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ARTICLE · 29 OCTOBER 2026

One Incident, Many Clocks: SEBI’s FIRE Format And The DPDP Breach Rules

Sarthak Advocates & Solicitors
Sarthak Advocates & Solicitors
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Sarthak Advocates & Solicitors

Sarthak Advocates & Solicitors

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A recent exchange on LinkedIn raised a practical question: if a ransomware note arrives tonight, can your team file a report compliant with the requirements of the Securities and Exchange Board of India (“SEBI”) by tomorrow without waiting for legal review? The main difficulty the organisations face is in deciding what to report before the facts are clear. SEBI’s new format brings this issue into focus.

IndiaPrivacy
Abhishek Tripathi
Abhishek Tripathi
Adesh Mishra
Adesh Mishra
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One Incident, Many Clocks: SEBI’s FIRE Format and the DPDP Breach Rules

By Abhishek Tripathi, Managing Partner, and Adesh Mishra, Associate, Sarthak Advocates & Solicitors

A recent exchange on LinkedIn raised a practical question: if a ransomware note arrives tonight, can your team file a report compliant with the requirements of the Securities and Exchange Board of India (“SEBI”) by tomorrow without waiting for legal review? The main difficulty the organisations face is in deciding what to report before the facts are clear. SEBI’s new format brings this issue into focus.

The Format for Incident Reporting Exchange (“FIRE”) is not a SEBI creation. The Financial Stability Board finalised FIRE on 15 April 20251 as a common template for operational and cyber incidents. It uses standard fields, definitions and classifications so that a firm dealing with multiple regulators across different sectors does not have to report the same incident in five different ways.

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