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APRA CPS 234 and CPS 230 · Information security and operational risk for Australian financial services

APRA CPS 234 and CPS 230 compliance, met with evidence your Board can stand behind.

CPS 234 makes the Board of every APRA-regulated bank, insurer and superannuation trustee answerable for information security, and CPS 230 extends that duty to operational risk, business continuity and service providers. Sterling's expert and experienced consultants turn both into controls, plans and testing your people own. We help our clients put it into practice and prove it.

  • Fixed scope, one proposal: consulting, Effivity software, Sterling Academy access and internal auditor training, as applicable to your standard, in one proposal
  • A team of expert and experienced information security consultants, with security programme consulting across sectors and countries since 2003
  • The Sterling Promise: 100% on-time completion, 100% success, 8,100+ client engagements. No certificate exists for CPS 234 or CPS 230; APRA supervises compliance and Sterling does not certify or attest

8,100+ client engagements in 60+ countries.

APRA CPS 234 client experience
  • Allianz
  • Emirates Flight Catering
  • Etihad Rail
  • Haier
  • Whirlpool
  • Emerson
  • Olam
  • Piramal Pharma Solutions

What it is

What are APRA CPS 234 and CPS 230, and what are they used for?

CPS 234 Information Security is a prudential standard issued by the Australian Prudential Regulation Authority. It sets what an APRA-regulated entity must do to stay resilient against information security incidents, including for information assets that related parties and third parties manage.

CPS 230 Operational Risk Management sits beside it. It requires the entity to manage operational risk, keep critical operations within tolerance through disruption and manage the risks of using service providers. It also expects the entity to meet CPS 234, so the two work best as one programme.

Neither is a certifiable management system: both set obligations that APRA supervises. Practice guide CPG 234 gives APRA's view of sound security practice but creates no enforceable requirements.

Current editions. CPS 234 has applied since 1 July 2019; for information assets managed by third parties, from the next contract renewal or 1 July 2020, whichever came first. CPS 230 has applied since 1 July 2025; for service provider contracts already in place, from the next renewal or 1 July 2026, whichever came first. A revised CPS 230 with targeted amendments took effect on 1 July 2026. Confirm the current position with APRA before you plan.

Who it is for

Who needs APRA CPS 234 and CPS 230 compliance?

CPS 234 applies to every APRA-regulated entity: authorised deposit-taking institutions, including foreign ADIs, general insurers, life companies and friendly societies, private health insurers and RSE licensees. For a foreign entity, it covers the Australian branch operations. CPS 230 covers ADIs, general insurers, life companies, private health insurers and RSE licensees. Projects usually begin in one of four ways:

  • A regulated customer passes the obligation down. Suppliers are asked to show their security capability and accept service provider terms, because the regulated entity must assess them.
  • A tender or outsourcing contract names CPS 234 or CPS 230. Security schedules, notice periods and service provider clauses follow the standards.
  • APRA or the Board asks for assurance. A supervisory review, incident or audit finding exposes gaps.
  • A group structure spreads the duty. The head of a group must see that the requirements apply appropriately across it.

Requirements

What are the main APRA CPS 234 and CPS 230 requirements?

CPS 234 groups its obligations under nine headings and CPS 230 under four. This summary stays at heading level; your programme is tested against the standards themselves.

  • Roles and responsibilities: the Board is ultimately responsible for information security, with defined roles for senior management and everyone with a security function.
  • Information security capability: in line with the size and extent of threats, including assessment of related parties and third parties that manage your information assets.
  • Policy framework: sized to your exposure to vulnerabilities and threats.
  • Information asset identification and classification: by criticality and sensitivity, supplier-managed assets included.
  • Implementation of controls: proportionate across each asset's life, with third-party control design evaluated.
  • Incident management: timely detection and response, with response plans reviewed and tested every year.
  • Testing control effectiveness: systematic testing by skilled, functionally independent specialists, reviewed at least annually.
  • Internal audit: design and operating effectiveness of security controls, including those third parties maintain.
  • APRA notification: no later than 72 hours after becoming aware of a notifiable incident, and no later than 10 business days for a material control weakness not remediated in a timely manner.
  • CPS 230 operational risk management: operational risks identified, assessed, controlled and monitored, with operational incidents managed.
  • CPS 230 business continuity: critical operations identified, tolerance levels set, and a continuity plan kept, tested and reviewed.
  • CPS 230 management of service provider arrangements: a service provider policy, formal agreements, and identification and monitoring of material service providers.
  • CPS 230 roles and responsibilities: Board oversight and senior management accountability for operational risk.

What does useful CPS 234 and CPS 230 evidence look like?

