Guideline on Scope of Cybersecurity Audit in Power Sector Nov 2024
Guideline on Scope of Cybersecurity Audit in Power Sector Nov 2024
Government of India
Ministry of Power
Power sector utilities are mandated to conduct periodic cybersecurity aud1t of both
Information Technology (IT) and Operational Technology (OT) assets, through auditors
empanelled by the CERT-In as per Article 14 of Central Electricity Authority (Cyber Security
Power Sector) Guidelines 2021. As the scope of such aud1t varies across utilities, it was
necessitated to fornmulate the scope of cyber security audit for power sector utilities.
Accordingly, CSIRT-Power has prepared "Guidelines on Scope of Cybersecurity Audit
in Power Sector" in consultation with various power sector utilities, sub-sectoral CERTs,
CERT-In, NCIIPCetc. The same is issued hereby for compliance of all concerned.
Encl.: Guidelines on Scope of Cybersecurity Aud1t in Power Sector
(R. P. Pradhan)
CISO, Ministry of Power
3rd Floor, NRPC.Shaheed Jeet Singh Marg New Delh1 Tele 011-26561171 Ema1l cso nopg gov in
Guidelines on
Scope of Cybersecurity Audit
in the Power Sector
Issued by
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
1 Purpose and Objectives
1.1 Purpose
1. Power sector utilities are mandated to conduct periodic cybersecurity audit of both
Information Technology (IT) and Operational Technology (OT) assets, through auditors
empanelled by the Computer Emergency Response Team - India (CERT-In). In alignment
with the directions provided, these cybersecurity audits go beyond Vulnerability Assessment
and Penetration Testing (VA/PT) of applications and systems. They encompass a thorough,
comprehensive audit of the deployed cyber infrastructure, ensuring a robust and holistic
approach to cybersecurity.
2. The utility should engage a CERT-In empanelled auditor with domain-specific
expertise to assess both IT and OT environments, as applicable. To ensure an independent
audit, the utility should directly hire a third-party CERT-In empanelled auditor, regardless of
whether the infrastructure is managed by the utility or a service provider. This approach
avoids conflicts of interest and ensures a neutral evaluation.
4. Part 1 outlines guidelines for scope of cybersecurity audits to assess and validate the
utility's overall cybersecurity posture, focusing on policies, processes, procedures, practices,
governance structures, and compliance with regulatory requirements. Part 2 defines the
scope of Vulnerability Assessment (VA) and Penetration Testing (PT) to address technical
cybersecurity evaluations.
1.2 Objectives
The audit should adhere to applicable cybersecurity standards, such as ISO 27001, IS 16335,
and the IEC 62443 series, and verify the utility’s cybersecurity resilience, including its
compliance with applicable cybersecurity rules, regulations, directives, and guidelines.
1. Comprehensive Coverage of Cyber Assets: The audit should ensure a thorough and
comprehensive cybersecurity assessment of cyber assets within the power sector utility,
enabling the identification and mitigation of vulnerabilities.
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
2. Assessment of IT and OT Architecture Resilience: It should assess the robustness of IT
and/or OT architecture within the utility's interconnected environment.
3. Verification of Technical Controls and System Hardening: The audit should provide a
structured evaluation of the effectiveness of implemented technical controls, hardening
measures, and the configuration of security devices.
5. Regulatory Compliance: The audit should enable the utility to verify compliance with
applicable Acts, Rules, Regulation, Directives, and Guidelines issued by Government of
India.
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
2 Part 1 - Guidelines for Scope of comprehensive
Cybersecurity Audit.
The specific audit areas are outlined in detail in the following sections.
1. all the identified Critical Information Infrastructures and notified Protected Systems of
the utility,
3. all medium and low-risk assets, (If the number of assets is too large to be audited in a
single audit, the utility may use a sampling and rotational approach)
4. all web applications, mobile applications and cloud-based applications including APIs,
internal applications as per risk based,
5. the utility's existing cybersecurity policies, processes, and procedures. This includes
reviewing of the Service Level Agreements (SLAs) with third-party vendors to ensure
that SLA meets appropriate cybersecurity requirements,
7. review of the network architecture and data flow in both IT and OT environments,
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
9. vulnerability analysis of all notified protected systems and critical and high-risk assets,
with medium and low-risk assets covered on a sample and rotational basis,
11. verification audit for compliance with applicable cybersecurity Rules, Regulations
Directives and Guidelines issued by CERT-In, National Critical Information
Infrastructure Protection Centre (NCIIPC), Central Electricity Authority (CEA) and other
Government Entities.
12. review of the architecture at both main and backup control centers including their
interconnections and data flow.
