Audit Trail
Every action the system takes — ingest, extraction, approval, evidence binding — is appended here as an event whose hash folds in the previous event’s hash. Nothing can be edited or deleted without breaking every link that follows. Tampering is not prevented; it is unmissable.
Master Circular for Stock Brokers (SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/91) ingested; 9 chapters, 412 paragraphs parsed and normalised. Triggered RUN-041.
Half-yearly net worth certificate to exchange — grounded to MC-SB-2025 para 4.1, chars 61–178.
Daily segregation of client funds — grounded to MC-SB-2025 para 22.1.
DDPI only — no PoA over client demat — grounded to MC-SB-2025 para 28.1.
Nomination (or opt-out) for every account — grounded to MC-SB-2025 para 31.5.
Half-yearly internal audit — grounded to MC-SB-2025 para 61.1.
Periodic VAPT with closure re-validation — grounded to MC-SB-2025 para 101.1.
180-day log retention + MFA on critical systems — grounded to MC-SB-2025 para 103.2. 16 further register entries created in this run.
Initial ingest complete: 23 obligations extracted from MC-SB-2025; verifier checks 5/5 passed; register routed to compliance officer.
Nomination re-papering opened against OBL-SB-009 — 214 legacy accounts without nomination or opt-out declaration.
Mapping, control and evidence spec reviewed against para 4.1 — approved.
Approved with at-risk status noted — nomination coverage below 100%, TSK-008 tracking closure.
Approved — VAPT programme accepted as the control; the Poneglyph scan engine designated evidence source.
Final of 23 base register entries approved — MC-SB-2025 baseline locked.
CSCRF clarification re-map: VAPT report re-verified — 2 medium-severity findings remain open past closure timeline.
Status met → at-risk; closure re-validation deadline pinned to 2026-08-20 per CSCRF timelines.
VAPT re-test of 2 open medium findings opened against OBL-SB-021, due 2026-08-20.
CSCRF clarification partial re-map complete — cyber chapter only; 1 obligation updated, 1 task created; checks 5/5 passed.
SB Regulations 2026 alignment: compliance officer qualification wording updated; mapping and evidence binding unchanged.
SB Regulations 2026 alignment: designated-director residency test restated (≥182 days); control unchanged.
SB Regulations 2026 update applied — 2 obligations updated, 0 created; checks 5/5 passed.
H2 FY26 net worth certificate with exchange acknowledgement uploaded and bound to OBL-SB-001.
Daily segregation report pulled via backoffice-api and bound to OBL-SB-004 — no exceptions in window.
KRA validation status export bound to OBL-SB-008 — 12,408 active clients, 0 unverified records.
H2 internal audit report, board minute and AP inspection records uploaded; bound to OBL-SB-013 and OBL-SB-014.
Scheduled evidence re-check (RUN-042): Poneglyph scan re-run — 2 medium findings still open; at-risk status confirmed.
Poneglyph config scan bound to OBL-SB-023 — log retention 180d verified, MFA coverage 100% of critical-system users.
Nomination coverage report bound to OBL-SB-009 — coverage 94.1%, 214 accounts outstanding.
IR SOP v3 and Q1 tabletop drill record uploaded; bound to OBL-SB-022.
Daily margin statement dispatch log bound to OBL-SB-011 and OBL-SB-012 — SLA within tolerance.
Amendment caught: HO/38/11/(9)2026-MIRSD-POD/I/15382/2026 replaces para 46 with the pledge-based CUSPA regime. Applicability: applies. Triggered RUN-047.
Open dedicated CUSPA pledgee account — grounded to CIRC-CUSPA-2026 para 46.1; phase-1 deadline 2026-11-02.
Auto-pledge unpaid securities to CUSPA — grounded to para 46.2.
Board-approved unpaid-securities policy (≤5-day window) — grounded to para 46.4.
Day-6 auto-release of un-invoked pledges — grounded to para 46.5. 10 delta register entries created in this run in total.
CUSPA account opening task raised against OBL-SB-101; first of 7 remediation tasks opened by RUN-047 (TSK-001…TSK-007).
CUSPA re-map complete: 10 obligations created, 7 tasks opened; verifier checks 5/5 passed; 3 entries (OBL-SB-104/106/108) routed to human gate — awaiting approval.
CUSPA delta review: 7 of 10 entries approved (101, 102, 103, 105, 107, 109, 110); 104/106/108 held pending policy and treasury review.
Draft unpaid-securities policy (5-day cap) uploaded and bound to OBL-SB-104 — entry remains pending-review until board approval.
Daily poll of sebi.gov.in complete — no new instruments for stock brokers; register unchanged.
Corpus-completion parse of MC-SB-2025: 5 chapters normalised into the existing root — technology (Part IV, 3 paras), change-control (Part V, 2), fatca (Part VI, 2), outsourcing (Part IX, 3), reporting (Part X, 3). These Parts were bound at onboarding ONB-001 but held no extracted content. Triggered RUN-049.
Digitally signed electronic contract notes with proof of delivery — grounded to MC-SB-2025 para 50.2, chars 61–232. Carried at-risk: the signing certificate lapses 2026-08-14 and renewal is unevidenced.
Exchange approval and unique identifier for every algorithm — grounded to para 62.1. Opened as a gap: no approval letters or live strategy inventory on file.
Prior approval before any change in control — grounded to para 66.1. First register entry under Part V, which held none before this run.
FATCA/CRS registration and reportable-account due diligence — grounded to para 69.1 with para 70.2 folded in as the reportable-account limb. First and only entry under Part VI.
Consolidated quarterly report in Annexure-28 format — grounded to para 93.1, due 2026-10-15. Para 93.6 carried as a completeness-and-certification condition rather than a separate entry. 10 register entries created in this run in total (OBL-SB-024…033).
Corpus-completion pass complete: 10 obligations created across Parts IV, V, VI, IX and X; verifier checks 5/5 passed; register now 43 entries covering 9 of the 10 Parts. Part VIII considered and deliberately not extracted — default provisions bind only on a default event and remain under a standing trigger watch. 3 entries (OBL-SB-027/032/033) routed to human gate — awaiting approval.
Approved with at-risk status accepted — mapping to para 50.2 is sound; the certificate expiry of 2026-08-14 is a control failure to remediate, not a mapping defect.
Approved as a gap — algorithm approvals exist with the exchanges but are not held as a reconciled inventory; the gap is the evidence, not the duty.
Approved — pre-trade risk gate on DMA and smart order routing confirmed against para 57.3; gateway configuration probe accepted as the standing evidence source.
Approved — quarterly constitution return already filed on cycle; fifteen-day computation from quarter end verified against para 67.2.
Approved — folding para 70.2 into the registration duty accepted: registration and reportable-account due diligence share one evidence surface and cannot be evidenced apart.
Approved as a gap — outsourcing arrangements are governed under contract but no board-approved policy or vendor register exists; core-activity carve-out from para 82.3 correctly folded into the entry.
Approved — seventh and last of the RUN-049 auto-approved mappings; OBL-SB-027, OBL-SB-032 and OBL-SB-033 remain pending my review.
Raised against OBL-SB-025 — the algorithm approval register cannot be evidenced while DOC-REQ-017 is an open ask. Due 2026-09-15, owner Dev Khanna.
Raised against OBL-SB-030 — board-approved outsourcing policy and vendor register outstanding against DOC-REQ-023. Due 2026-10-15, owner Rohan Iyer.
Verification replays the recorded chain in this browser: for each event, prevHash is compared against the hash of the event before it. No write path exists here — the sandbox register is read-only.