INDIA · SEBI
SEBI's CSCRF sets cybersecurity and cyber-resilience expectations for regulated entities in capital markets, including third-party / vendor risk and recovery capability. This guide explains the requirement, scope, timeline and evidence mapping for software escrow and Software Recoverability.
REGULATORY EVIDENCE MAP
SEBI CSCRF
PERIMETER
India
REQUIREMENT
Cyber-resilience governance for regulated entities
CASTLER EVIDENCE
Vendor software is independently rebuilt and verified
OUTPUT
Signed Proof of Recovery
SEBI CSCRF — critical third-party applications and continuity controls
In forceWho it applies to
Entities should comply according to their CSCRF category and applicable implementation circulars, maintaining current evidence for critical applications.
What the regulation requires
The Castler artefact that evidences it
Cyber-resilience governance for regulated entities
Vendor software is independently rebuilt and verified
Third-party and vendor risk management
A signed Proof of Recovery evidences recovery capability
Recovery and continuity capability
Third-party risk is reduced by proven recoverability
Ongoing assurance and testing
Resilience testing is reinforced every release
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
SEBI’s Cybersecurity and Cyber Resilience Framework establishes cyber-governance, vendor-risk and continuity expectations across market infrastructure institutions and regulated entities.
SEBI's CSCRF sets cybersecurity and cyber-resilience expectations for regulated entities in capital markets, including third-party / vendor risk and recovery capability. 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
Critical third-party applications should be governed through appropriate source-code escrow, vendor continuity, cyber-resilience and testing arrangements proportionate to their importance to market operations.
Reference: Securities and Exchange Board of India — Cybersecurity and Cyber Resilience Framework. 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.
Stock exchanges
Depositories
Clearing corporations
Qualified regulated entities and market intermediaries
Technology teams operating critical third-party 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
Entities should comply according to their CSCRF category and applicable implementation circulars, maintaining current evidence for critical applications.
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
Non-compliance may create audit findings, supervisory remediation, heightened cyber-resilience scrutiny and operational risk where critical market functions rely on an unavailable vendor.
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 |
|---|---|
| Cyber-resilience governance for regulated entities | Vendor software is independently rebuilt and verified |
| Third-party and vendor risk management | A signed Proof of Recovery evidences recovery capability |
| Recovery and continuity capability | Third-party risk is reduced by proven recoverability |
| Ongoing assurance and testing | Resilience testing is reinforced every release |
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 SEBI CSCRF 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
SEBI's Cyber Security and Cyber Resilience Framework requires Market Infrastructure Institutions and Qualified Regulated Entities to escrow source code for critical third-party applications. Castler SRP provides the custody, verification and signed Proof of Recovery that satisfies the CSCRF evidence requirement.
SEBI CSCRF
Bring your SEBI CSCRF perimeter. We’ll map the critical systems, current custody and Proof of Recovery evidence required for a defensible procedure.
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