14. review of Cyber Crisis Management Plan of the utility and effectiveness of its
implementation,
1. Audit of Cybersecurity Policy Effectiveness and Alignment: The auditor will verify
whether cybersecurity policy complies with latest edition of ISO 27001 and ISO 27019
standards, as applicable. This includes ensuring alignment with business goals, legal
obligations, and contractual terms. Audit shall also verify the exceptions to ensure that
these exceptions are authorised, legitimate and valid.
2. As applicable, audit of the OT specific cybersecurity policy, and its compliance with
sector specific cybersecurity standards like IS 16335 and IEC 62443 series.
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
3. Audit of the cybersecurity governing structure such as designation of CISO with ring
fenced cybersecurity duties, existence of dedicated division for cybersecurity with
defined roles & responsibilities and staffed with adequate and trained manpower.
4. Audit of the asset management process, and verification of the asset identification and
classification process is in place.
5. Audit of the Vulnerability Management Process in both IT and OT systems for periodic
identification and closure of vulnerabilities,
6. Audit of Risk Management Process to evaluate how the utility identifies, assesses, and
manages cybersecurity risks.
7. Audit of the processes for managing changes to IT and OT systems and configurations.
Audit of patch management procedures for applying patches to IT and OT systems,
including pre-patch testing, post-patch validation, and rollback procedures.
9. Audit of the personnel risk assessment process present with utility to mitigate internal and
external cybersecurity risks from their own personnel or from that of their Service
Provider having access to their critical and high-risk assets
10. Audit of the process and procedure, in place for safe & secure disposal of legacy systems
to verify that such systems are disposed as per established process.
11. Audit of the Supply Chain Risk Management system to evaluate their effectiveness in
securing the supply chain and managing associated risks. This includes audit of the
outsourced activities to mitigate risks from third-party vendors and their adherence to
utility cybersecurity policy and regulatory requirements.
12. Audit of existing cybersecurity training and awareness program to verify its suitability
and adequacy. This includes assessment of user awareness w.r.t organisation’s security
policies, evaluation of the employee’s susceptibility to social engineering attacks, such as
phishing and impersonation.
13. Verification of the availability of a tailored and approved Cyber Crisis Management Plan
(CCMP) that includes utility-specific cyber-attack scenarios and procedures, and
assessment of whether the CCMP's efficacy is tested through mock drills and exercises.
14. Review of the business continuity and disaster recovery plans to ensure they are
comprehensive and up to date.
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
2.3.2 Audit of Identity and Access Management (IAM)
4. Audit of defined remote access policies and implemented cybersecurity measures by the
utility for remote access cybersecurity.
5. Audit of mobile device policies, addressing cybersecurity risks associated with use of
external removable and BYOD systems as defined in cybersecurity policy.
1. Audit of the process for data classification based on sensitivity and criticality.
2. Audit to check the implementation of data retention, data access controls, and data
leakage prevention mechanism. This includes audit of the mechanism/ system used for
data encryption to evaluate their effectiveness in protecting sensitive data, both at rest and
in transit.
3. Audit to check the effectiveness of data backup strategies and the ability to recover from
data loss or corruption.
4. Audit of Cryptographic controls, key management, and key storage mechanism (if in
use).
5. Audit of the practices used or followed for In-house or Out-sourced application
development, secured coding practices and code testing process.
6. Audit to check implementation of data security and data privacy measures to ensure
compliance with applicable rules and regulations for protection of sensitive data.
7. Audit the cybersecurity mechanisms deployed in the database to identify potential threats
and ensure the protection of sensitive information.
8. Evaluation of the measures in place for data protection in cloud environments, including
backup and encryption.
9. Review of the security practices of cloud service providers and any third-party
integrations.
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
2.3.4 Logging and Monitoring
1. Audit of the mechanism/system in place to monitor, detect and log events of deployed
security devices, networks, end devices and hosts.
2. Review of the logs storage systems in place to comply with existing regulatory
requirements. This includes review of the operational and functional efficacy of the
Security Operational Centre (SOC) to check for threat detection and response capabilities.
3. Review of the deployment and effectiveness of logging and monitoring solutions, such as
SIEM, to ensure timely detection and response to security incidents.
1. Audit of the incident response process and customization for the power sector, and its
effectiveness across IT and OT systems.
2. Evaluation of the effectiveness of the deployed tools and processes for detecting and
monitoring of the cybersecurity incidents
4. Review of previous audit / Incident Report (IR) reports and their compliance status.
3. Audit to check the security configurations of servers, workstations, and other endpoints
and to verify the deployment of Endpoint Security solutions such as Antivirus, EDR
solutions.
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
blocking of unnecessary ports and services, whitelisting of applications, and others in
comparison with cybersecurity benchmarks like CIS Benchmarks.
1. Audit of physical Access controls to evaluate the effectiveness of physical access controls
and surveillance systems, visitor management, and employee identification systems.
