[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

MIDDLE EAST · SAUDI ARABIA & UAE

Middle East software escrow and recoverability regulations

Saudi Arabia's CST Software Escrow Guideline and the ADGM FSRA's IT risk guidance both focus on keeping critical services running when a technology provider can no longer deliver. Compare the two frameworks and see where custody and signed Proof of Recovery evidence fit.

CST EscrowADGM FSRA IT Risk

SIDE BY SIDE

Middle East frameworks compared

CST EscrowSaudi Arabia

Regulator

Communications, Space & Technology Commission (CST)

Instrument

Software Escrow Guideline

Status

Published guidance

Applies to

Organisations that depend on critical technology, subject to current CST requirements and contractual obligations

Focus

Software-escrow and continuity arrangements for critical technology

ADGM FSRA IT RiskUnited Arab Emirates · ADGM

Regulator

ADGM Financial Services Regulatory Authority (FSRA)

Instrument

Information Technology Risk Management Guidance

Status

Current FSRA guidance

Applies to

FSRA-authorised firms, applied proportionately to their activities and risk profile

Focus

Technology and information risk, outsourcing and resilience of third-party critical systems

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

WHAT THE FRAMEWORKS SHARE

Two regulators, 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

An escrow deposit has to be operable

CST guidance looks for assurance that escrowed software can actually be operated, not only that a deposit exists.

Castler rebuilds and deploys the deposit, turning it into a proven, runnable system.

02

Outsourced critical systems need resilience

The FSRA expects firms to manage the resilience of outsourced and third-party-provided critical systems and oversee material outsourcing.

Critical third-party systems are independently re-verified on every release.

03

Continuity must hold when a provider fails

Both frameworks cover continuity of critical services, with the FSRA also expecting disaster-recovery capability.

A signed Proof of Recovery shows the recovery path has been executed, not just documented.

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

Middle East regulations, answered

Which Middle East regulations does Castler map?+

This hub covers Saudi Arabia's CST Software Escrow Guideline and the ADGM FSRA Information Technology Risk Management Guidance. Each framework has its own evidence page with scope, status, consequences and a requirement-by-requirement mapping.

Does the CST Software Escrow Guideline set a compliance deadline?+

No single universal deadline applies. The guideline is reference guidance, so organisations should confirm applicability against current CST requirements and their contractual obligations.

Who does the ADGM FSRA IT risk guidance apply to?+

It informs authorisation and supervisory review for firms regulated by the FSRA in Abu Dhabi Global Market. Firms apply it proportionately to their activities and risk profile.

Can one programme cover entities in Saudi Arabia and the UAE?+

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.

MIDDLE EAST

Make the recovery claim examinable

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

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