CBO Cyber Security & Resilience Framework: assess your mobile banking app before and after every release.

The Central Bank of Oman's Cyber Security & Resilience Framework, issued by Circular BM 1194, sets minimum security requirements for banks, payment service providers, finance and leasing companies and money exchange establishments. It asks for vulnerability assessment and penetration testing of critical systems, with penetration testing of internet-facing systems at least annually or after significant changes, and its electronic banking section covers multi-factor authentication, session timeouts and mobile banking through official app stores. Ostorlab tests your app and the APIs behind it, behind login, on every release.

  • Assesses the mobile app and the APIs it calls, on the build your customers download
  • Tests login, one-time codes, step-up checks and session handling with your test accounts
  • Lists the SDKs and native libraries in each release and maps them to known vulnerabilities
  • Proves each finding with a replayable exploit or request and response evidence
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Who it applies to
Banks, payment service providers, finance and leasing companies and money exchange establishments licensed by the CBO
Key date
Circular BM 1194 issued on 31 July 2023; full compliance with the framework required by 31 July 2024
Focus
Vulnerability assessment and penetration testing, MFA and sessions for electronic banking, and personal data protection
Main reference
CBO Cyber Security & Resilience Framework (CS&RF), Circular BM 1194
Key dates

The CBO texts behind your mobile channel

The cyber security framework sits alongside the older electronic banking and fraud risk circulars, which it keeps in force unless they are inconsistent with it. The dates below are for the texts cited on this page.

  1. 18 January 2011

    BM 1078 Combating Frauds

    The CBO issues its first circular on combating frauds, later consolidated with the electronic banking security circular into the master circular on fraud risk management.

  2. 16 June 2015

    BM 1136 Security of Electronic Banking Systems

    The CBO sets out security requirements for electronic banking systems, consolidated into BM 1153 and still cited by it.

  3. 25 December 2017

    Master Circular BM 1153

    Consolidates fraud risk management and electronic banking security: vulnerability assessment at least quarterly by internal teams, VAPT at least once a year by external experts, and two-factor authentication for mobile banking debits.

  4. 31 July 2023

    Cyber Security & Resilience Framework

    Circular BM 1194 issues the framework (Version 1.0). It is effective from the date of issue, with full compliance permitted until 31 July 2024. It is built on references including NIST, ISO 27001, ISF, Basel and PCI DSS.

  5. 1 June 2025

    Digital banks framework

    Decision 25/2025, the Regulatory Framework for Digital Banks, requires applicants and licensed digital banks to comply with the Cyber Security & Resilience Framework, the e-KYC instructions and the anti-fraud framework, and allows the CBO to require a third-party assessor to run VAPT.

  6. 7 September 2026

    Personal data amendments

    Royal Decree 68/2026, published on 6 September 2026, amends the Personal Data Protection Law and takes effect the next day, adding rules on automated processing, erasure and marketing consent.

What the CBO asks

The CBO's cyber security rules, applied to your mobile app

For each rule: what the text says, what it means for a mobile banking app, how Ostorlab helps, and what stays with your team. Clause summaries follow the Cyber Security & Resilience Framework enclosed with Circular BM 1194.

  1. Cyber Security & Resilience Framework (CS&RF), 3.3.11, controlling measures 1 to 5

    Run vulnerability assessments and penetration tests on critical systems

    What the text says

    Each licensed institution should periodically conduct vulnerability assessment to identify security vulnerabilities in its information assets, with frequency based on the criticality of the assets. Penetration testing should also be carried out, with frequency based on the criticality of the systems and the institution's exposure to cyber risk. For internet-facing systems, penetration testing should be conducted at least annually or whenever there are significant changes to the systems or an update. Institutions should establish processes for remediating the vulnerabilities found and validate the remediation to make sure the gaps are fully addressed, and should report identified vulnerabilities to the IT and Risk Management committee. Regular cyber simulation exercises should also be conducted.

    Source:Cyber Security & Resilience Framework (CS&RF), 3.3.11, controlling measures 1 to 5

    What it means for your mobile app

    The mobile banking app and the APIs behind it are internet-facing systems. The framework expects a set cadence, a validated fix process and committee reporting, not a one-off test.

