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. Any alteration is detectable by recomputing the chain.
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.