NBFCs and Lending
Securing lending platforms, borrower data and regulatory compliance
INDUSTRY FACT FILE · NBFCS & LENDING
Applicable Cybersecurity Services and Codec Networks Bundles for NBFCs
How Codec Networks services and bundled service models help NBFCs resolve their threats, meet layer-specific RBI requirements and reduce business impact.
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In this document 1. Our approach 2. Mapping threats to services 3. Codec Networks service catalogue for the sector 4. Codec Networks bundles for the sector 5. Sector programmes built from the bundles 6. Packages: Foundation, Assurance and Continuous Resilience 7. Regulatory requirement-to-bundle mapping 8. Threat-to-bundle coverage matrix 9. Delivery methodology and deliverables 10. Why Codec Networks 11. Annex: indicative commercial ranges |
1. Our approach
NBFCs need assurance that is proportionate to their layer and focused on the lending chain. Codec Networks works on four principles:
- Start with applicability: map the NBFC's layer, type and activities to the right chapter of RBI's 2026 Directions and related lending rules.
- Follow the loan: test origination, partners, onboarding, underwriting, disbursement and collections end to end.
- Assure the partners: treat LSPs, DSAs, dealers and co-lenders as part of the attack surface.
- Prove closure: retest findings and organise evidence for the Board, auditors, bank partners and RBI or NHB.
2. Mapping threats to services
The table maps the 18 threats identified in Document 4 of this set to the Codec Networks services that help mitigate them.
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Threat / challenge |
Applicable Codec Networks services |
Intended outcome |
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Synthetic identity and document fraud |
Onboarding and V-CIP controls review, document-verification testing, fraud risk assessment |
Fewer fraudulent loans approved |
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Dealer, DSA and agent collusion |
Fraud analytics, EWS framework review, forensic audit, process-bypass testing |
Earlier detection of collusive clusters |
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Fake lending apps |
Brand and rogue-app monitoring, takedown support, anti-phishing |
Faster removal of impersonation |
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Lending app and API exposure |
Application and API security testing, secure code review, DevSecOps |
Flaws found before release |
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Account takeover and payout diversion |
Authentication and payout-flow testing, IAM & MFA bypass testing, SOC monitoring |
Protected disbursements and refunds |
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Phishing and BEC |
Phishing simulation, awareness, DMARC review, deepfake testing |
Reduced impersonation success |
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Ransomware |
Ransomware simulation, backup security testing, EDR/XDR validation, IR retainer |
Tested recovery and smaller blast radius |
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Insider and field-agent misuse |
Insider threat simulation, data exfiltration simulation, access reviews |
Accountability for sensitive actions |
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Third-party and LSP compromise |
Third-party risk management, LSP and DSA assessments, contract review |
Enforceable partner controls |
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Cloud misconfiguration |
Cloud security audit, IAM and storage reviews |
Continuous posture visibility |
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Field device compromise |
Mobile app testing, MDM and remote-wipe review, DLP |
Protected offline borrower data |
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Loan data manipulation |
LOS/LMS access and workflow testing, maker-checker review, forensic audit |
Integrity of loan records |
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Co-lending data tampering |
Integration and file-integrity testing, secure transfer review |
Trusted partner data exchange |
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Data leakage and privacy failures |
DPDPA readiness, data discovery and classification, DLP review |
Reduced data footprint |
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Weak detection and response |
Managed SOC, SIEM use-case tuning, playbooks, tabletop exercises |
Reliable 6-hour reporting |
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Deepfake-assisted fraud |
AI-powered deepfake testing, V-CIP liveness review |
Verification that assumes impersonation |
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Backup and recovery failure |
Backup and DR testing, DR drill observation |
Proven recovery |
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Mule accounts |
Disbursement and repayment account analytics, SOC fraud use cases |
Fewer mule-linked loans |
3. Codec Networks service catalogue for the sector
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Service line |
Sector-relevant services |
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Security Vulnerability Assessment & Penetration Testing |
Six-monthly VA and annual PT for Middle Layer and above; web, mobile and API testing of lending apps, LOS and LMS; cloud, network and database testing; configuration review |
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Offensive security & people/process testing |
Red teaming, phishing simulation, IAM & MFA bypass testing, loan-approval workflow bypass testing, insider threat simulation, deepfake testing |
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Information security consulting, audit & compliance |
Layer applicability assessments against RBI's 2026 Directions, IS audit, fraud risk and EWS framework reviews, ISO/IEC 27001:2022, third-party risk management |
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Data privacy & protection |
DPDPA readiness, DPIA, consent review for lending apps, data discovery and classification, DLP, breach response |
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24/7 Managed SOC & threat monitoring |
SOC-as-a-Service, SIEM, managed EDR/XDR, SOAR, fraud and EWS signal correlation, brand and rogue-app monitoring |
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Cyber forensics & threat analysis |
Loan-fraud and collusion investigations, device and mobile forensics, malware analysis, cloud forensics |
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Board-level advisory |
Board and ITSC briefings, cyber risk quantification, CISO support, crisis communication readiness |
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Emerging technology security |
AI and LLM security for underwriting and collections, ISO 42001 readiness |
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Centre for Professional Excellence (CoPE) |
Awareness for branch, field and collection teams; CISO workshops and certification training |
4. Codec Networks bundles for the sector
Eleven of the twelve bundles in the Codec Networks Bundled Service Models apply directly to NBFCs and lenders; the Global Cyber Back-Office SPV Program (Bundle 12) is offered separately for international clients.

