Phishing has traditionally been treated as an employee awareness problem.
An organization conducts security awareness training, employees complete an online course, perhaps take a quiz, and the compliance team keeps the completion report.
But India’s financial-sector regulators are increasingly looking at cybersecurity awareness as an ongoing organizational responsibility — not simply a training activity.
The important question is therefore changing:
Did your employees complete cybersecurity training?
to:
Are your employees actually aware of phishing and social-engineering risks, and can you demonstrate that awareness?
This is where phishing simulation becomes relevant.
RBI: Awareness Must Be Evaluated Periodically
The Reserve Bank of India’s Cyber Security Framework for Banks contains a specific section on “User / Employee / Management Awareness.”
- Section 23.1 requires banks to define and communicate security policies and educate users and employees about cybersecurity risks and protection measures.
- Section 23.2 asks organizations to encourage employees to report suspicious behaviour and incidents. Section 23.3 calls for targeted awareness and training for key personnel.
- Most importantly, Section 23.4 states that the awareness level should be evaluated periodically. Section 23.5 also calls for mandatory cybersecurity awareness programs for new recruits and annual web-based quiz and training for management.
RBI also specifically refers to phishing in its customer education requirements, including encouraging customers to report phishing emails and phishing sites.
This creates an important distinction.
A training completion report can demonstrate that an awareness program was delivered. A quiz can provide some indication of knowledge. But neither necessarily demonstrates how an employee behaves when presented with a realistic phishing attempt.
A controlled phishing simulation can provide that additional layer of evidence: whether employees click, report, ignore or otherwise respond to a simulated attack.
For banks, therefore, phishing simulation can be a practical way to support the periodic evaluation of cybersecurity awareness called for by the RBI framework.
SEBI: Phishing and Social Engineering Are Explicitly Identified
The Securities and Exchange Board of India’s Cybersecurity and Cyber Resilience Framework (CSCRF) is even more direct about phishing awareness.
Under PR.AT – Awareness and Training, the framework requires regulated entities to establish mandatory programs for building awareness of cybersecurity, cyber resilience and system hygiene among employees. It specifically requires employees to be aware of potential risks including social engineering attacks and phishing.
The framework also emphasizes awareness among employees from non-technical disciplines. This is significant because phishing is not limited to the IT department. Finance, HR, operations, sales and senior management can all become targets.
SEBI’s earlier CSCRF material also states that many infections are introduced through phishing emails and recommends thoughtfully designed security awareness campaigns that emphasize avoiding malicious links and attachments as an essential pillar of defence.
The practical question is then how an organization determines whether those awareness efforts are actually working.
An annual presentation about phishing tells employees what they should do.
A phishing simulation allows an organization to observe what they actually do.
That difference matters when the objective is to build measurable cyber resilience rather than simply demonstrate that training was conducted.
IRDAI: Awareness Needs a Structured and Periodic Approach
The Insurance Regulatory and Development Authority of India’s Information and Cyber Security Guidelines, 2023 apply to insurers, insurance intermediaries and the Insurance Information Bureau of India. IRDAI states that the revised guidelines were issued to strengthen the industry’s defences and governance mechanisms against emerging cyber threats.
The guidelines include requirements around information-security training and awareness. The framework calls for an Information Security Training and Awareness Program with defined content, timelines and periodicity, along with mechanisms to track employee participation and maintain the history and versions of training content.
The regulatory direction is therefore broader than simply conducting an occasional awareness session.
Organizations need a structured program, defined periodicity and evidence that the program is being implemented.
This is where phishing simulation can complement conventional awareness training.
A simulation can be incorporated into the awareness cycle to expose employees to controlled phishing scenarios, measure their responses and identify where additional education is required. The results can then become part of the organization’s broader awareness and improvement program.
The important point is that IRDAI’s guidelines should not be interpreted as saying that every regulated entity must purchase or deploy a specific phishing-simulation product. Rather, phishing simulation can provide a practical mechanism for strengthening and evidencing the awareness activities required by the framework.
Training Shows Participation. Simulation Shows Behaviour.
This is the gap that many organizations still have.
Traditional cybersecurity awareness programs typically rely on:
- Annual awareness presentations
- E-learning courses
- Policy acknowledgements
- Online quizzes
- Training completion reports
- Attendance records
These are useful controls. But they primarily answer one question:
Was the employee exposed to the training?
Phishing simulation asks a different question:
What did the employee do when faced with a realistic phishing scenario?
The difference is substantial.
| Traditional awareness approach | Phishing simulation |
|---|---|
| Measures training completion | Measures behaviour |
| Tests knowledge through quizzes | Tests response to realistic scenarios |
| Usually periodic or annual | Can be repeated throughout the year |
| Shows participation | Shows actual response |
| Often produces static evidence | Produces behavioural trends |
| Limited visibility into high-risk users | Identifies users or groups requiring attention |
| Difficult to demonstrate improvement | Improvement can be measured across campaigns |
Neither approach needs to replace the other.
Training teaches the expected behaviour. Simulation tests whether that behaviour has been adopted.
Why Repeated Simulation Matters
One phishing simulation is also not enough.
An employee who fails one simulated campaign may learn from it. The organization therefore needs to know whether behaviour improves afterwards.
This creates a simple cycle:
Train → Simulate → Measure → Educate → Simulate Again → Measure Improvement
Over time, the organization can begin to answer more useful questions:
- Are employees reporting phishing emails?
- Which departments show higher susceptibility?
- Are repeat failures declining?
- Are employees improving after targeted education?
- Are new phishing techniques creating new weaknesses?
- Is the overall human attack surface reducing?
This turns phishing awareness from a once-a-year activity into a measurable security control.
Where Trust Habit Fits
Trust Habit is designed around this exact principle.
The platform enables organizations to conduct realistic phishing simulations, run multiple targeted campaigns, monitor campaign performance, identify vulnerable users and measure security-awareness progress over time.
Instead of treating phishing simulation as an isolated exercise, organizations can use it as part of a continuous awareness program.
For regulated organizations, this can help create a much stronger evidence trail around activities such as:
- Awareness campaigns conducted
- Employees and groups covered
- Phishing scenarios used
- Employee responses
- Users requiring additional education
- Repeat campaign results
- Improvement over time
- Management-level reporting
This does not mean that using Trust Habit by itself makes an organization compliant with RBI, SEBI, IRDAI or any other regulatory framework.
Compliance depends on the organization’s complete cybersecurity program and the requirements applicable to that organization.
What Trust Habit provides is a practical technology layer for conducting, measuring and evidencing phishing-awareness activities within that broader program.
The Regulatory Direction Is Clear
Across India’s regulated financial sector, cybersecurity awareness is moving beyond the idea of simply distributing policies or completing training.
The language used by regulators varies.
RBI talks about educating employees, encouraging reporting and periodically evaluating awareness.
SEBI explicitly identifies phishing and social engineering as risks employees must understand and requires mandatory cybersecurity awareness programs.
IRDAI requires structured information-security training and awareness programs with defined periodicity and tracking.
The common direction is clear: awareness needs to be an ongoing, structured and demonstrable activity.
Phishing simulation provides a practical way to take that one step further.
Because ultimately, cybersecurity awareness is not proven by how many employees completed a training module.
It is demonstrated by what employees do when the phishing email actually arrives.