Board papers showing decisions; an asset register with classifications, supplier-held assets included; critical operations with tolerance levels; continuity and response plan test records; a service provider register with assessments; independent test results with remediation; internal audit reports; and a notification procedure naming who decides materiality.

Compliance process

How do you achieve APRA CPS 234 and CPS 230 compliance?

There is no certificate at the end. You demonstrate compliance to your Board and to APRA, so the route builds evidence that holds up to supervision, internal audit and independent testing.

  1. 01
    Confirm the entity, group, operations and asset scope.Identify which regulated entities and group members are covered, the critical operations and information assets in play, and the service providers, related parties and third parties behind them.
  2. 02
    Gap analysis: compare current practice with each CPS 234 and CPS 230 heading.We review governance, policies, asset classification, controls, operational risk, business continuity, service provider agreements, incident plans, testing and internal audit coverage, then agree actions, owners and dates.
  3. 03
    Close the gaps in controls, continuity and service provider oversight.Classify assets, strengthen controls in proportion, set tolerance levels for critical operations, assess supplier capability and bring service provider agreements up to the standard.
  4. 04
    Test, rehearse and audit.Independent specialists test control effectiveness, response and business continuity plans are exercised, internal audit reviews design and operating effectiveness, and results reach the Board.
  5. 05
    Operate the programme and report to APRA when required.Keep testing and reviews on schedule, and notify APRA whenever a threshold is met.

Check the route before you sign. CPS 234 and CPS 230 are enforced by APRA, and no certification body, consultant or software vendor can declare an entity compliant. Ask what evidence the work produces and who tests it independently. The certification buyer's checklist

Cost

How much does APRA CPS 234 compliance cost?

With no certification fee, the budget sits in the programme work, the independent testing and your own people's time.

Cost componentWhat affects it
Consulting and programme workCurrent maturity, the number of entities in the group, and whether you choose Design™ or Drive™
Independent testingThe number and criticality of assets, how fast threats change for them, and the testing techniques chosen
Third-party oversightHow many suppliers and related parties manage your information assets, and the assurance each one already provides
RemediationControl gaps and tooling identified in the gap analysis, never assumed in advance
Software and learningEffivity and Sterling Academy access, itemised at no additional cost

What moves the price

  • Existing ISO/IEC 27001 or similar controls that can be reused
  • Outsourced and cloud services holding critical assets
  • Depth of internal audit coverage already in place

What a Sterling proposal always shows

  • Deliverables, assumptions and exclusions in writing
  • Milestones linked to deliverables
  • One all-inclusive proposal for our work

Timeline

How long does APRA CPS 234 compliance take?

Supplier work usually sets the pace, because assessments need each party's cooperation, and response plans need a real test. As an estimate, most programmes reach a defensible position in four to nine months.

PhaseWhat sets the pace
Scope and gap analysisAccess to asset owners, supplier lists and past audit findings
Controls and policy buildThe size of the remediation list and the availability of IT and business owners
Third-party assessmentSupplier responsiveness and contract renewal dates
Testing and internal auditTester availability, the plan rehearsal and time to close findings before the Board reports

Your engagement

What your APRA CPS 234 engagement includes

Sterling OS™ runs every engagement, with each phase adapted to a prudential obligation rather than a certificate. Sterling does not certify or attest: APRA supervises compliance, and your Board remains accountable for it.

  • Design™: guided support

    Your team builds the programme; a Sterling consultant sets the method, reviews every policy, register and plan, and coaches the owners.

  • Drive™: managed support

    The alternative to Design™ when capacity is short: Sterling drafts the framework, registers and supplier assessments with your owners and runs the programme to Board sign-off.

  • Sustain™: after the programme

    Annual plan tests, supplier reassessments and readiness for internal audit and supervisory reviews.

  • Automate™: Effivity

    Your security programme runs in Effivity, included with the engagement at no additional cost.

  • Training for your people

    Internal auditor training, as applicable to your standard, and preferential Sterling Academy access, including complimentary awareness training for your people as part of the engagement.

Compliance decisions and any supervisory action remain with APRA.

How Sterling implements ISO and GRC standards

Effivity · information security software, included in every engagement

How Effivity helps you fulfil, automate and simplify the requirements of APRA CPS 234.

Effivity is the ISO and GRC automation platform built by the Sterling group and used in 50+ countries. For a CPS 234 client, your consultant configures the security workspace within the agreed scope: policies, the information asset register, risks, supplier assessments, incidents, test results, internal audits, corrective actions and Board reporting in one place. Notifications still go to APRA through its own channel; Effivity keeps the record of who decided and when. Sterling consulting clients get their Effivity subscription included with the engagement, at no additional cost.