Figure 6: Codec Networks bundles applied to the sector.
|
Bundle |
Name |
Sector-relevant scope |
Best suited for |
Key deliverables |
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B1 |
Cyber Assessment & VAPT Assurance Program |
Six-monthly VA, annual PT, configuration review, retest |
Middle Layer NBFCs and above; all lenders before launches |
VAPT reports, remediation tracker, retest report |
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B2 |
Application, API & DevSecOps Security Program |
Lending apps, LOS, LMS, partner APIs, secure SDLC |
Digital and partner-led lenders |
Application and API risk report, code review report |
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B3 |
Cloud, Infrastructure & Zero Trust Security Program |
Cloud LOS/LMS, IAM, segmentation, remote access |
Cloud-native NBFCs and those migrating |
Cloud posture report, IAM review |
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B4 |
Regulatory Cybersecurity Audit & Compliance Assurance Program |
Layer applicability and gap assessments, IS audit support, evidence index |
All NBFCs aligning to the 2026 Directions |
Applicability matrix, gap assessment, evidence index |
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B5 |
GRC, ISO, SOC 2 & Cyber Maturity Program |
ISO 27001, policies, risk register, fraud risk assessment |
NBFCs formalising governance for partners and investors |
Maturity scorecard, policy framework |
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B6 |
Data Privacy, DPDPA & Data Protection Program |
Borrower data mapping, consent, retention, DLP |
All NBFCs ahead of May 2027 |
Privacy gap assessment, data inventory |
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B7 |
Managed SOC, MDR & Continuous Threat Monitoring Program |
24x7 SOC, SIEM, EDR/XDR, fraud and EWS signals |
NBFCs without in-house 24x7 monitoring |
SOC reports, incident tickets, MTTD/MTTR |
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B8 |
Digital Forensics, Incident Response & Malware RCA Program |
Loan-fraud investigations, triage, device forensics |
Any NBFC facing fraud or compromise |
Forensic evidence index, RCA |
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B9 |
Third-Party Risk Management & Supply Chain Cyber Risk Program |
LSP, DSA, dealer, co-lender and SaaS assessments |
Partner-led and digital lenders |
Vendor risk assessments, remediation plan |
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B10 |
Cyber Simulation, Awareness, Tabletop & Crisis Readiness Program |
Phishing, ransomware, insider and deepfake simulations, tabletops |
Boards, treasury, branch and field teams |
Campaign and tabletop reports |
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B11 |
Emerging Technology, AI, Web3 & Future Security Program |
AI/LLM testing, ISO 42001 readiness |
Lenders using AI in underwriting or collections |
AI/LLM risk assessment |
5. Sector programmes built from the bundles
Codec Networks packages the catalogue bundles into six NBFC programmes that match common buying needs.
