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14 April 2026

Strengthening Control and Third‑Party Risk Management for Australia’s Financial Market Infrastructure

 

How a major Australian financial market organisation strengthened control and third‑party risk management during the transformation of systemically important infrastructure.

Background

A major Australian financial market organisation supports systems that underpin systemically important market activity.

As part of a long-term transformation programme, the organisation began replacing a core legacy platform used to support essential market operations. Given the systemic importance of this infrastructure, independent control and long-term continuity planning were identified as essential requirements from the outset.

Challenge

The transformation programme reflected lessons learned from an earlier effort to modernise the same critical systems, shaped by regulatory and parliamentary scrutiny in Australia. This led to high expectations around governance, delivery confidence, and operational resilience.

The organisation faced several key challenges:

  • Supporting continuity planning for systems that operate at the heart of Australia’s financial markets.
  • Managing supplier dependency risk for mission critical software.
  • Aligning the requirements of multiple enterprise stakeholders, including a cautious end customer and a global technology supplier with established escrow processes.
  • Incorporating independent control aligned to major software releases.

At the same time, the technology supplier was operating under increasing regulatory scrutiny as a globally significant provider of critical financial market systems. Supporting a global customer base in highly regulated environments, the supplier recognised that customers would expect clear evidence of effective continuity controls and alignment with regulatory expectations.

Both parties required an approach that would support continuity objectives while allowing the programme to progress without introducing additional delivery risk.

Solution

The organisation partnered with Escode, the global leader in software escrow and verification services, to support the programme. The approach built on an established relationship between the technology supplier and Escode, with the supplier already familiar with the role of software escrow in supporting continuity and third‑party risk management for regulated customers.

A new Master Agreement was established to provide a structured framework for escrow and verification. This included the creation of two secure escrow deposit accounts holding source code and critical technical materials relevant to the platform.

As part of the agreement, Escode will deliver:

  • Standard Build Verifications aligned to major software releases were conducted on a once or twice annual basis. These verification support knowledge transfer by confirming that escrowed source code, build instructions, and technical materials were complete, current, and sufficient to successfully compile the application.
     
  • Scenario testing and Independent Build Verification where additional control is required, confirming the software can be rebuilt and run using escrowed materials.

The agreement adopted a hybrid structure, combining customer specific requirements with established supplier escrow processes. This approach supported independence and contractual clarity while remaining practical for a complex enterprise environment involving multiple stakeholders.

Escode worked with all parties to align expectations and manage supplier dependency risk, ensuring escrow and verification activities could be incorporated into the wider transformation programme. In parallel, a scalable commercial model was agreed to support future verification activity as the programme evolves.

Results

The agreement established a clear framework for escrow and verification to support continuity controls for a critical national infrastructure programme.

Through this engagement, the organisation has:

  • Put escrow arrangements in place for software materials supporting systems critical to Australia’s financial ecosystem.
  • Established a framework to support control and continuity planning in the event of supplier disruption.
  • Defined a scalable verification model aligned to major releases, with flexibility for additional assurance where required.

The approach also delivered clear benefits for the technology supplier. Software Escrow and independent verification enabled the supplier to demonstrate robust, tested continuity controls aligned with regulatory expectations, moving beyond contractual commitments to evidence‑based resilience. This enabled the supplier to give the client confidence that effective arrangements are in place to maintain and recover the system in the event of disruption.

By combining software escrow with independent verification, the organisation strengthened its approach to long-term third-party risk management for systems operating at the core of Australia’s financial markets.

“This engagement reflects how escrow and independent verification can be incorporated into complex transformation programmes to support third party risk management for financial market systems. Escode supports financial service organisations in Australia by providing structured escrow and verification frameworks that help manage supplier dependency for critical infrastructure.”

– Abigail Thornley, Sales Manager, Escode 

Learn how escrow and independent verification support third‑party risk management

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