[INDIA] RBI, SEBI and IRDAI · Source-code escrow and continuity obligations for critical applications[EU DORA] ICT third-party risk testing required · In force Jan 2025[PRA] SS2/21 UK · Vendor recovery evidence required[MAS] Singapore TRM · Independent vendor recoverability expected[APRA] CPS 230 Australia · Third-party continuity obligations in force[FFIEC] United States · Source-code access and software escrow addressed in third-party contracts[ENTERPRISE] Mission-critical software procurement increasingly requires continuity evidence before contract
[INDIA] RBI, SEBI and IRDAI · Source-code escrow and continuity obligations for critical applications[EU DORA] ICT third-party risk testing required · In force Jan 2025[PRA] SS2/21 UK · Vendor recovery evidence required[MAS] Singapore TRM · Independent vendor recoverability expected[APRA] CPS 230 Australia · Third-party continuity obligations in force[FFIEC] United States · Source-code access and software escrow addressed in third-party contracts[ENTERPRISE] Mission-critical software procurement increasingly requires continuity evidence before contract

AI & MODEL ESCROW · NEW

AI systems are not just code. Escrow them accordingly

A trained model weight is not in the source repository. Neither is the fine-tuning dataset, inference environment, prompt configuration, or evaluation harness. Castler custodies and verifies the full AI artifact stack and produces a signed Proof of Recovery.

Escrow scopeNew
WeightsLayer 1
InferenceLayer 2
PromptsLayer 3
EvaluationVerified
Custody mapped to signed evidence

WHAT IT IS

Your institution now depends on AI systems it cannot operate without the vendor.

Financial institutions, insurers, and large enterprises now use vendor-provided AI for credit scoring, fraud detection, KYC, claims, document intelligence, and risk modelling. These systems operate continuously and increasingly support critical decisions.

The institution often pays for access to a model or inference API while holding no model artefacts, no escrow rights, and no independent recovery path.

AI continuity requires custody before acquisition, model deprecation, API withdrawal, or regulatory audit makes access urgent.

WHAT NEEDS TO BE IN CUSTODY

An AI system has six layers. Standard escrow covers one.

01

Source and training pipeline code

Model architecture, training loops, preprocessing, and evaluation logic. Necessary, but not sufficient.

02

Trained model weights

The numerical parameters that define model behaviour. They cannot be reconstructed from source code alone.

03

Fine-tuning datasets

Domain-specific data used to adapt the model. Without it, the model cannot be retrained or updated after recovery.

04

Inference environment

Containers, accelerators, memory, batching, serving configuration, and runtime dependencies.

05

Prompt configurations

System instructions, few-shot examples, retrieval configuration, and output formatting that define application behaviour.

06

Evaluation harness

Benchmarks, test sets, and validation logic required to confirm that the recovered model remains fit for purpose.

THE CASTLER APPROACH

Full AI artifact custody and agentic verification.

Castler treats the model as a complete operating system of artefacts, not a code repository. Custody and verification follow the full inference path.

What Castler custodies

Model architecture and training code

PyTorch, ONNX, TensorFlow, Safetensors, and GGUF weights

Fine-tuning datasets or cryptographic hashes

Inference environment specifications

Prompt templates and system instructions

Evaluation harness and benchmarks

Model cards and documentation

Verification pipeline

Agents provision an isolated inference environment, load the model weights, and execute the deposited evaluation harness. The run confirms that the model loads, produces outputs consistent with benchmarks, and operates within the declared resource profile.

Signed output

Signed Proof of Recovery with Model Load Report, Inference Verification Report, Benchmark Comparison, Resource Configuration Validation, Confidence Score, engineer seal, and public verification URL.

REGULATORY MANDATE

AI escrow requirements are emerging across every major jurisdiction.

EU AI Act

High-risk AI systems require documentation, transparency, human oversight, and operational controls that depend on retained access to the full model system.

EU DORA

AI vendors supporting critical ICT functions fall within third-party risk and recoverability requirements.

Evidence map

RBI IT Directions 2023 §12(f)

AI systems that qualify as critical applications fall within source-code access and continuity obligations.

Evidence map

SEBI CSCRF

AI used in market surveillance, risk, and client-facing functions is within the continuity scope for critical third-party applications.

Evidence map
See all 17 mandates

FREQUENTLY ASKED

Questions about this escrow type

What model formats does Castler support?

PyTorch, ONNX, TensorFlow SavedModel, Hugging Face Safetensors, and GGUF are supported. Proprietary formats require a defined deposit specification.

Can Castler verify GPU models?

Yes. The deposited inference specification defines the required accelerator, memory, serving, and resource configuration.

What about foundation-model APIs?

When provider weights are unavailable, scope focuses on the application-controlled layer: fine-tuned weights, prompts, retrieval infrastructure, orchestration, and evaluation harness.

Is AI escrow required today?

Critical AI systems can already fall within RBI, SEBI, DORA, and sector continuity obligations. The EU AI Act adds AI-specific documentation and oversight requirements.

GET STARTED

Find out which AI systems in your estate need custody and verification.

A 15-minute briefing. We map your AI vendor estate, identify the artefact layers outside current escrow scope, and show you a verified AI Proof of Recovery.

Book a 15-min briefing
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