;
- role-based cyber and technology-risk learning;
- institutional online training;
- faculty-led virtual programmes;
- classroom training;
- workshops for Compliance, Risk, Internal Audit and IT teams;
- cybersecurity and operational-resilience training; and
- RBI-aligned annual training calendars for different employee groups.
RMAI can work with Chief Compliance Officers, CROs, CISOs, Internal Audit Heads and HR/L&D teams to determine which employees require basic awareness and which functions need deeper cyber-governance and technology-risk capability.
NBFCs can also structure the programme around measurable outcomes such as completion tracking, assessments, role-based learning and periodic refresher training, helping align capability-building more closely with RBI’s regulatory expectations.
Organisations may request a course outline, institutional training proposal or RBI-aligned annual cybersecurity training plan based on their employee population and regulatory requirements.
Risk Management Association of India
www.rmaindia.org
Email: info@rmaindia.org
Phone: +91 82320 83010
