[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

ASIA-PACIFIC · SINGAPORE & AUSTRALIA

Asia-Pacific software escrow and recoverability regulations

Singapore's MAS Technology Risk Management Guidelines and Australia's APRA CPS 230 both expect financial institutions to keep critical services running when a technology provider fails. Compare the two frameworks and see where custody and signed Proof of Recovery evidence fit.

MAS TRMAPRA CPS 230

SIDE BY SIDE

Asia-Pacific frameworks compared

MAS TRMSingapore

Regulator

Monetary Authority of Singapore (MAS)

Instrument

Technology Risk Management Guidelines

Status

In force as supervisory guidance

Applies to

Banks, merchant banks, insurers, capital-markets intermediaries, payment-service providers and other MAS-supervised institutions

Focus

Technology and vendor risk governance, secure software delivery and IT business continuity

APRA CPS 230Australia

Regulator

Australian Prudential Regulation Authority (APRA)

Instrument

Prudential Standard CPS 230 Operational Risk Management

Status

In force from 1 July 2025

Applies to

Authorised deposit-taking institutions, general, life and private health insurers, and RSE licensees

Focus

Critical operations within tolerance and the risks of material service-provider arrangements

Summaries support orientation. For exact operative wording, use the current official text and advice applicable to your supervisory perimeter.

WHAT THE FRAMEWORKS SHARE

Two rulebooks, one recovery question

The wording differs by regulator. The operational question is the same: can the critical service keep running if the vendor behind it fails?

01

Vendor risk sits with the board

MAS expects sound governance of technology and vendor risk. CPS 230 requires board oversight of operational resilience and material service providers.

Per-release seals give the board current, examinable evidence for each critical vendor.

02

Continuity has to survive provider failure

MAS TRM covers IT business continuity and recovery capability. CPS 230 asks for credible plans to respond to the failure or exit of a provider.

Vendor software is rebuilt and deployed independently, so the exit plan is a tested procedure.

03

Recovery must be tested, not assumed

MAS expects recovery capability to be documented and tested. CPS 230 requires critical operations to stay within tolerance through disruption.

A signed Proof of Recovery records that the system was restored without the original vendor.

HOW CASTLER FITS

Custody first, then proof that recovery works

A stored deposit gives you a legal path to the materials. Independent verification shows the recovery path has been exercised. Castler separates the two so you can start with custody and add verification when the framework or your board asks for it.

FAQ

Asia-Pacific regulations, answered

Which Asia-Pacific regulations does Castler map?+

This hub covers Singapore's MAS Technology Risk Management Guidelines and Australia's APRA CPS 230. Each framework has its own evidence page with scope, status, consequences and a requirement-by-requirement mapping.

Is APRA CPS 230 in force?+

Yes. CPS 230 took effect on 1 July 2025 for APRA-regulated entities, including authorised deposit-taking institutions, insurers and RSE licensees.

Does MAS TRM prescribe software escrow?+

The MAS TRM Guidelines set expectations for third-party technology controls and tested IT continuity rather than one specific mechanism. Software escrow provides custody of source code and build materials. Independent rebuild and a signed Proof of Recovery show that continuity can actually be executed.

Can one programme cover entities in Singapore and Australia?+

Yes. The same custody, verification and Proof of Recovery artefacts are mapped to each framework's language, so a group operating in both markets keeps one evidence set per critical application.

ASIA-PACIFIC

Make the recovery claim examinable

Bring your Asia-Pacific perimeter. We'll map the critical systems, current custody and Proof of Recovery evidence each framework expects.

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