CPS 234 COMPLIANCE

CPS 234 Compliance for APRA-Regulated Entities

Gap assessments and compliance programs for APRA-regulated entities and material service providers. Practitioner-led, not just consultant-advised. We own the outcome from gap assessment through to APRA attestation - and stay accountable until your compliance gaps are closed.

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24⁺

Years combined cyber and compliance experience

APRA

Regulatory expertise across CPS 234 and CPS 230

Board-ready

Reporting and attestation support included

CPS 234 is the APRA prudential standard that sets minimum information security requirements for all regulated entities, effective from July 2019. It holds boards directly accountable for information security capability, mandates systematic control testing and self-assessments, sets 24-hour notification requirements for material incidents, and extends obligations to material service providers that manage information assets on behalf of regulated entities. Non-compliance exposes organisations to APRA enforcement action and significant reputational risk with institutional counterparties.

Why It Matters

Why CPS 234 Compliance Is a Board-Level Priority

CPS 234 shifts information security accountability from the IT team to the board. These are the compliance challenges that routinely surface in APRA-regulated entities - and why most need external support to address them.

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Board accountability requires structured evidence - not just good intentions

CPS 234 places information security accountability at board level. Boards need a regular reporting cadence, gap tracking against the standard, and documented evidence of control effectiveness - most organisations lack the internal capability to produce this to APRA's standard.

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Third-party and MSP obligations are poorly understood

Regulated entities must manage the information security risk posed by material service providers - but most have no systematic way to assess MSP compliance, enforce contractual security requirements, or demonstrate to APRA that they have done so.

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The 24-hour incident notification clock is unforgiving

CPS 234 requires notification of material information security incidents to APRA within 24 hours. Most organisations lack tested incident response procedures that can identify a material incident, escalate to the board, and notify APRA within that window.

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Integrating CPS 234 with ISO 27001 and Essential Eight without duplication

Organisations already pursuing ISO 27001 certification or Essential Eight maturity often run parallel compliance programs rather than a unified control framework. Without proper integration, the cost and effort of CPS 234 compliance multiplies unnecessarily.

What We Deliver

What Does a CPS 234 Engagement Include?

A structured, practitioner-led engagement from gap identification to board-ready attestation. Scoped to your regulatory obligations, integrated with your existing frameworks, and tracked to verified closure.

Phase 1

CPS 234 Gap Assessment

Structured review of your current information security posture against every clause of CPS 234. Output is a prioritised gap register mapped to specific APRA requirements, with a board-ready summary and a technical control testing workbook.

Phase 2

Control Testing and Evidence

Hands-on testing of controls identified in the gap assessment. We assess policy adequacy, technical control effectiveness, and process maturity - producing evidence that supports both APRA self-assessment and board attestation.

Phase 3

Remediation Roadmap

Prioritised remediation plan that sequences improvements by risk and regulatory impact. We separate critical gaps from longer-term program enhancements, provide implementation guidance, and define measurable milestones for board tracking.

Phase 4

Board Reporting and Attestation

Board-ready information security status reports and attestation support for APRA reporting obligations. Written for risk committees and boards - not just IT and security teams - with clear status, progress, and residual risk language.

MSP Support

Material Service Provider Alignment

For MSPs to APRA entities: documentation, control evidence, and attestation packs that satisfy regulated entity due diligence requirements. We help MSPs demonstrate security capability that protects their position in regulated supply chains.

Ongoing

Retained CPS 234 Advisory

Ongoing advisory to maintain compliance through regulatory changes, new MSP relationships, and material incident preparedness. Fractional CISO-level support aligned to your APRA reporting cycle and board calendar.

How We Work

How Does the CPS 234 Engagement Process Work?

A defined, milestone-driven engagement - not an open-ended advisory retainer. We scope the gap assessment, own the remediation roadmap, and produce board-ready artefacts at every stage.

Scoping and kick-off - Review of your regulatory obligations, existing frameworks (ISO 27001, Essential Eight, CPS 230), and current security documentation. Agreed scope, timeline, and deliverable dates before any work begins.
Gap assessment - Clause-by-clause review of your information security posture against CPS 234. Interviews with key stakeholders, review of policies and evidence, and control testing where applicable. Typically 4 to 6 weeks for a mid-sized regulated entity.
Gap report and remediation roadmap
- Board-ready summary of findings and compliance status
- Clause-level gap register with severity ratings
- Technical control testing workbook with evidence references
- Prioritised remediation roadmap with milestones and owners
Remediation support - Hands-on support to close identified gaps, including policy uplift, control implementation, and evidence collection. We own the gap list and stay accountable until your compliance position is defensible to APRA.
Board reporting and attestation - Regular board-ready reporting, attestation support for APRA obligations, and documentation of your information security program for audit and review purposes.

