APRA CPS 234 Compliance Guide

APRA Prudential Standard CPS 234 establishes information security requirements for APRA-regulated entities. Compliance requires comprehensive security programs addressing information asset protection, incident management, testing, and third-party management. This guide provides practical guidance for achieving and maintaining CPS 234 compliance.

CPS 234 Requirements Overview

CPS 234 requires entities to maintain information security capabilities commensurate with information asset size, business activities, and complexity. Key requirements include information asset identification and classification, security control implementation, incident management, testing, and third-party management.

Information Asset Management

Create and maintain comprehensive information asset register identifying all information assets, classification levels, and owners. Document asset criticality, protection requirements, and implemented controls. Review and update register regularly.

Identify all information assets
Classify by criticality and sensitivity
Assign asset owners
Document protection requirements
Maintain current asset register

Security Control Implementation

Implement security controls appropriate to asset criticality. Address access control, encryption, network security, endpoint protection, and monitoring. Align controls with recognized frameworks including ISO 27001, NIST, or CIS Controls.

Incident Response and Notification

Establish incident response capabilities with clear roles, procedures, and escalation paths. Implement 72-hour notification requirement for material information security incidents. Define incident severity classification and notification thresholds.

Document incident response procedures
Define severity classification
Establish notification processes
Train response team members
Conduct regular exercises

Testing and Assurance

Conduct regular security testing including penetration testing, vulnerability assessments, and control effectiveness reviews. Document testing scope, methodology, findings, and remediation. Maintain evidence for regulatory review.

Third-Party Risk Management

Assess and monitor third-party service providers' security capabilities. Implement vendor risk assessment processes, contractual security requirements, and ongoing monitoring. Address supply chain security risks.

Board Reporting and Governance

Provide board-level reporting on information security posture, incidents, and risk. Present information in business language focusing on risk, impact, and remediation rather than technical details. Maintain board minutes documenting security oversight.

Conclusion

CPS 234 compliance requires sustained effort and organizational commitment. Success factors include executive support, adequate resources, clear ownership, and integration with existing risk management processes. Treat compliance as ongoing program rather than one-time project, continuously improving security capabilities while maintaining regulatory requirements.