How source code escrow works within NIS2 / DORA
1. Supplier chain risk management
When critical software depends on an external supplier, its failure or loss of support can threaten operational continuity. Source code escrow and related materials provide a legally and procedurally treated plan B, supporting supply chain risk management.
2. Support for operational continuity
NIS2 emphasizes the ability to restore and maintain services after an incident or supplier outage. Access to source code and technical documentation enables deployment, administration and further development independently of the original vendor.
3. Auditable management and documentation
Escrow is connected to clearly defined processes and contractual mechanisms, from risk identification and regular updates to release scenarios. This provides measurable and verifiable documentation for internal and external audits.
4. Strengthening resilience in relation to DORA
Although DORA is focused on the financial sector, its requirements for digital operational resilience complement NIS2 and require robust approaches to cyber resilience and continuity. Source code escrow is compatible with these principles.
5. Demonstrating technical self-sufficiency
The provable ability to recover and manage information systems without dependence on one supplier is a strong signal of technical and procedural independence expected by regulators and internal governance frameworks.