"India's cybersecurity architecture is largely reactive, responding to breaches after disclosure." Critically examine this statement in light of the rise of agentic AI.
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India's cyber defence rests on CERT-In, the national incident-response agency under Section 70B of the IT Act, 2000 [2]. Incidents rose from about 20.4 lakh in 2024 [2] to over 29.4 lakh in 2025 [3], and agentic AI is shortening the time attacks take. Against this background, the charge that the system is reactive is largely valid, though not wholly.
Why the statement holds
- Reporting starts only after detection: CERT-In's 2022 Directions require incidents to be reported within 6 hours of being noticed [6]. The duty begins only when an entity detects the incident, and many entities lack the capacity to detect it.
- Penalties not yet enforceable: The DPDP Rules, 2025 are being rolled out in phases over 18 months [1]. Until then, penalties of up to ₹250 crore for weak security safeguards cannot be imposed [1].
- Little public learning: CERT-In was placed in the RTI Act's Second Schedule in 2023 [5]. It also does not publish post-mortems of incidents, which weakens public accountability.
- Legal lag: IT Act liability assumes a human actor. AI agents that act beyond their authorised limits fall into a legal grey zone.
Where it is overstated
- Preventive outputs: In 2025, CERT-In issued 1,530 alerts, 390 vulnerability notes and 65 advisories [3].
- Early warnings: CERT-In's high-severity advisory warned that autonomous AI could find vulnerabilities and run multi-stage attacks, before any large-scale harm occurred [4].
- Duties before a breach: The DPDP framework requires reasonable security safeguards. It also requires plain-language breach notice to the Data Protection Board and to each affected person [1].
Agentic AI makes a reactive approach costlier
- AI agents act at machine speed, so by the time a breach is detected and reported, the data may already be gone.
- Open-source agent tools let low-skill actors automate reconnaissance. They still mostly exploit basic lapses such as exposed passwords.
Way forward
- Continuous threat-hunting, and testing of AI agents only in isolated environments, never on live infrastructure.
- Make developers liable for their agents' actions through the proposed Digital India Act.
- Publish anonymised post-mortems of major incidents.
- Cyber-hygiene support for MSMEs before DPDP duties take full effect.
India has built the necessary laws and institutions, but its system still acts mainly after a breach is disclosed. It needs a regime that puts detection first and accounts for AI risks: a transparent CERT-In, enforceable DPDP safeguards and clear liability for AI agents. Such a regime would protect the Article 21 right to privacy affirmed in Puttaswamy (2017) and maintain trust in India's digital economy.
Sources
- 1PIB Backgrounder: Digital Personal Data Protection Rules, 2025 (Nov 2025): 18-month phased rollout, security safeguards, breach notice to the Board and affected persons, ₹250 crore penalty ceiling
- 2PIB: Government of India Taking Measures to Protect Critical Infrastructure and Private Data Against Cyber Attacks: CERT-In under Section 70B; 2024 incident count
- 3PIB document (Jan 2026) on CERT-In's 2025 activity: 29.44 lakh incidents; 1,530 alerts, 390 vulnerability notes, 65 advisories in 2025
- 4OECD.AI Incidents Monitor: India's CERT-In Issues High-Severity Warning on AI-Driven Cyber Threats (2026): CERT-In's warning on autonomous AI finding vulnerabilities and running multi-stage attacks
- 5DoPT Gazette Notification under Section 24(2), RTI Act, 2005, adding CERT-In to the Second Schedule (Nov 2023): CERT-In's RTI exemption
- 6CERT-In Directions under Section 70B(6) of the IT Act, 2000 (28 April 2022): 6-hour incident-reporting requirement