APRA CPS 234: Implementation Lessons from Early Adopters
APRA CPS 234 has fundamentally changed information security practices across Australian financial institutions. Early adopters' experiences offer valuable lessons for organizations still working toward full compliance.
Information Asset Register Challenges
Every interviewed organization struggled with information asset identification and classification. The seemingly simple requirement of cataloging information assets proved complex in practice, requiring cross-functional collaboration and senior executive engagement.
- Average 8-12 months to complete initial register
- Required involvement from business units, IT, and security
- Data discovery tools helped but required significant configuration
- Ongoing maintenance remains challenging
Third-Party Risk Management
Assessing and monitoring third-party service providers' security postures requires substantial resources. Organizations found that standardized questionnaires helped but weren't sufficient for critical vendors requiring detailed technical assessment.
Board Reporting and Governance
Translating technical security information into board-level reporting challenged many organizations. Successful approaches focused on risk language, business impact, and clear remediation timelines rather than technical details.
Incident Response Requirements
CPS 234's incident notification requirements necessitated clear severity classification frameworks and escalation procedures. Organizations learned to err on the side of over-reporting initially, refining classification over time.
Conclusion
CPS 234 compliance is achievable but requires sustained effort, adequate resources, and genuine commitment from senior leadership. Organizations that approached compliance as a security improvement opportunity rather than a checkbox exercise reported the best outcomes and most sustainable programs.
Want to Discuss This Topic?
Our security experts are available to discuss how these insights apply to your specific environment.