[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
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GLOBAL · ISO 22301

ISO 22301Business Continuity Management Systems

ISO 22301 specifies requirements for a business-continuity management system — the capability to continue delivering products and services at acceptable levels after disruption. This guide explains the requirement, scope, timeline and evidence mapping for software escrow and Software Recoverability.

REGULATORY EVIDENCE MAP

ISO 22301

Published · ISO 22301:2019
01

PERIMETER

Global Standards

02

REQUIREMENT

A business-continuity management system (BCMS)

03

CASTLER EVIDENCE

Recovery of vendor-built systems becomes a tested, evidenced procedure

OUTPUT

Signed Proof of Recovery

ARTICLE ANATOMY

Business Continuity Management Systems

Published · ISO 22301:2019

Who it applies to

  • Entities and teams responsible for a business-continuity management system (BCMS)
  • Entities and teams responsible for business-impact analysis and recovery objectives
  • Entities and teams responsible for tested continuity and recovery procedures
  • Entities and teams responsible for assurance over dependencies including technology providers

ISO 22301:2019 is the current published edition. Adoption and certification follow the organisation’s business-continuity programme and audit cycle rather than a single statutory deadline.

Requirement

A business-continuity management system (BCMS)

Castler artefact

Recovery of vendor-built systems becomes a tested, evidenced procedure

Requirement

Business-impact analysis and recovery objectives

Castler artefact

A signed Proof of Recovery supports your recovery-time objectives

Requirement

Tested continuity and recovery procedures

Castler artefact

Continuity testing is reinforced every release

Requirement

Assurance over dependencies including technology providers

Castler artefact

Technology-provider dependencies are independently verifiable

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

1 · WHAT THE REGULATION IS

What is ISO 22301?

Business Continuity Management Systems is the governing framework or standard represented on this page.

ISO 22301 specifies requirements for a business-continuity management system — the capability to continue delivering products and services at acceptable levels after disruption. 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

Business Continuity Management Systems

In summary

A business-continuity management system (BCMS); Business-impact analysis and recovery objectives; Tested continuity and recovery procedures; Assurance over dependencies including technology providers

Reference: International Organization for Standardization — ISO 22301:2019, Business continuity management systems — Requirements. 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.

3 · Who it applies to

Entities and teams responsible for a business-continuity management system (BCMS)

Entities and teams responsible for business-impact analysis and recovery objectives

Entities and teams responsible for tested continuity and recovery procedures

Entities and teams responsible for assurance over dependencies including technology providers

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.

4 · Compliance timeline

Published · ISO 22301:2019

ISO 22301:2019 is the current published edition. Adoption and certification follow the organisation’s business-continuity programme and audit cycle rather than a single statutory deadline.

Organisations should align implementation, evidence collection and review cadence with the applicable certification, examination, supervisory or contractual cycle. Vendor identification, agreement execution, repository integration, initial deposit, reconciliation and first verification all require lead time.

5 · CONSEQUENCES

What happens when the evidence is missing?

Failure to maintain credible third-party resilience can lead to audit findings, remediation programmes, increased supervisory scrutiny, reputational damage and operational loss during a provider disruption.

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

How Castler maps to ISO 22301.

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 requirementCastler evidence
A business-continuity management system (BCMS)Recovery of vendor-built systems becomes a tested, evidenced procedure
Business-impact analysis and recovery objectivesA signed Proof of Recovery supports your recovery-time objectives
Tested continuity and recovery proceduresContinuity testing is reinforced every release
Assurance over dependencies including technology providersTechnology-provider dependencies are independently verifiable

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

ISO 22301 questions from compliance and technology teams.

Does having a software escrow agreement satisfy the requirement?

An agreement can satisfy the contractual custody element, but ISO 22301 also expects the institution to manage continuity, third-party risk or recovery evidence. The exact answer depends on the clause and supervisory perimeter.

How current must the source-code deposit be?

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.

Does the software vendor need to participate in every verification?

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.

What evidence should be presented to an auditor or supervisor?

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.

Can an institution begin with custody and add verification later?

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.

How often should recoverability be re-tested?

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

Continue the third-party resilience mapping

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 mapping

Global Standards

ISO 27001

ISO/IEC 27001 is the international standard for information-security management, including supplier-relationship and operations-security controls relevant to third-party software.

Read the mapping

Global Standards

SOC 2

SOC 2 reports on controls relevant to the trust-services criteria, including availability — the system's ability to be available for operation and use to meet commitments.

Read the mapping

This guide is for regulatory orientation and does not constitute legal advice. Verify obligations against current official texts and professional advice for your entity.

ISO 22301

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