2. Review of logs and records of physical access and Comparison of physical security
measures with industry standards and best practices.
3. Audit of the mechanism/system in place for Protection from physical and environmental
threats, such as natural disasters and other intentional or unintentional physical threats to
infrastructure.
1. Vulnerability analysis of all notified Protected Systems, critical and high-risk assets.
Medium and low-risk assets should be covered on a sample and rotation basis.
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
2. Active Vulnerability Assessments and Penetration Testing may be conducted in
simulated environments or isolated test setups. Additionally, whenever possible,
targeted testing should be performed on testbeds or during planned maintenance
windows to assess system vulnerabilities. In latter case, the target OT systems and
their components should be clearly identified to minimize operational impact.
Components that cannot tolerate downtime or interruptions should be excluded from
testing.
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
2.4 Audit Deliverables
1. Detailed plan outlining objectives, scope, methodology, and timeline.
2. Auditor should immediately inform the critical findings observed (if any) during audit to
utility for their immediate action.
8. Identified gap and Suggestion to update cybersecurity policies, procedures, and controls
based on audit findings and evolving threats.
9. The audit report shall provide a comprehensive and detailed account of the entire audit
process. It should include identified vulnerabilities, risks, non-compliance issues, with
artefacts and evidence and areas for improvement.
10. The audit report should also encompass the audit mechanism, detailed scope, duration,
methodologies, standards used, tools, manual processes, findings, prioritization, sampling
decisions, manpower involved, as well as any exemptions, limitations, and other
constraints encountered during the audit. Additionally, a list of the testing software or
tools used should be included.
11. The report should begin with an executive summary that offers a concise overview of the
audit findings, highlighting the associated risks to the organization and the overall
security posture of the audited application or infrastructure. This summary is intended for
submission to higher management, including board members.
12. Exit briefing: Convey preliminary interim audit observations to the utility, such as critical
findings, vulnerabilities, major gaps etc. which require immediate attention / action and
educating the utility in providing feedback to the empanelling agency about the quality of
the audit performed by empanelled auditors at utility end.
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
2.5 References & Sources
1. International Organization for Standardization. ISO/IEC 27001: Information technology
– Security techniques – Information security management systems – Requirements.
2. International Organization for Standardization. ISO/IEC 27005: Information technology
– Security techniques – Information security risk management.
3. National Institute of Standards and Technology. (2008). NIST SP 800-115: Technical
guide to information security testing and assessment.
4. Open Web Application Security Project. OWASP Testing Guide.
5. SANS Institute. (n.d.). SANS Penetration Testing Methodology.
6. International Electrotechnical Commission. IEC 62443-3-2: Industrial communication
networks – Network and system security – Part 3-2: Security risk assessment and system
design.
7. National Institute of Standards and Technology. (2010). NIST IR 7628: Guidelines for
Smart Grid Cybersecurity.
8. North American Electric Reliability Corporation. (n.d.). NERC CIP Standards.
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3 Part-2: Guideline on the Scope of Vulnerability
Assessment (VA) & Penetration Testing (PT)
This guideline outlines the scope, activities, methodology, and deliverables for conducting a
Vulnerability Assessment (VA) & Penetration Testing (PT) audit. Part-2 should be
implemented in conjunction with Part-1 for a comprehensive cybersecurity audit.
The scope of the VA/PT assessment should be defined in accordance with the Scope of Audit
(2.1) outlined in Part 1 - Guidelines for the Scope of a Comprehensive Cybersecurity Audit.
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
3.2 Vulnerability Assessment (VA)
Objective is systematic examination of IT and OT system or product to identify security
deficiencies, determine the adequacy of security measures, provide data from which to
predict the effectiveness of proposed security measures, and confirm the adequacy of such
measures after implementation.
3.2.1 Activities
i. Port and Network Scanning: Identify open ports and services running on the network.
ii. Vulnerability Scanning: Use automated tools to detect vulnerabilities across all systems
in scope.
iii. System and Service Identification: Enumerate and fingerprint operating systems and
services.
iv. Malware Scanning: Detect and analyse any malware or potential threats within the
network.
v. Password Strength Assessment: Assessment of the strength of passwords.
vi. Authentication and Authorization Testing: Test access control mechanisms and account
lockout policies.
vii. Configuration Assessment: Assessment of network devices configuration such as
firewall configurations for security gaps.
viii. Server and Database Assessment: Evaluate OS and database configurations for
vulnerabilities.
ix. Any additional activities as mutually agreed upon by the utility and the auditor.
3.2.2 Methodology
The utility, in consultation with the selected vendor, should finalize the methodologies.
However, at a broader level, the following structured approach is suggested:
i. Preparation: Define the scope, identify assets, and determine the boundaries for
analysis.
ii. Execution: Conduct assessments using both automated tools and manual techniques, as
applicable.
