[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

SAAS ESCROW

Your critical software runs in someone else's cloud. What happens when they disappear?

SaaS means you never hold the software. A traditional source code deposit does not change that. Castler captures and verifies the full SaaS application stack: source, infrastructure, configuration, and data export mechanisms, tested in a clean environment without vendor involvement.

Escrow scope
SourceLayer 1
IaCLayer 2
ConfigurationLayer 3
Data exportVerified
Custody mapped to signed evidence

WHAT IT IS

SaaS escrow, and why it is different from source code escrow.

SaaS escrow is a continuity arrangement for software delivered entirely as a cloud-hosted service. The vendor runs the application, controls the infrastructure, manages updates, and controls access. The enterprise dependency is total.

A source code deposit assumes the beneficiary can take the code and run it. SaaS applications often depend on vendor-managed infrastructure, databases, multi-tenant orchestration, and private APIs. Source alone addresses only one layer of the recovery problem.

SaaS escrow must cover source code, infrastructure-as-code, environment configuration, database schemas, data export mechanisms, integration maps, and operational runbooks. Castler verifies the entire stack in a clean environment.

THE PROBLEM

Three reasons standard escrow does not work for cloud-native software.

01

The operating environment is missing

A SaaS application running on Kubernetes, managed databases, private networking, and vendor APIs cannot be recovered from source code alone. The infrastructure and configuration are part of the system.

02

Tenant isolation makes recovery non-trivial

Multi-tenant applications require a documented way to isolate one organisation's data and configuration. That recovery path is rarely present in a standard code deposit.

03

Data portability is an afterthought

A rebuilt SaaS application is useless without a current operational dataset, schema history, export format, and tested restore procedure.

THE CASTLER APPROACH

Full-stack SaaS custody and agentic verification.

SaaS recovery is an infrastructure problem, not only a code custody problem. The deposit, verification pipeline, and evidence pack must reflect the full cloud-native architecture.

What Castler custodies

Application source and build artefacts

Terraform and Helm charts

Docker and OCI-compliant container images

Kubernetes manifests for EKS, GKE, AKS, and on-premises clusters

Environment configuration templates

Database schemas and migrations

Data export pipeline definitions

API integration maps

Tenant isolation documentation

Independent deployment runbooks

Verification pipeline

Agents provision the declared infrastructure, initialise the database schema, deploy the containers, and execute a functional replication test in a clean cloud environment without access to vendor credentials.

Signed output

Signed Proof of Recovery with Build Report, Infrastructure Deployment Trace, Replication Report, Data Schema Validation Report, SBOM, Confidence Score, named engineer seal, and public verification URL.

REGULATORY MANDATE

SaaS escrow requirements across active mandates.

EU DORA

Critical ICT third-party risk frameworks must address recoverability of cloud and SaaS services.

Evidence map

UK PRA SS2/21

Material SaaS outsourcing arrangements require exit plans and independent continuity evidence.

Evidence map

MAS TRM

Financial institutions must maintain continuity for critical systems delivered by third-party technology providers.

Evidence map

APRA CPS 230

Regulated entities must continue critical operations within tolerance during service-provider disruption.

Evidence map

RBI IT Directions 2023 §12(f)

The outsourced IT exit obligation applies across delivery models, including SaaS.

Evidence map
See all 17 mandates

CASTLER VS TRADITIONAL ESCROW

What you get with Castler SaaS escrow.

ComparisonTraditional Source Code EscrowCastler SaaS Escrow
Source codeIncludedIncluded
Infrastructure-as-codeNot includedIncluded
Container imagesNot includedIncluded
Database schema and migrationsRarelyIncluded
Data export pipelineNot includedIncluded
Environment configurationNot includedStructure included
VerificationNoneAgentic full-stack deployment
OutputStored archiveSigned Proof of Recovery

FREQUENTLY ASKED

Questions about this escrow type

Can a major enterprise SaaS platform be escrowed?

In many cases, yes. The deposit relationship may be established through vendor cooperation or a managed exit provision in the licence agreement. The scope depends on the platform and contractual rights.

What if the SaaS vendor will not deposit source code?

Regulatory and procurement requirements give enterprises leverage to require escrow in new contracts and renewals. Castler provides deposit specifications and agreement support.

How are multi-cloud applications handled?

Verification can provision AWS, Google Cloud Platform, and Microsoft Azure environments. Multi-cloud scope is agreed at onboarding and includes the IaC for each required component.

What about vendor-managed AI components?

AI model weights, prompts, inference pipelines, and evaluation artefacts are handled through AI & Model Escrow, which can be combined with SaaS escrow in one scope.

GET STARTED

Map your SaaS vendor estate against the mandates that apply to you.

A 15-minute briefing. We identify which SaaS vendors require escrow and show you what a full-stack SaaS Proof of Recovery looks like.

Book a 15-min briefing
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