    How Ostorlab helps

    Ostorlab runs AI-agent penetration tests of the app and its APIs behind login on the build you ship, plus Mobile SAST and DAST in CI/CD. Each AI-agent finding comes with a working exploit you can replay, and retests confirm the fix.

    What stays with you

    Setting the frequency, testing servers, VPN equipment and other platforms, running simulation exercises, and reporting to the IT and Risk Management committee.

  2. Regulatory Framework for Digital Banks, Decision 25/2025, 6.1(o), 6.1(s), 11.1 and 11.3

    Meet the digital banking framework's security expectations

    What the text says

    Applicants and licensed digital banks must demonstrate compliance with the Banking Law and the National Payment Systems Law, the Cyber Security & Resilience Framework, the Instructions on Digital Onboarding and Electronic KYC, the anti-money laundering framework, the anti-fraud framework, and the rules for outsourcing and cloud services. Their business plans must show ex-ante technological preparedness such as zero-trust architecture, industry-grade certifications like PCI-DSS, and measures to identify, protect, detect, respond and recover from cyber threats. The Central Bank may require the applicant to appoint a qualified third-party assessor to perform vulnerability assessment and penetration testing at the applicant's expense, at different stages of its operations.

    Source:Regulatory Framework for Digital Banks, Decision 25/2025, 6.1(o), 6.1(s), 11.1 and 11.3

    What it means for your mobile app

    If you are building or running a digital bank, the app and API layer is where the framework's cyber security, e-KYC and anti-fraud requirements meet.

    How Ostorlab helps

    Ostorlab provides the technical testing on the app and API side: AI-agent pentests, authenticated testing and API testing, with evidence for each result. It is not the licensing assessor and does not certify PCI-DSS.

    What stays with you

    The licence application and business plan, the choice of assessor, and the wider programmes for zero trust, fraud and cloud governance.

  3. CS&RF, 3.3.2, controlling measures 1 to 4

    Secure the application layer and what you build with

    What the text says

    Application configurations should comply with the applicable information security policies and procedures, and audit trails for critical applications must be maintained and reviewed in case of an incident. A risk analysis must be documented for each application requiring network access. Institutions should have policies and procedures on the use of third-party and open-source code, and should perform source code reviews and testing for in-house and custom-developed applications to find vulnerabilities arising from coding issues, poor coding practices or malicious attempts.

    Source:CS&RF, 3.3.2, controlling measures 1 to 4

    What it means for your mobile app

    A mobile banking app is custom code plus third-party SDKs. The framework expects both to be governed and tested, not just the backend.

    How Ostorlab helps

    Mobile SAST works on the APK, AAB or IPA without source code, with taint analysis across the app and its embedded SDKs. SCA and SBOM list the third-party and native components in each release and map them to known vulnerabilities.

    What stays with you

    Secure coding standards, manual code reviews, configuration baselines, and the policy on open-source use.

  4. CS&RF, 3.5.2, controlling measures 1 and 2; BM 1153, Annexure, 6(xxi) and 6(xxii)

    Enforce MFA and session controls for electronic banking

    What the text says

    Institutions should design multi-factor authentication methods that are comparatively strong and reliable, and should consider implementing MFA for registration, sign-on, password resets, adding or changing beneficiaries, high level transactions that exceed predefined limits, and adding government and utility payment services. Online sessions should be terminated automatically after a fixed period of time unless re-authenticated, and confirmatory second channel procedures such as SMS or email should be used for transactions above pre-set values, registration of third-party payee details, changing account details and revising funds transfer limits.

    Source:CS&RF, 3.5.2, controlling measures 1 and 2; BM 1153, Annexure, 6(xxi) and 6(xxii)

    What it means for your mobile app

    MFA has to be enforced by the server on every one of those operations, including when the app skips a step, and session expiry and second-channel confirmation are behaviours you can test.

    How Ostorlab helps

    Authenticated testing covers login and logout, one-time codes, step-up flows, token refresh, timeouts and session invalidation, together with the API calls behind registrations and beneficiary changes.

    What stays with you

    Choosing and deploying the MFA methods and the second channel, and customer communication.