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
iii. Analysis: Analyse the results to identify the vulnerabilities and security gaps.
iv. Reporting: Document findings, categorize vulnerabilities by risk level, and provide
remediation recommendations.
3.2.3 Deliverables
(b) categorization of vulnerabilities by risk level (e.g., Critical, High, Medium, Low).
(c) assessment of the potential impact of the vulnerabilities on the system and operations
of the utility.
(d) technical documentation with scan results and screenshots supporting the identified
vulnerabilities.
(a) the steps necessary to close identified vulnerabilities, including any required patches
or configuration changes.
(b) comparison of current security posture against industry benchmarks and standards.
(c) plan for overall improvement of the cybersecurity posture by adherence to relevant
security standards and best practices
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
systems to achieve broader access than would be possible through a single vulnerability
alone.
Internal Penetration Testing may be conducted to simulate an insider attack for identification
of potential vulnerabilities within the internal network and applications.
ii. Servers and Workstations: Internal-facing servers, desktops, and other endpoints.
3.3.1.1 Activities
i. Port Scanning and System Enumeration: Identify open ports, running services, and
system details.
ii. Security Bypass: Attempt to bypass security controls such as EDR, firewalls and
intrusion detection/prevention systems (IDS/IPS).
iii. Privilege Escalation: Test for potential paths to escalate privileges within the network.
v. Lateral Movement: Evaluate the ability to move laterally within the network after initial
compromise.
vi. Data Exfiltration: Simulate data exfiltration scenarios to test data security.
3.3.1.2 Methodology:
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
ii. Reconnaissance: Gathering the information about the internal network, systems, and
users to identify potential targets and vulnerabilities.
3.3.1.3 Deliverables
3.3.2.1 Scope
ii. Web Applications: Web applications and Mobile applications accessible via the internet.
iii. Firewall and Security Devices: External security devices such as firewalls and IDS/IPS
systems.
3.3.2.2 Activities
i. Reconnaissance: Gather information about the target network and its public IPs.
ii. Port Scanning: Identify open ports and services on public-facing systems.
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
iii. Vulnerability Exploitation: Attempt to exploit known vulnerabilities in public-facing
systems.
iv. Attack Simulation: Simulate various attacks such as SQL injection, cross-site scripting
(XSS), and remote code execution (RCE).
v. Denial of Service (DoS) Testing: Simulate DoS attacks to assess system resilience.
vi. Firewall and IDS/IPS Testing: Assess the effectiveness of perimeter defences.
3.3.2.3 Methodology
i. Preparation: Define the scope, identify public-facing assets, and establish testing
windows.
ii. Testing: Conduct external penetration tests using both manual techniques and automated
tools.
iii. Analysis: Analyse test results to identify vulnerabilities and potential security risks.
iv. Reporting: Document all findings and provide recommendations for improving external
security.
3.3.2.4 Deliverables
ii. Security Improvement Plan: A plan outlining steps to enhance the security posture of
external-facing systems.
3.4.1 Scope
i. Web and Mobile Applications: All publicly exposed web-based and mobile applications.
ii. APIs: Application Programming Interfaces (APIs) associated with the web applications.
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
3.4.2 Activities
i. Input Validation: Test for vulnerabilities such as SQL injection, cross-site scripting, and
input validation flaws.
v. Data Exposure: Test for sensitive data exposure and improper data handling.
vi. API Security: Assess the security of APIs associated with the web applications.
3.4.3 Methodology
i. Black Box Testing: Conduct testing without prior knowledge of the internal workings of
the application.
ii. Gray Box Testing: Combine black box testing with some knowledge of the application’s
internals.
iii. Manual and Automated Testing: Use a combination of automated tools and manual
techniques to identify vulnerabilities.
3.4.4 Deliverables
ii. Compliance Check: Ensure that the application complies with relevant security standards
such as OWASP Top Ten.
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
3.5.1.1 Scope
ii. Compliance Assurance: Ensure that all remediation activities align with power sector
requirements and relevant standards.
3.5.1.2 Deliverables
i. Remediation Report: A report detailing the remediation efforts and verifying the closure
of identified vulnerabilities.
3.6 Re-Scan
Objective -To verify that previously identified vulnerabilities have been effectively
remediated.
Validation: Validate the effectiveness of the remediation efforts through a comprehensive re-
scan.
Re-Scan Report: A report confirming the closure of vulnerabilities and the overall
improvement in security posture.
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024
3.7 Standards and Guidelines
1. National Institute of Standards and Technology. (2008). NIST SP 800-115:
Technical guide to information security testing and assessment.
End of Document
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Guidelines on Scope of Comprehensive Cybersecurity Audit in the Power Sector Version 1.0, Nov 2024