|
Programme |
Built from bundles |
Challenges addressed |
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NBFC Applicability and Governance |
B4, B5 |
Unclear layer obligations, policy and governance gaps |
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Lending Platform Security |
B2, B1 |
Lending app, LOS, LMS and API weaknesses |
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Partner and LSP Assurance |
B9, B2 |
LSP, DSA, dealer and co-lending exposure |
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Fraud Detection and Forensics |
B7, B8 |
Document fraud, collusion, mule-linked loans |
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Borrower Data Protection |
B6, B3 |
DPDP readiness, field-device and cloud data exposure |
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Resilience and Response |
B7, B10, B8 |
Ransomware, DR readiness, 6-hour reporting |
6. Packages: Foundation, Assurance and Continuous Resilience
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Package element |
Foundation |
Assurance |
Continuous Resilience |
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Typical NBFC |
Base Layer NBFCs and growing lenders |
Middle Layer NBFCs and HFCs |
Upper Layer and large NBFCs |
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Testing |
B1: scoped VAPT and retest |
B1 + B2: six-monthly VA, annual PT, app and API testing |
B1 + B2 + B10: continuous testing, red teaming, simulations |
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Regulatory and GRC |
B4: layer applicability assessment |
B4 + B5: gap assessment, IS audit support, evidence pack |
B4 + B5 + B9: multi-entity evidence, partner assurance |
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Cloud and privacy |
B3: infrastructure review |
B3 + B6: cloud posture and DPDPA readiness |
B3 + B6 + B11: continuous assurance, privacy and AI governance |
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Monitoring and response |
Optional IR retainer (B8) |
B7: extended-hours SOC + B8 retainer |
B7: 24x7 SOC with fraud correlation + B8 |
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Reporting |
Assessment report and roadmap |
Consolidated risk and remediation reporting |
Quarterly Board and ITSC reporting |
7. Regulatory requirement-to-bundle mapping
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Requirement (RBI 2026 NBFC Directions unless stated) |
How Codec Networks helps |
Bundle |
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All NBFCs: Board-approved technology and cyber policies, reviewed at least annually |
Policy framework review and Board packs |
B5 |
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All NBFCs: cyber incidents on DAKSH within six hours (HFCs to NHB); CERT-In notified |
IR retainer, playbooks and reporting support |
B7, B8 |
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Base Layer < ₹500 crore and CICs: baseline IT policy, access controls, BCP and tested backups |
Baseline assessment and backup testing |
B4, B10 |
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Base Layer ≥ ₹500 crore: ITSC at least six-monthly; IS audit at least annually |
IS audit support and governance review |
B4 |
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Middle Layer and above: VA six-monthly, PT annually for critical and customer-facing systems |
Scheduled VA/PT with retest |
B1 |
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Middle Layer and above: DR drills at least half-yearly; BCP tested annually |
DR drill observation and recovery testing |
B1, B10 |
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Middle Layer and above: CISO quarterly review; ITSC at least quarterly |
Board and ITSC reporting support |
B5 |
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Digital Lending Directions 2025: LSP and DLA oversight, borrower-data restrictions |
Lending app, LSP and API assurance |
B2, B9 |
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Fraud Risk Directions 2024: EWS framework and red-flagging (Upper and Middle Layers) |
EWS review, fraud analytics, forensic audit |
B7, B8 |
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DPDP Act and Rules: safeguards and breach intimation (from May 2027) |
DPDPA programme and breach drills |
B6 |
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Auditor eligibility and independence Where a regulator, standard or contract requires CERT-In empanelled or independent auditors, Codec Networks—CERT-In empanelled for information security auditing services—confirms eligibility and independence in each proposal. |
8. Threat-to-bundle coverage matrix
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Threat / challenge |
Primary bundle |
Supporting bundles |
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Synthetic identity and document fraud |
B8 |
B4, B7 |
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Dealer and agent collusion |
B8 |
B7 |
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Fake lending apps |
B7 |
B10 |
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Lending app and API exposure |
B2 |
B1 |
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Account takeover and payout diversion |
B2 |
B7 |
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Phishing and BEC |
B10 |
B7 |
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Ransomware |
B7 |
B8, B10 |
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Insider and agent misuse |
B7 |
B8 |
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Third-party and LSP compromise |
B9 |
B2 |
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Cloud misconfiguration |
B3 |
B7 |
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Field device compromise |
B2 |
B6 |
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Loan data manipulation |
B8 |
B4 |
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Co-lending data tampering |
B9 |
B3 |
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Data leakage |
B6 |
B3 |
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Weak detection and response |
B7 |
B8, B10 |
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Deepfake-assisted fraud |
B10 |
B11 |
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Backup and recovery failure |
B10 |
B1 |
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Mule accounts |
B7 |
B8 |
“Primary” and “supporting” indicate suggested combinations, not guaranteed mitigation or complete coverage.
9. Delivery methodology and deliverables

Figure 7: The Codec Networks delivery methodology.
Typical deliverables include a layer applicability matrix, an executive summary for the Board or ITSC, a technical findings register with evidence and CVSS ratings, a compliance gap matrix mapped to the 2026 Directions, a prioritised remediation roadmap, retest reports and an evidence tracker for auditors, bank partners and RBI or NHB.