  5. CS&RF, 3.5.2, controlling measures 8 and 12; BM 1153, Annexure, 6(xxv) and 6(xxxi)(f)

    Keep mobile banking on official channels, with two-factor debits

    What the text says

    Institutions should make online and mobile banking available only through official applications stores or any other secure delivery channels, and should establish brand protection for their online services, including social media, and implement a detection measure to take down any malicious websites and apps. Mobile banking services should ensure appropriate risk mitigation measures such as transaction limits, transaction velocity limits and fraud and AML checks. All mobile banking transactions involving a debit to the account should be permitted only through two-factor authentication, and proper security should be ensured at all stages of processing mobile banking transactions. Where third parties are associated with electronic banking activities, institutions should bind them with liability clauses on security threats emanating from their systems.

    Source:CS&RF, 3.5.2, controlling measures 8 and 12; BM 1153, Annexure, 6(xxv) and 6(xxxi)(f)

    What it means for your mobile app

    The store build is your customer-facing channel. Clones and tampered builds, debit flows that skip the second factor, and limits that live only in the interface are all things the framework expects you to control.

    How Ostorlab helps

    Ostorlab scans the store build release after release and tests root and jailbreak detection, anti-tampering and TLS pinning at runtime, so you can see which protections held and which were bypassed. It also tests whether the two-factor checks and transaction limits hold on the server side.

    What stays with you

    Store monitoring and the takedown process for clones, the transaction and velocity limits themselves, and vendor liability clauses.

  6. CS&RF, 3.3.8, patch management measures; BM 1153, Annexure, 6(xx)

    Patch on time and keep track of components

    What the text says

    Institutions should keep operating systems, network and infrastructure devices, security software and remote access computers updated and patched in accordance with a patch management policy, after due risk assessment. They should continuously monitor vendor patch releases and make sure critical patches are tested in a test environment before production; if a patch breaks a critical application, they should devise other mitigating controls that block exploitation. Where applications are bought from vendors, institutions should obtain application integrity statements in writing that the application is free of malware, bugs and covert channels, and there should be a risk management analysis and security vulnerability assessment of the application and network at least once a year.

    Source:CS&RF, 3.3.8, patch management measures; BM 1153, Annexure, 6(xx)

    What it means for your mobile app

    Every library, SDK and native component inside the app is software you ship. Each needs a known version, a severity when something breaks, and a fix deadline you can evidence.

    How Ostorlab helps

    SCA fingerprints statically compiled libraries and maps them to known vulnerabilities, release to release. Findings are rated critical, high, medium or low, tracked as tickets in the platform or in Jira and ServiceNow, and retested once the fix ships.

    What stays with you

    Patching servers and infrastructure, vendor maintenance contracts, compensating controls, and risk acceptance decisions.

  7. CS&RF, 3.3.5 and 3.5.1(7); Personal Data Protection Law (Royal Decree 6/2022), Articles 13, 14, 15 and 19, as amended by Royal Decree 68/2026

    Protect personal data on the device and in transit

    What the text says

    Institutions should implement endpoint, peripheral and network data loss prevention solutions, and should implement end to end encryption at rest and in transit for the protection of sensitive information such as login credentials and card information. Under the Personal Data Protection Law, the controller and the processor must put in place the controls and procedures for processing, including the risks the data subject is exposed to and the technical measures that guarantee the law is applied; when using automated processing they must protect privacy and confidentiality; they must erase personal data when the purpose of processing ends; and they must notify the ministry and the data subject of a personal data breach. Transfers of personal data outside Oman follow the controls in the executive regulation.

    Source:CS&RF, 3.3.5 and 3.5.1(7); Personal Data Protection Law (Royal Decree 6/2022), Articles 13, 14, 15 and 19, as amended by Royal Decree 68/2026

    What it means for your mobile app

    Passwords, tokens and card data should never sit in clear text on the phone or travel unprotected to the backend, and personal data collected by the app is subject to the data protection law.

    How Ostorlab helps

    Ostorlab looks for session tokens and personal data in local storage, caches, logs and screenshots, and checks for misconfigurations that weaken transport and session protections.

    What stays with you

    Data classification, consent notices, data protection officer duties, breach notification to the ministry and to data subjects, and transfer assessments.

  8. CS&RF, 3.3.10, controlling measures 1 to 4

    Lock down access and credentials

    What the text says

    Institutions should define, approve and monitor a policy on access management, applying segregation of duties, need-to-have and least privilege when granting access to staff, contractors and third-party vendors. Records of user access activities should be uniquely logged and identified for audit and investigation purposes, and additional authentication mechanisms such as multi-factor authentication should be used for remote access and for privileged access to systems that support essential functions, based on a risk assessment.

