Saudi Arabia’s Communications, Space and Technology Commission (CST) released its Software Escrow Guideline at the end of 2025, establishing a best practice, formal framework, for how Critical National Infrastructure (CNI) organisations in the region should use escrow to protect their ability to access to critical software assets and build operational resilience. The guidance reflects the Kingdom’s broader regulatory direction under Vision 2030, which includes strengthening digital infrastructure, increasing trust in local technology providers, and improving continuity planning across public and private sectors.
CNI operators in energy, utilities, transport, and telecommunications depend on complex digital systems that must remain reliable even if a software vendor fails. The new guidance highlights additional expectations around third‑party software risk, business continuity and data governance.
CST’s guideline defines how software escrow should operate, clarifying the roles of developers, beneficiaries (end‑users), and escrow agents like Escode, helping to standardise escrow as a resilience mechanism rather than a “nice‑to‑have. It outlines procedures for deposit, verification, updates and controlled release of source code and essential technical materials. The objective is to ensure that organisations can access the assets they need to maintain mission‑critical software if a vendor fails, withdraws service, or is unable to meet contractual obligations.
Key aims include:
Supporting business continuity across sectors in the region.
Strengthen trust between software providers and beneficiaries.
Advancing the maturity of the local software market & unlocking new opportunities
This aligns closely with the country’s ongoing digital‑economy strategy, which emphasises secure software supply chains and stronger controls around critical national infrastructure.
Saudi regulators have accelerated resilience expectations due to increased dependency on third‑party digital services and the rising risk of software supply‑chain disruption. The guideline forms part of CST’s broader mandate to regulate and mature the local technology market, enhance trust, and support business continuity planning.
It also complements existing national frameworks governing data protection and cybersecurity, including:
For CNI, these frameworks collectively reinforce the expectation that critical digital assets and third-party risk must be controlled, auditable, and recoverable.
CNI operators face some of the strictest regulatory expectations due to the essential nature of the services they deliver. CST’s Software Escrow Guideline key compliance actions include:
1. Identify critical software dependencies
Assess which applications, whether operational technology (OT), industrial control systems (ICS) or enterprise software, are essential for uninterrupted operation. CST expects clear classification and understanding of digital software and applications, and their associated risks. Your escrow agent should be able help with this by undertaking a third-party risk assessment with you.
2. Implement appropriate escrow arrangements
Where critical systems rely on third‑party software, institutions should maintain a verified escrow agreement that:
3. Implement regular verification and testing
The guideline emphasises that escrow deposits should be validated to ensure they are usable when required. Verification activities may include build testing, documentation review, or deployment checks.
4. Maintain compliance with data residency and sovereignty rules
CNI organisations must comply with overlapping rules governing data movement, including:
This means ensuring your escrow provider can store materials entirely within Saudi Arabia when required. Escode offers a localised service to ensure compliance with these rules.
When selecting an escrow provider, firms should ensure the provider can meet both CST expectations and Saudi data‑localisation rules. Key criteria include:
1. Localised storage and data handling
The provider must support secure storage within Saudi Arabia, ensuring compliance with PDPL, NDMO, SAMA, and CST restrictions on data transfers.
2. Robust verification services
CST explicitly references the importance of verification to maintain trust and business continuity. A provider should offer tiered verification options and documented testing processes.
3. Alignment with sector‑specific requirements:
CNI environments must align with national data governance and cyber security rules (e.g., NCA CCC‑2020). A compliant escrow provider must support these frameworks.
4. Transparent and controlled release mechanisms:
Transparent and controlled release mechanisms: The provider should follow CST‑defined release and incident‑notification procedures, enabling controlled, auditable access to escrowed materials when continuity triggers occur.
Escode is the global leader in software escrow and is trusted by our clients in the region to deliver escrow services aligned with global best practice and tailored to the requirements emerging in Saudi Arabia. Speak to our Saudi team about how our services can support your regulatory compliance:
Choose Escode for a highly experienced software escrow service provider who can help you comply with the CST guideline, while also understanding and meeting broader national expectations for data protection, operational resilience and third‑party risk management.
