INDIA · IRDAI
IRDAI's information and cyber-security guidelines require insurers to manage technology and outsourcing risk, including business continuity and the resilience of critical systems. This guide explains the requirement, scope, timeline and evidence mapping for software escrow and Software Recoverability.
REGULATORY EVIDENCE MAP
IRDAI CS
PERIMETER
India
REQUIREMENT
Information and cyber-security governance
CASTLER EVIDENCE
Critical insurance systems are independently rebuilt and verified
OUTPUT
Signed Proof of Recovery
IRDAI Information and Cyber Security Guidelines 2023 — software escrow and critical applications
In forceWho it applies to
Insurers should maintain the required controls as part of the current information and cyber-security framework and address gaps through governance and audit processes.
What the regulation requires
The Castler artefact that evidences it
Information and cyber-security governance
Critical insurance systems are independently rebuilt and verified
Outsourcing and third-party risk management
Outsourcing resilience is evidenced per release
Business-continuity and disaster-recovery capability
Disaster recovery is demonstrated with a signed Proof of Recovery
Oversight of critical technology systems
Recovery becomes a repeatable, examinable procedure
THE GLOBAL REGULATORY MANDATE
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
1 · WHAT THE REGULATION IS
IRDAI’s Information and Cyber Security Guidelines 2023 establish technology, outsourcing, cyber-security, continuity and critical-application expectations for the insurance sector.
IRDAI's information and cyber-security guidelines require insurers to manage technology and outsourcing risk, including business continuity and the resilience of critical systems. For a CIO, CISO or compliance officer, the practical issue is whether a critical third-party application can remain available when the provider fails, exits, is acquired or can no longer support the product.
Software escrow addresses custody: who holds the source code, build materials and documentation. Software Recoverability addresses the next question: whether those materials have been independently rebuilt, deployed and tested. The distinction matters because an agreement and a deposit do not prove that recovery can be completed within the institution’s operational tolerance.
Castler therefore treats the requirement as part of vendor onboarding. The agreement and first deposit are established when the relationship begins, every release is captured, and the verification evidence is renewed before an auditor, insurer or supervisor asks for it.
2 · EXACT REQUIREMENT
In summary
Insurers should maintain software escrow and source-code availability arrangements for critical applications so continuity does not depend solely on the continued availability of the software vendor.
Reference: Insurance Regulatory and Development Authority of India — Information and Cyber Security Guidelines 2023. For legal interpretation and exact operative wording, use the current official text and advice applicable to your supervisory perimeter.
In practical terms, compliance requires more than a clause in the vendor contract. The institution must identify which applications are critical, establish custody or source-code access, ensure the deposited materials remain current, document release conditions and maintain evidence that continuity or exit can be executed.
Where the framework requires tested recovery, resilience or credible exit, a stored deposit is only the starting control. Independent build evidence, deployment instructions, architecture replication and a signed engineer review show that the recovery path has been exercised rather than assumed.
Life, general and health insurers
Insurance intermediaries within scope
Technology and outsourcing functions
Owners of critical policy, claims and actuarial applications
The accountable group normally includes technology, information security, outsourcing, procurement, compliance, business continuity and the business owner of the supported service. Scope should be based on criticality, not only contract value.
In force
Insurers should maintain the required controls as part of the current information and cyber-security framework and address gaps through governance and audit processes.
Institutions should work backwards from the operative date. Vendor identification, agreement execution, repository integration, initial deposit, reconciliation and first verification all require lead time. Onboarding-first implementation avoids a deadline-driven retrofit.
5 · CONSEQUENCES
Weak escrow or continuity controls can produce audit findings, remediation obligations, supervisory concern and increased operational exposure across policy administration, claims and other critical services.
The operational consequence can be more severe than the supervisory consequence. If a critical provider fails and the deposited software cannot be built or deployed, the institution may breach customer commitments, impact tolerances, market obligations and board-approved continuity objectives while the technical team reconstructs undocumented knowledge under incident conditions.
A current custody record and signed Proof of Recovery reduce that uncertainty. They do not replace legal analysis, incident planning or the institution’s own controls; they create tested technical evidence that those controls rely on.
6 · CASTLER EVIDENCE MAPPING
The mapping is specific: each obligation is paired with the Castler artefact or operating control that provides relevant evidence. It is not a claim that software alone guarantees compliance.
| Regulatory requirement | Castler evidence |
|---|---|
| Information and cyber-security governance | Critical insurance systems are independently rebuilt and verified |
| Outsourcing and third-party risk management | Outsourcing resilience is evidenced per release |
| Business-continuity and disaster-recovery capability | Disaster recovery is demonstrated with a signed Proof of Recovery |
| Oversight of critical technology systems | Recovery becomes a repeatable, examinable procedure |
Cloud Custody
Establish the software escrow agreement, current deposit, release history and audit trail required as the custody foundation.
Explore custody →Software Recoverability
Add independent rebuild, deployment, replication, confidence scoring and an engineer-sealed Proof of Recovery.
Explore Proof of Recovery →7 · FREQUENTLY ASKED QUESTIONS
An agreement can satisfy the contractual custody element, but IRDAI CS also expects the institution to manage continuity, third-party risk or recovery evidence. The exact answer depends on the clause and supervisory perimeter.
The deposit should track the production release. Automated repository capture, version history and release identifiers make it possible to show that updates and fixes are included rather than relying on the original filing.
The vendor participates in onboarding, deposit setup and structured reconciliation where documentation is missing. Verification is then designed to run independently so the vendor does not need to be present every time.
Present the executed escrow arrangement, deposit and release history, build report, deployment runbook, replication report, SBOM, confidence score, exception record and signed Proof of Recovery for the release in scope.
Yes. Cloud Custody establishes the current deposit and agreement. The same record can be upgraded to Standard or Premium Software Recoverability without creating a new custody foundation.
Re-test when the vendor releases a material version and according to the institution’s criticality, regulatory and board-approved assurance cycle. Per-release verification avoids stale annual evidence.
8 · RELATED REGULATIONS
European Union
EU DORA
DORA requires financial entities to keep ICT third-party risk under control across the full lifecycle of a contract — including a documented exit strategy and assurance that a critical or important function can continue if a provider fails (Article 28).
Read the mappingIndia
RBI §12(f)
RBI's directions on outsourcing of IT services require regulated entities to maintain robust exit strategies and business-continuity arrangements so critical operations survive a service provider's exit or failure.
Read the mappingIndia
RBI PSO §17(c)
RBI's framework for Payment System Operators sets expectations for outsourcing governance and continuity so payment services remain resilient to the failure of a technology provider.
Read the mappingThis guide is for regulatory orientation and does not constitute legal advice. Verify obligations against current official texts and professional advice for your entity.
CASTLER SRP EVIDENCE
IRDAI CS Guidelines 2023 require insurers to ensure source code availability via escrow arrangements. Castler SRP goes beyond contractual cover to provide independently verified recoverability — the Standard Verification and Premium Recoverability tiers produce evidence that the deposit is complete, buildable and deployable.
IRDAI CS
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