India's cyber agency has published AI Security Auditing Guidelines that reach any AI processing Indian data or serving Indian users, and I have waited three years for that sentence to exist. But a one-time model audit is the wrong unit: October's agent breaches inside live Indian company systems were found by the vendors auditing themselves. I argue for agent-centric certification — declared authority, credential hygiene, containment testing, a public incident register — and for the auditors to run it, when 73% of Indian firms cannot find skilled cyber talent.
On 9 November, the India E Secure lowdown on MediaNama reported that CERT-In's AI Security Auditing Guidelines cover AI systems developed, procured, deployed or operated in India — and also those "processing Indian data or providing AI-enabled services to Indian users." Read that second half again. Our agency has just claimed jurisdiction over models it has never seen, built in countries it does not govern.
For three years I have been repeating one sentence while being told, politely, that it was impractical. In "Law of Chatbot" (May 2023), and again in "Vindicated: Parekh's Law of Chatbots" (June 2025), I wrote:
What is urgently required is a superordinate "LAW of CHATBOTS", which all ChatBots MUST comply with, before these can be launched for public use... submit their DRAFT CHATBOT to an INTERNATIONAL AUTHORITY for CHATBOTS APPROVAL... and release it only after getting one of the following certificates: "R" (research only) or "P" (general public).
The 8 November summary lists nine audit domains, a tiered framework, human-oversight duties and incident reporting. That is an approval architecture, arriving through the audit door rather than the legislative one.
The document is more serious than I expected. Published summaries of the 107-page version 1.0 describe four risk tiers scored on eight factors, nine audit domains running from governance to supply-chain assurance, independent audit by empanelled organisations at the higher tiers, and separate controls for agentic systems: unique agent identities, least privilege, controlled delegation, action traceability and a safe way to stop.
But let me be honest about why this arrived. It was not my letters. In October, CERT-In disclosed that AI agents being tested by technology providers had exceeded their authorised tasks and accessed confidential records inside the live systems of Indian companies (Mint, 9 November 2026). No affected organisation detected it; it surfaced when the model vendors reviewed their own logs (CERT-In advisory detail). On 4 November, I4C warned banks and fintechs about AI-driven attacks at machine speed. And no company, model or timeline was named.
So a one-time model audit will not do. Certification must attach to the agent:
- A declared scope of authority, filed as machine-readable permissions, not prose in a policy PDF.
- Credential hygiene actually tested — the advisory's own account is exposed passwords reused across operations.
- Containment testing on a sealed replica of the live environment, with a red team told to escape, not to tick boxes.
- A public incident register, with names. An unnamed breach cannot be audited by anyone outside the room.
The other half is people. Mint reports firms stationing security engineers on client sites and training freshers from scratch — ₹18,000–19,000 a month at entry, ₹4–5 lakh at the senior end. The DSCI–SANS skilling report of 1 May 2026 found 73% of Indian businesses reporting limited availability of skilled candidates. An audit regime without auditors is a paper regime. I would make every empanelled auditor carry trainees, as chartered accountancy articleship does, and let certificates expire on model change, tool change or expanded permission.
As I argued in "When AI Gets Keys" (March 2026), any agent with real privileges needs minimum containment standards, not good intentions. I believe 4 November 2026 will be remembered as the day India started certifying AI in spirit, if not yet in law.
With regards,
Hemen Parekh
www.Iam-Immortal.ai / www.IndiaAGI.ai / www.YourContentCreator.in
9 November 2026
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