10. Why Codec Networks
- CERT-In empanelled for information security auditing services, and empanelled with NICSI for application audit and compliance services (start-up category).
- Certified to ISO 9001:2015, ISO/IEC 27001:2022 and ISO/IEC 20000-1:2018.
- Full stack: VAPT, regulatory audit, managed SOC, forensics, privacy and Board advisory from one partner, so findings, monitoring and closure stay connected.
- Lending depth: lending app, LOS, LMS, partner API, field-device and fraud-scenario testing aligned to RBI's 2026 NBFC Directions and digital lending rules.
- Recognised frameworks and tools: OWASP ASVS/MASVS and API Top 10, MITRE ATT&CK, NIST CSF, ISO 27001 and PCI DSS; tools such as Burp Suite, Nessus, Metasploit, Prowler and leading SIEM/EDR platforms.
- Certified people: CEH, OSCP, CPENT, CISA, ISO 27001 LA/LI, CHFI, CTIA and ECIH professionals.
Annex: Indicative commercial ranges
For internal sales reference only—remove this annex before sharing externally. Ranges are taken from the Codec Networks Bundled Service Models and are subject to scoping, asset counts, frequency and service levels.
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Bundle |
Package examples and indicative ranges |
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B1 VAPT Assurance |
Essential ₹1.5–5 lakh; Professional ₹5–15 lakh; Enterprise ₹15–40 lakh; Annual retainer ₹25 lakh–₹1.5 crore |
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B2 AppSec & DevSecOps |
API Quick Check ₹2–6 lakh; AppSec Professional ₹8–20 lakh; DevSecOps Maturity ₹12–35 lakh; Secure SDLC retainer ₹3–15 lakh/month |
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B3 Cloud & Zero Trust |
Cloud Essential ₹3–8 lakh; Professional ₹8–25 lakh; Enterprise ₹25–75 lakh; Continuous assurance ₹2–10 lakh/month |
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B4 Regulatory Audit |
Gap review ₹5–15 lakh; Full regulatory audit ₹15–50 lakh; Multi-framework audit ₹30 lakh–₹1.25 crore; Annual retainer ₹3–20 lakh/month |
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B5 GRC, ISO, SOC 2 |
ISO readiness ₹5–15 lakh; ISO implementation ₹15–45 lakh; SOC 2 readiness ₹15–60 lakh; GRC retainer ₹2–12 lakh/month |
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B6 Privacy & DPDPA |
Quick assessment ₹3–10 lakh; Implementation ₹10–40 lakh; DPO-as-a-Service ₹2–8 lakh/month; Privacy retainer ₹3–15 lakh/month |
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B7 Managed SOC |
Starter ₹2–5 lakh/month; Professional ₹5–15 lakh/month; Enterprise ₹15–50 lakh/month; co-managed per FTE/shift |
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B8 Forensics & IR |
Triage ₹3–15 lakh; Full investigation ₹15–75 lakh; Ransomware response ₹25 lakh–₹1.5 crore; IR retainer ₹5–50 lakh/year |
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B9 TPRM |
₹25,000–₹2 lakh per vendor; batch pricing for 50–500 vendors; retainer ₹3–25 lakh/month |
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B10 Simulation & Tabletop |
Awareness ₹1–5 lakh; Phishing simulation ₹2–10 lakh; Tabletop ₹5–20 lakh; Cyber war-game ₹15–75 lakh; Annual retainer ₹10 lakh–₹1 crore/year |
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B11 Emerging Tech |
AI/LLM risk review ₹5–25 lakh; Smart contract audit ₹5–50 lakh; Emerging tech retainer ₹5–25 lakh/month |
Talk to Codec Networks
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Contact Codec Networks Pvt. Ltd. New Delhi: 507, 5th Floor, New Delhi House, Barakhamba Road, Connaught Place, New Delhi – 110001 Gurugram: 707, 7th Floor, Silverton Tower, Golf Course Extension Road, Sector 50, Gurugram – 122018, Haryana Landline: 011 430 496 96 | 011 437 522 99 Mobile: +91 99716 76124 | +91 88007 88220 | +91 88003 31124 Email: mktg@codecnetworks.com Web: www.codecnetworks.com |
Note: Service scope, deliverables, monitoring coverage and service levels are confirmed during engagement scoping. Services support risk reduction and assurance but do not guarantee prevention of all cyber incidents or regulatory compliance. Regulatory references are summaries; confirm against the official instruments applicable to each entity.