[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

SOFTWARE ESCROW & RECOVERABILITY REGULATIONS

One signed Proof of Recovery. Every rulebook that matters

Financial regulators are converging on the same expectation: critical third-party software must remain recoverable when the provider fails. Castler maps software escrow, current custody and signed recovery evidence to the exact framework that governs your institution.

RBISEBIIRDAIDORAFCAMASAPRA

GLOBAL COVERAGE

Nine jurisdictions. Seventeen evidence maps

Select a jurisdiction to open the regulation, deadline and evidence mapping behind it.

● IN FORCE● DEADLINE PENDING● STANDARD

THE GLOBAL REGULATORY MANDATE

The regulator stopped asking “Do you have escrow?” It now asks “Can you prove recovery?”

Across financial regulation, cyber-resilience rules and global assurance standards, the direction is converging: critical third-party software must remain current, testable and recoverable when its provider fails.

17

MANDATES

9

JURISDICTIONS

European UnionUnited KingdomUnited StatesAustraliaSingaporeSaudi ArabiaUnited Arab EmiratesGlobal StandardsIndia
Explore every mandate and evidence map

17

Regulation and standard mappings

9

Regions and framework groups

Per release

Current recoverability evidence

Signed

Board-examinable artefact

THE STRUCTURAL SHIFT

The agreement was a proxy. Regulators now want the evidence

Software escrow regulation began with a custody problem: a regulated institution depended on software it did not own and needed continuing access if the vendor failed. The contract and source-code deposit created a legal path to those materials. Modern frameworks now examine whether the institution can actually maintain the critical function through disruption.

That change is visible across RBI IT Directions §12(f), RBI PSO §17(c), SEBI CSCRF and IRDAI’s Information and Cyber Security Guidelines in India; DORA Articles 9, 28 and 30 in Europe; PRA SS2/21 and the UK operational-resilience regime; MAS technology-risk expectations; and APRA CPS 230. The language differs, but the operational question is consistent: is the third-party dependency understood, current, testable and recoverable?

Castler separates the two layers. Cloud Custody establishes software escrow, current deposit capture, agreement management and an audit trail from vendor onboarding. Software Recoverability independently rebuilds, deploys and replicates the application, then seals the evidence as a signed Proof of Recovery.

Exact requirement

Each detail page names the article, section, scope and current status.

Artefact mapping

Every regulatory expectation is paired with a specific custody or Proof of Recovery artefact.

Onboarding-first

The control begins when the vendor contract starts, not when an audit finding appears.

THE DIRECTORY

Pick your jurisdiction. Read the exact evidence mapping

Each page explains the issuing body, requirement reference, entity scope, compliance timeline, consequences, Castler mapping, frequently asked questions, and related regulations. The summaries support orientation and should be read alongside official texts and professional advice.

India — RBI · SEBI · IRDAI

Source-code escrow, current deposits, third-party cyber resilience, and recovery evidence across banking, payments, capital markets, and insurance.

European Union

DORA, NIS2 and the Cyber Resilience Act place digital resilience, supply-chain controls and lifecycle evidence at the centre of technology governance.

United Kingdom

PRA and FCA expectations require credible stressed exit, material-provider continuity, impact tolerances and demonstrable operational resilience.

United States

Third-party technology, continuity and recoverability requirements for the jurisdiction or standard.

Australia

APRA CPS 230 requires operational-risk management, material-service-provider controls and continuity of critical operations within tolerance.

Singapore

MAS technology-risk guidance covers outsourced software, third-party governance, secure delivery and tested IT continuity.

Saudi Arabia

Third-party technology, continuity and recoverability requirements for the jurisdiction or standard.

United Arab Emirates

Third-party technology, continuity and recoverability requirements for the jurisdiction or standard.

Global standards

ISO 27001, ISO 22301 and SOC 2 provide assurance structures for suppliers, continuity, availability and operating effectiveness.

REGULATORY MAPPING

Show your regulator recovery is a procedure

Bring your perimeter. We’ll map the current custody, critical applications, article language and signed recovery evidence your institution needs.

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

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