    Source:CS&RF, 3.3.10, controlling measures 1 to 4

    What it means for your mobile app

    API keys, tokens and other credentials left in the app package are access that anyone who downloads the app can extract; authorisation between the app, the backend and external services has to hold at every boundary.

    How Ostorlab helps

    Ostorlab finds API keys, tokens and credentials in the app package and validates whether they work, and tests the APIs for broken authorization (BOLA, BFLA, IDOR) and misuse of tokens and sessions.

    What stays with you

    Privileged account management, access reviews, joiner and leaver processes, and third-party access control.

  9. CS&RF, 3.5.2, controlling measure 14 (a) to (e)

    Test e-KYC and onboarding security

    What the text says

    For e-KYC, which lets institutions digitally onboard new customers and update know your customer records through electronic means, institutions should conduct cyber security assessments prior to launch of the e-KYC solution and assess periodically how effective the technology is in mitigating cyber threat risks and fraud risks. The identification and verification process should adopt an appropriate combination of multi-factor authentication, the application must make use of real time secured end-to-end encryption, and the digital footprint and logs collected during identification and verification should be preserved, including complementary data such as IP addresses. Video recordings should be stored safely with the date and time stamps maintained.

    Source:CS&RF, 3.5.2, controlling measure 14 (a) to (e)

    What it means for your mobile app

    Onboarding runs through the mobile app before an account exists. The encryption, the MFA combination and the evidence trail are all part of the app and API flow you can test.

    How Ostorlab helps

    Ostorlab completes onboarding and e-KYC flows with your test accounts and identity documents and tests the API calls behind them, including MFA enforcement, session handling and transport protections.

    What stays with you

    The identity verification product, liveness and document checks, video storage, and the retention policy for onboarding data.

Summary of public CBO texts and the Personal Data Protection Law, checked on 27 September 2026. The Cyber Security & Resilience Framework is enclosed with Circular BM 1194, and clause summaries follow the framework text. This page is not legal advice.

Mapping

CBO rules, control by control

The controls the CBO texts point to, how Ostorlab tests them in your app and its APIs, and the evidence you can keep.

CBO rules, control by control
ControlHow Ostorlab helpsEvidence you keep
Vulnerability assessment of critical systemsCS&RF 3.3.11(1)AI-agent pentest of the app and its APIs, behind login, on the build you ship, with Mobile SAST and DAST in CI/CD. Details A working exploit you can replay for each AI-agent finding, and a coverage heatmap
Penetration testing of internet-facing systemsCS&RF 3.3.11(2)Intercepts traffic even with TLS pinning and tests authorization, token misuse and abuse such as enumeration and replay. Details Request and response evidence for each API finding
Application security and source code reviewCS&RF 3.3.2Mobile SAST on the binary, including embedded SDKs, with no source code needed. Details Static findings per build, with call paths and code location
Vulnerable components, versions and patch deadlinesCS&RF 3.3.8; BM 1153 6(xx)Fingerprints statically compiled libraries and maps them to known vulnerabilities, release to release. Details Mapped vulnerabilities with upgrade or replace recommendations, and closure tracked across releases
MFA on registration, sign-on, password resets and beneficiariesCS&RF 3.5.2(1)Logs in with one-time codes and tests MFA enforcement and step-up flows, and the API calls behind them. Details Findings on login, registration and step-up flows, with reproduction steps
Session timeouts and second-channel confirmationCS&RF 3.5.2(2); BM 1153 6(xxii)Tests login and logout, token refresh, timeouts and session invalidation. Details Session and token findings, with request and response logs
Mobile banking through official stores, with two-factor debitsCS&RF 3.5.2(8) and 3.5.2(12); BM 1153 6(xxv)Scans each store release and tests root and jailbreak detection, anti-tampering and pinning at runtime. Details Per-release shielding results showing which protections held and which were bypassed
Credentials in the app and API access controlCS&RF 3.3.10Finds API keys, tokens and credentials in the app package and validates whether they work. Details Validated secrets, with the permissions and services they expose
Personal data on the device and in transitCS&RF 3.3.5, 3.5.1(7); PDPL Articles 13 to 19Looks for tokens and personal data in storage, caches, logs and screenshots, and checks transport protections. Details File system evidence showing what was written, where and when
e-KYC and onboarding securityCS&RF 3.5.2(14)Completes onboarding flows with your test accounts and tests the API calls behind them. Findings on the onboarding flow, with reproduction steps and request and response logs

Ostorlab tests controls in the app and its APIs. SOC monitoring, incident response and reporting to the CBO, simulation exercises, TLPT, backups and recovery, governance and physical security stay with your teams.