Why Logic Weave

Practitioner-led, not consultant-advised. CISM, CRISC, ISO 27001 Lead Auditor certified. Deep experience with APRA-regulated entities, MSPs to regulated entities, and organisations integrating CPS 234 with ISO 27001 and Essential Eight. We own the outcome - not just the report.

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Why Logic Weave

Why Choose Logic Weave for CPS 234?

Practitioner-led advisory with deep regulatory experience. We don't just identify gaps - we own remediation and produce evidence that stands up to APRA scrutiny.

Practitioner-Led, Not Consultant-Advised

Our team holds CISM, CRISC, and ISO 27001 Lead Auditor certifications with hands-on experience implementing and testing the controls CPS 234 requires. We work alongside your team - not above it.

Ownership of Outcomes

We own the gap register and stay accountable until your compliance position is defensible to APRA. The engagement doesn't close when the report is delivered - it closes when identified gaps are tracked to verified remediation.

APRA Regulatory Experience

Direct experience with APRA-regulated entities across banking, insurance, and superannuation. We understand APRA's supervisory expectations, the self-assessment process, and what "reasonable steps" looks like in practice.

Integration with ISO 27001 and Essential Eight

We map CPS 234 requirements to your existing ISO 27001 controls and Essential Eight maturity levels to avoid duplication. A unified control framework means your compliance investment goes further - not further apart.

Board-Level Reporting

Every engagement includes board-ready reporting - written for risk committees and boards, not just IT teams. Our attestation support helps boards discharge their CPS 234 accountability with confidence and clear audit trails.

CPS 230 Integration

For organisations addressing CPS 230 alongside CPS 234, we integrate both standards into a single operational resilience framework. One assessment cycle, shared evidence, and aligned board reporting - not two parallel programs.

Who This Is For

Who Needs CPS 234 Compliance?

CPS 234 obligations extend beyond the regulated entity itself. Here is who Logic Weave typically works with on CPS 234 engagements.

APRA-Regulated Entities

Banks, credit unions, insurance companies, and superannuation fund trustees with direct CPS 234 obligations. Typically seeking gap assessments, board reporting, and attestation support - particularly ahead of APRA reviews or following a material incident.

Material Service Providers

Technology, data, and outsourcing providers to APRA-regulated entities that are expected to demonstrate security capability aligned to their clients' CPS 234 requirements. MSPs need documentation, control evidence, and attestation packs that protect their position in regulated supply chains.

Boards and Risk Committees

Board members and risk committees of regulated entities who need to understand and discharge their CPS 234 accountability. Logic Weave provides clear, board-ready reporting - not technical jargon - so boards can make informed decisions and attest with confidence.

Common Questions

CPS 234 Compliance - Frequently Asked Questions

What is APRA CPS 234?

CPS 234 is an APRA prudential standard that sets minimum information security requirements for regulated entities, effective from July 2019. It requires boards to be accountable for information security capability, mandates regular control testing and self-assessments, and sets out obligations for managing third-party security risks. The standard applies to all APRA-regulated entities including banks, insurers, and superannuation fund trustees.

Who needs to comply with CPS 234?

All APRA-regulated entities are subject to CPS 234, including authorised deposit-taking institutions (banks and credit unions), general and life insurers, and superannuation fund trustees. Material service providers that manage information assets on behalf of regulated entities also carry obligations and are expected to demonstrate security controls aligned to their clients' CPS 234 requirements.

How does CPS 234 relate to CPS 230?

CPS 234 covers information security specifically, while CPS 230 (effective July 2025) addresses broader operational risk management including business continuity and service provider management. The two standards are complementary - strong CPS 234 controls form a core component of a CPS 230 operational resilience framework. Organisations addressing both simultaneously can share assessments, control libraries, and board reporting artefacts.

What is a CPS 234 gap assessment?

A CPS 234 gap assessment evaluates your current information security posture against each clause of the standard, identifying where controls, policies, or practices fall short of APRA's expectations. The output is a prioritised remediation roadmap mapped to specific CPS 234 clauses, with a board-ready summary and a technical control testing workbook included as standard deliverables.

How long does CPS 234 compliance take?

A gap assessment typically takes 4 to 6 weeks depending on the size and complexity of your environment. Implementing a full remediation program can take 3 to 9 months based on the number and severity of gaps identified. Logic Weave works to a defined roadmap with clear milestones so you can demonstrate progress to APRA and your board throughout the engagement.

Do material service providers need CPS 234 alignment?

Yes. APRA-regulated entities must manage the information security risks posed by their MSPs, and MSPs are expected to demonstrate adequate controls and provide security assurance to their regulated clients. Logic Weave helps MSPs build the documentation, control evidence, and attestation packs that satisfy regulated entity due diligence requirements and protect their position in financial services supply chains.