Effivity: Context of the Organisation dashboard with issues, interested parties and scope
Effivity · Context of the Organisation dashboard
Roles and responsibilities

Accountability the Board can see

Security roles and Board decisions recorded with dates.

Information security capability

Capability and supplier assessments

Your own capability and each supplier's, assessed on schedule.

Policy framework

Controlled policies

Policies under version control, with approvals and review dates.

Information asset identification and classification

One asset register

Assets classified by criticality and sensitivity, with owners, including those that suppliers manage.

Implementation of controls

Risks and treatments

Risks linked to the controls chosen for each asset.

Incident management

Incidents and plan tests

Incidents from detection to post-incident review, and each annual plan test.

Testing control effectiveness

Test results and remediation

Independent test findings assigned and tracked to closure.

Internal audit

Audit programme and corrective action

Audits covering supplier-held controls, with closure checked.

What this means at the review

When internal audit or APRA asks who judged a control weakness material and when the Board heard, the answer is already linked and dated in Effivity.

In your engagement

  • Subscription included with the engagement, at no additional cost
  • Configured by your Sterling consultant within the agreed scope
  • Your documents, records and registers migrated, not retyped
  • Admin and user training for your team
  • Modules for QMS, EMS, OHSMS, FSMS and more when you integrate other standards

Sterling Academy · information security e-learning

Give every employee a clear part in keeping information secure.

Sterling Academy provides video lessons with practice checkpoints, a final exam and a numbered Certificate of Completion that can be verified online. Sterling consulting clients benefit from preferential Sterling Academy course access and special pricing through their Sterling consultant, including complimentary awareness training for their people as part of the engagement.

  • Security awareness for staff, so incidents are recognised and reported quickly
  • Internal auditor training, as applicable to your standard, as part of the engagement
  • Completion reports by team, ready for internal audit
  • New joiners trained as they start, so records stay current

Why Sterling

Want successful APRA CPS 234 compliance? Come to Sterling.

Regulated entities rarely hold all their information assets in-house. Sterling builds one security programme that covers your own controls and the suppliers behind them, with an engagement team accountable for the whole.

60+ countries since 2003

Security, privacy and resilience programmes for financial services, technology and outsourcing firms, with offices in 21 countries.

All-inclusive proposal

Consulting, Effivity, training and Academy access in one proposal; independent testing and remediation shown separately.

One set of controls, several obligations

Existing ISO/IEC 27001 or SOC 2 controls are mapped, not rebuilt.

Expert and experienced consultants

Security specialists who understand regulated finance and speak the language of Boards and supervisors.

Sterling vs the rest: the full comparisonExplore APRA CPS 234 client experience

The Sterling Promise

What our APRA CPS 234 compliance success guarantee means

100%on-time completion · success · 8,100+ client engagements

We stay with you until your agreed APRA CPS 234 compliance outcome is achieved, through the gap analysis, remediation, testing and the closure of internal audit findings.

The engagement identifies the standard, scope, outcome and responsibilities. Your organisation supplies accurate information and puts the agreed controls into use. APRA supervises compliance and your Board remains accountable for it. Our commitment concerns the agreed compliance support, not a promise that no incident will ever occur or of any supervisory outcome.

FAQs

Frequently asked questions about APRA CPS 234 and CPS 230

Do CPS 234 and CPS 230 apply to service providers that are not regulated by APRA?

Not directly, but both reach them through their regulated customers. Under CPS 234, a bank, insurer or super fund must assess the security capability of any third party that manages its information assets and evaluate that party's controls. Under CPS 230, material service providers can expect formal agreements and ongoing monitoring by their regulated customers.

Is ISO/IEC 27001 certification enough to comply with CPS 234?

No, although it is a strong starting point. CPS 234 adds Board accountability, notification to APRA, testing by functionally independent specialists and internal audit of third-party controls; a mapping exercise shows what is left.

How does CPS 234 relate to CPS 230 Operational Risk Management?

They work as a pair. CPS 230 covers operational risk as a whole, including business continuity and service providers, and requires the entity to meet CPS 234 for information security. APRA states that where an incident is notifiable under both standards, a single notification is sufficient, and the earliest timeframe applies. One risk register, one supplier register and one incident process can serve both.

What counts as a notifiable information security incident?

One that materially affected, or could have materially affected, the entity or the interests of its depositors, policyholders, beneficiaries or other customers, financially or otherwise, or one that has been notified to another regulator in Australia or overseas. Agree materiality criteria and the decision-maker in advance.

Does Sterling carry out the independent testing?

The standard requires testing by appropriately skilled and functionally independent specialists. Sterling plans the testing programme and helps you act on the results; who performs each test, and how independence is shown, is agreed in the proposal.

Keep exploring

More on APRA CPS 234 and CPS 230 and related standards

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