CySEC Circular C571, building on the EBA Guidelines on ICT and Security Risk Management, and its follow-up Circular C609 turned cybersecurity from good practice into a supervised obligation for Cyprus Investment Firms. Firms with initial capital of €150,000 or €750,000 were required to comply by 31 December 2023, and Class 2 CIFs must additionally appoint a control function responsible for ICT and security risk. The first internal audit report on ICT and security risk was due to the Board by 30 June 2024 — and CySEC can request it at any time.
We turn that obligation into evidence: a gap analysis against C571/C609, a manual, exploit-led penetration test of your trading platform and client-facing systems, and a report structured for your Board, not just your server room.
We start by mapping your ICT and security risk framework against what C571/C609 and the underlying EBA guidelines actually require — governance, the control function, risk assessment, incident management and testing. Then we run a manual penetration test across the systems that carry real regulatory and financial risk: your trading platform, client portal, back-office and CRM, and the APIs and third-party integrations that connect them. The output is built to drop directly into the internal audit report your Board is expected to review.
Why it matters
CIFs and forex brokers hold exactly what attackers want: client funds, KYC documents and trading data, on internet-facing platforms that never stop running. CySEC does not accept a policy document as evidence of a secure ICT environment — it expects a demonstrated control framework and, increasingly, DORA has layered its own digital operational resilience requirements on top since January 2025. A CIF that cannot produce recent, credible technical testing evidence is exposed twice: to an attacker, and to a supervisory finding.
What we test
- Trading platform & client portal penetration testing
- Back-office, CRM & KYC data exposure testing
- API, FIX protocol & third-party integration testing
- ICT risk register & control-function gap review
- Third-party / liquidity provider ICT risk exposure review
- Incident-response & regulatory reporting readiness check
Common vulnerabilities we uncover
- Unpatched trading-platform components exposed to the internet
- Weak segregation between client-facing and back-office systems
- Third-party liquidity, KYC or CRM integrations with excessive trust
- Missing, outdated or undocumented ICT risk register
- No evidence of periodic technical testing for the Board
- An incident-response plan that has never actually been tested
How we run your engagement
- Kick-off & scoping. A short call to agree goals, in-scope assets and rules of engagement, so your cysec ict risk & cybersecurity compliance penetration testing is safe, authorised and aimed at your real business risk.
- Mapping & discovery. Before touching anything we map the full attack surface in scope, so nothing exploitable slips through.
- Hands-on testing. Cyprus-based specialists exploit and chain weaknesses manually — the flaws scanners walk straight past — to show genuine impact.
- Reporting. Each issue is verified, CVSS-rated and documented with a step-by-step reproduction and a practical fix your team can apply.
- Free retest. Once you have remediated, we re-test at no extra cost to confirm the attack path is truly closed.
Tools & techniques
Our approach pairs regulatory gap mapping with hands-on exploitation. We review your ICT risk register, governance structure and control-function documentation against C571/C609 and the EBA guidelines, then manually test your trading platform, client portal, back-office/CRM and any FIX, webhook or third-party liquidity integrations the way a motivated attacker would — chaining weaknesses to prove real business impact rather than listing theoretical findings.
Every finding is reproducible and mapped back to the specific control it undermines, so your compliance team can trace each fix directly to the obligation it satisfies.
