[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

UNITED ARAB EMIRATES · SOFTWARE ESCROW

Software Escrow for UAE Financial Institutions

UAE financial institutions operating under ADGM FSRA and DIFC frameworks need proportionate controls over critical vendor technology and credible operational-resilience arrangements. Castler SRP delivers signed Proof of Recovery for every verified deposit — creating evidence that the software was rebuilt and run without the vendor. CastlerX is our dedicated entity for the Kingdom of Saudi Arabia and the broader Gulf region.

01

What UAE regulators require

Financial institutions operating in the UAE manage technology risk across federal requirements and financial-free-zone frameworks. ADGM FSRA-regulated firms and DIFC firms are expected to govern outsourcing, information security, operational risk, business continuity, and material third-party dependencies in a manner proportionate to the services and risks involved.

For a critical vendor application, the control objective is broader than obtaining a contractual promise. The institution needs to understand what materials are available, whether the arrangement supports continuity and exit, how a vendor failure would affect regulated services, and whether the planned recovery procedure has been tested against the current release.

Software escrow and independent verification can support that control environment where the application's criticality, substitutability, concentration risk, or proprietary architecture makes vendor failure difficult to manage. The exact requirement should be assessed against the institution's licence, rulebook, outsourcing model, and legal advice rather than treated as a universal control for every supplier.

02

CastlerX for the Gulf region

Castler operates CastlerX as a dedicated entity for the Kingdom of Saudi Arabia and the broader Gulf region. The structure supports locally aligned software escrow and recoverability engagements for institutions navigating Gulf regulatory, contracting, residency, and operating requirements.

Saudi frameworks place explicit emphasis on cyber-security requirements in vendor contracts, risk assessment, audit rights, business continuity, termination, and escrow agreements where applicable. UAE and KSA institutions can use the same Castler SRP verification platform while the engagement structure, agreement, custody model, and evidence package are aligned to the relevant jurisdiction and institutional perimeter.

CastlerX does not replace an institution's legal or regulatory assessment. It provides a regional operating structure through which the technical escrow, custody, verification, and Proof of Recovery workflow can be scoped with the appropriate stakeholders.

03

What Proof of Recovery means for UAE compliance

Castler SRP rebuilds and redeploys the vendor's application in a clean environment without the vendor present. The process tests whether the deposited source code, build scripts, dependencies, configuration, documentation, and deployment knowledge are sufficient for an independent recovery procedure.

The resulting signed Proof of Recovery includes a Build Report, Deployment Runbook, Replication Report, SBOM, recorded exceptions, and the seal of a named verification engineer. This creates a dated evidence pack for internal audit, technology-risk oversight, outsourcing reviews, business continuity, and discussions with supervisors.

The evidence is specific to the verified release and environment. Where gaps are found, Castler records them and works through structured reconciliation so the institution and vendor know what must be corrected before the next verification cycle.

04

How a UAE engagement is structured

The engagement begins with the institution's regulatory perimeter, application criticality, vendor contract, hosting arrangement, release cadence, data-residency requirements, and existing continuity controls. Castler then defines the deposit schedule, required materials, access model, release conditions, and verification depth with legal, risk, technology, and vendor stakeholders.

After the deposit is captured, Castler verifies integrity and completeness, reconstructs the application, documents the emergency deployment procedure, and produces the signed evidence pack. Later production releases can be captured against the same custody record and verified using the established foundation.

A standard single-vendor engagement is commonly scoped over four to six weeks from agreement to the first Proof of Recovery. Complexity, deposit quality, vendor responsiveness, security controls, and environment requirements can extend the timetable. Multi-vendor programmes are prioritised by criticality and scheduled individually.

FREQUENTLY ASKED QUESTIONS

Software escrow in United Arab Emirates

Does Castler SRP operate in the UAE?+

Yes. Castler SRP supports UAE financial institutions directly, including firms operating under ADGM FSRA and DIFC frameworks. The engagement is scoped to the institution's exact licence, technology-risk model, and vendor estate.

What is CastlerX?+

CastlerX is Castler's dedicated entity for the Kingdom of Saudi Arabia and the broader Gulf region. It provides a regional structure for locally aligned escrow and recoverability engagements using the Castler SRP verification platform.

How does software escrow support ADGM-aligned controls?+

For critical vendor software, escrow can support access, continuity, and exit planning when applied proportionately. Castler adds independent verification so the institution receives evidence that the current release was rebuilt and deployed, rather than relying on storage alone.

How quickly can Castler onboard a UAE institution?+

A standard single-vendor engagement is typically scoped over four to six weeks from agreement to the first Proof of Recovery. The final timetable depends on application complexity, deposit completeness, vendor participation, and environment requirements.

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