[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

SOURCE CODE ESCROW

Source code escrow. Now with proof that it actually works

Storing source code with a third party satisfies the letter of the law. Castler goes further: AI agents rebuild your vendor's codebase in a clean environment, without vendor involvement, and produce a signed Proof of Recovery for every verified release.

ISO 27001 · SOC 2 Type II · CERT-In · PCI DSS · RBI aligned

Escrow scope
SourceLayer 1
DependenciesLayer 2
BuildLayer 3
RecoveryVerified
Custody mapped to signed evidence

WHAT IT IS

Source code escrow, defined precisely.

Source code escrow is a legal and operational arrangement in which a software vendor deposits the source code of a critical application, together with build instructions, configuration files, and dependencies, with an independent third party. The deposit is released to the beneficiary if predefined conditions such as insolvency, discontinued support, or product abandonment are met.

The purpose is continuity. If the vendor can no longer support the software, the beneficiary must be able to maintain, rebuild, and operate the system independently.

Traditional escrow rarely proves that outcome. A stored deposit may be incomplete, stale, or dependent on infrastructure the beneficiary cannot access. Until the software is independently rebuilt and run outside the vendor environment, the agreement is a legal instrument, not a recovery plan.

THE PROBLEM

Three ways source code escrow fails the institutions that rely on it.

01

The deposit is never verified

The standard model stores a code archive. Nobody rebuilds it, confirms that it compiles, checks the dependencies, or verifies that the resulting binary matches the production system. The first real test often happens on the day recovery is required.

02

The deposit goes stale within months

Software changes continuously. An annual filing cycle can leave the deposited release many months behind production, disconnected from current infrastructure, APIs, and data formats.

03

The agreement is the output, not evidence

A signed agreement, deposit acknowledgement, or assessment PDF does not demonstrate that the software runs. Regulators and boards need current, examinable recovery evidence.

THE CASTLER APPROACH

From deposit to signed Proof of Recovery. Automatically.

Castler replaces the document-centric model with a verification-centric one. Every deposit triggers an agentic verification pipeline, and the output is a signed evidence pack proving the software rebuilt, ran, and replicated outside the vendor environment.

1

Secure deposit

The vendor deposits code, configuration, build scripts, infrastructure-as-code, and dependency manifests through an encrypted, version-controlled intake pipeline.

2

Agentic verification

AI agents rebuild and deploy the deposit in a clean environment with no connection to the vendor's systems.

3

Engineer review and seal

A named Castler engineer reviews the evidence and signs the result.

4

Proof of Recovery artefacts

The signed evidence pack is linked to the exact release tested and refreshed when a new release is verified.

THE CASTLER APPROACH

Every verified release produces an evidence pack.

A named engineer reviews the build logs, deployment trace, replication evidence, and SBOM. The beneficiary receives a signed Build Report, Deployment Runbook, Replication Report, SBOM, Confidence Score, Engineer’s Seal, and Public Verification Record.

Deposit scope

Full application source code

Build and compilation scripts

Infrastructure-as-code

Dependency manifests and lockfiles

Database schema and migration scripts

Environment configuration files

Deployment runbooks

Third-party licence inventory

Verification pipeline

Castler agents work in a clean, isolated cloud environment. They parse the build manifest, resolve dependencies, execute the build, deploy the result, and replicate the declared architecture without relying on vendor infrastructure.

Signed output

A named engineer reviews the build logs, deployment trace, replication evidence, and SBOM. The beneficiary receives a signed Build Report, Deployment Runbook, Replication Report, SBOM, Confidence Score, Engineer’s Seal, and Public Verification Record.

AGREEMENT SCOPE

What a Castler source code escrow agreement covers

Deposit scope

Source code

Build scripts

Infrastructure-as-code

Dependency manifests

Database schema

Environment configuration

Operational runbooks

Licence inventory

Verification output

Independent clean build

Dependency resolution check

Deployment and replication test

SBOM per release

Confidence Score

Signed Build Report

Executable Deployment Runbook

Named engineer seal

REGULATORY MANDATE

Source code escrow requirements across active mandates.

RBI IT Directions 2023 §12(f)

Banks, NBFCs, and AIFIs must maintain an exit strategy for outsourced IT services, including source-code access for critical applications.

Evidence map

RBI PSO Directions 2024 §17(c)

Non-bank payment system operators must escrow source code for critical payment technology.

Evidence map

SEBI CSCRF

Market institutions and qualified regulated entities must protect continuity for critical third-party applications.

Evidence map

IRDAI Cyber Security Guidelines 2023

Insurers must ensure source-code availability through escrow arrangements.

Evidence map

EU DORA

Critical ICT contracts must address access, verification, exit, and recovery rights.

Evidence map

UK PRA SS2/21

Material outsourcing arrangements require documented exit plans and continuity evidence.

Evidence map
See all 17 mandates

CASTLER VS TRADITIONAL ESCROW

What you get with Castler source code escrow.

ComparisonTraditional Source Code EscrowCastler Source Code Escrow
Deposit scopeSource code archiveSource, IaC, configuration, and runbooks
VerificationNone or manual reviewAgentic rebuild and replication
FrequencyOne-off or annualEvery release
Time to evidence14 to 28 days6 to 18 hours
OutputAgreement and archiveSigned Proof of Recovery
SBOMNot includedIncluded per release
Named engineerNoYes, every proof
Public verification URLNoYes

FREQUENTLY ASKED

Questions about this escrow type

What release conditions typically trigger a source code escrow release?

Common triggers include vendor insolvency, acquisition followed by discontinued support, product abandonment, material service breach after a cure period, and regulatory access requirements. The agreement can be extended for sector-specific conditions.

Does the vendor need to cooperate with verification?

The initial deposit must contain the agreed materials. The verification itself is designed to run without vendor involvement or access to the vendor environment.

How is the deposit kept current?

Repository and CI/CD integrations can trigger a new deposit and verification cycle on each production release. The beneficiary can see the current verified version and any divergence from production.

What happens if verification fails?

The failure is reported immediately with the exact build or deployment stage, severity, logs, and remediation required. Discovering the gap before an incident gives the institution time to act.

GET STARTED

Find out whether your vendor estate is actually recoverable.

A 15-minute briefing. We walk you through your Software Estate, identify which vendors require source code escrow, and show you a live signed Proof of Recovery.

Book a 15-min briefing
ISO 27001SOC 2 Type IIPCI DSS

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