Action plan

CBO controls to test in your mobile app

A practical list for security and system risk teams, based on the CBO cyber security framework and the fraud risk circular.

  1. Mobile app and APIs in scope

    Put the mobile app and the APIs it calls in the scope of your vulnerability assessment and penetration testing procedures, with a risk-based frequency and a pre-release step.

  2. Internet-facing pen test

    Penetration test internet-facing systems at least annually and after significant changes, and keep the report for the IT and Risk Management committee.

  3. MFA and sessions

    Verify that registration, sign-on, password resets, beneficiary changes and high-value transactions require the second factor on the server, and that sessions end after a fixed period.

  4. Official stores and clones

    Ship mobile banking only through official app stores, and watch for malicious websites and clones with a detection and takedown path.

  5. Components and deadlines

    Keep a versioned list of the SDKs, third-party code and native libraries in each release, and set patch deadlines by severity.

  6. Secrets and personal data

    Check the app package for API keys, tokens and credentials, and check storage, caches, logs and screenshots for personal data and session tokens.

  7. e-KYC flows

    Test onboarding and e-KYC with your test accounts: the MFA combination, end-to-end encryption, and the logs and recordings the framework asks you to preserve.

  8. Report and retest

    Report significant findings to the IT and Risk Management committee, track them to closure and keep retest results as a record. Incident reporting to the CBO stays with your team.

A suggested list, not a CBO template. This is not legal advice.

Sources

The official texts this page is based on, checked on 27 September 2026.

  • Circular BM 1194 – Cyber Security & Resilience FrameworkCBO, 31 July 2023. Issues the Cyber Security & Resilience Framework (Version 1.0), effective on issue, with full compliance permitted until 31 July 2024. Addressed to all licensed banks, payment service providers, finance and leasing companies and money exchange establishments
  • Master Circular BM 1153 – Fraud Risk ManagementCBO, 25 December 2017. Consolidates the fraud risk management instructions with BM 1078 (18 January 2011) and BM 1136 (16 June 2015). Annexure section 6 covers VAPT, electronic banking and mobile banking security
  • Circular BM 1136 – Security of Electronic Banking SystemsCBO, 16 June 2015. Security requirements for electronic banking systems, consolidated into BM 1153 and still cited by it. The scanned original is published by the CBO
  • Regulatory Framework for Digital Banks (Decision 25/2025)CBO, 1 June 2025. Requires digital bank applicants and licensed digital banks to comply with the Cyber Security & Resilience Framework, digital onboarding and e-KYC instructions, the anti-fraud framework and cloud and outsourcing rules, and allows third-party VAPT at the applicant's expense
  • Personal Data Protection LawRoyal Decree 6/2022, issued 9 February 2022, published in Official Gazette 1429 on 13 February 2022, in force from February 2023. Security, breach notification, erasure and transfer duties in Articles 13 to 23
  • Royal Decree 68/2026 amending the Personal Data Protection LawIssued 3 September 2026, published in Official Gazette 1664 on 6 September 2026, in force on 7 September 2026. Amends Articles 2, 3, 7, 10, 14, 15, 22, 25 and 27 and adds Articles 5 bis and 10 bis
  • Executive Regulation of the Personal Data Protection LawMinisterial Decision 34/2024, published 4 February 2024, in force 5 February 2024. Ministerial Decision 6/2025 extended the compliance grace period to 5 February 2026. Covers security measures, data subject rights and cross-border transfers
  • Banking Law (Royal Decree 2/2025)Issued 1 January 2025, published in Official Gazette 1578 on 5 January 2025, replacing the Banking Law 114/2000 that the CBO circulars cite. Provides the legal basis for the CBO's frameworks and instructions
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