When you need this engagement
- You are a CIF with initial capital of €150,000 or €750,000 regulated by CySEC
- You need to prepare or refresh the annual ICT risk internal audit report for your Board
- You are a Class 2 CIF needing to evidence your ICT and security risk control function
- You are preparing for a CySEC on-site inspection or a formal request for information
- You are newly licensed and building your ICT risk framework from a blank page
What you receive
- CySEC C571/C609 gap analysis mapped to specific controls
- Manual penetration test report with reproducible evidence
- ICT risk register review and prioritised recommendations
- Board-ready internal audit report draft
- Prioritised, risk-based remediation roadmap
- Free retest after remediation
Your deliverables
When your cysec ict risk & cybersecurity compliance penetration testing wraps up, you receive a clear, audit-ready report plus a walkthrough call with your team. Inside you will find:
- A concise executive summary that management and the board can act on
- Every technical finding with a reproducible, copy-paste proof of concept
- CVSS v3.1 ratings and plain-language business impact for each issue
- Practical, prioritised remediation your developers can implement straight away
- A free retest and updated finding status once fixes are in place
- A signed attestation letter for clients, auditors, GDPR, NIS2 and ISO 27001
Standards & frameworks
EBA Guidelines on ICT and Security Risk Management
CySEC Circular C571
CySEC Circular C609
DORA (EU 2022/2554)
What you gain
By the end of your cysec ict risk & cybersecurity compliance penetration testing, you will know exactly which weaknesses a real attacker could exploit, what it would cost your business, and the precise order in which to fix them — backed by evidence, not a scanner’s guesswork. Cyprus firms use our findings to close critical gaps, satisfy client and regulator security questionnaires, and demonstrate due diligence for GDPR and NIS2. With a free retest included, you also get documented proof the issues are resolved.
Working with us
Every cysec ict risk & cybersecurity compliance penetration testing begins with a short, no-obligation scoping call to understand your goals, environment and constraints, followed by a fixed-price proposal. Most work is delivered remotely, and because we are based in Cyprus we work in your timezone with on-site visits across Limassol, Nicosia and island-wide where it helps. We keep you updated throughout and flag any critical finding immediately rather than waiting for the report. Everything is covered by a signed NDA and safe, non-disruptive testing that protects your production systems. You receive your report, a walkthrough and a complimentary retest once fixes land. Engagements are typically booked one to three weeks ahead, and urgent testing can often be arranged — just email hi@cypruspentest.com.
Why Cyprus businesses choose CyprusPentest
Your cysec ict risk & cybersecurity compliance penetration testing is run by senior offensive-security specialists who test the way genuine attackers do — manually, creatively and focused on proving real impact. What sets us apart:
- Based in Cyprus — local, in your timezone, with on-site coverage across Limassol and Nicosia.
- Manual, exploit-led testing that chains vulnerabilities the way an attacker would, well beyond automated scanners.
- Reproducible proof for every finding, with copy-paste steps your team can independently verify.
- Compliance-ready reporting that supports GDPR, NIS2, ISO 27001 and CySEC expectations.
- A free retest so you have documented evidence your fixes actually hold.
- Fixed-price and responsive, with a named point of contact from scoping through to retest.
Explore related services
CySEC ICT Risk & Cybersecurity Compliance Penetration Testing pairs well with our other Cyprus penetration testing services for fuller coverage. You may also want:
How much does CySEC ICT Risk & Cybersecurity Compliance Penetration Testing cost?
Every cysec ict risk & cybersecurity compliance penetration testing in Cyprus is scoped and priced individually, so you pay only for the coverage you need — with no hidden extras. After a short, no-obligation scoping call we send a fixed-price quote, usually within one business day, with clear deliverables, a firm timeline and a complimentary retest included. The price depends on the size and complexity of your environment, so you always know the cost up front before any work begins.
Get a fixed-price quote
Frequently asked questions
Does CySEC explicitly require penetration testing?
Circulars C571 and C609 require CIFs to maintain a robust ICT and security risk management framework aligned to the EBA guidelines. In practice, CySEC and your own internal auditor expect that framework to be evidenced by regular technical security testing, including penetration testing, not policy documents alone.
Which CIFs does this apply to?
Cyprus Investment Firms with initial capital requirements of €150,000 or €750,000 were required to comply by 31 December 2023, with Class 2 CIFs additionally needing a dedicated control function for ICT and security risk.
How does DORA affect CySEC-regulated firms?
Since January 2025, DORA adds digital operational resilience requirements on top of CySEC's existing framework, including threat-led penetration testing for entities a regulator designates as significant. We can scope a combined CySEC and DORA engagement, or run them separately.
Can you help prepare the internal audit report for the Board?
Yes. Our findings and gap analysis are structured so your compliance team can incorporate them directly into the ICT and security risk internal audit report CySEC expects your Board to review annually.