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AU: CPS 234 Information Security

Regulator APRA
Jurisdiction AU
Status live
Applicability Platform

APRA Prudential Standard CPS 234 Information Security requires APRA-regulated entities to maintain information security capability commensurate with their information security vulnerabilities and threats. It mandates a board-approved information security (IS) policy framework, identification and classification of information assets, implementation and testing of controls proportionate to the risk of compromise, IS incident management with APRA notification within 72 hours of a material incident, and information security requirements in third-party arrangements.

The platform's security modules (MOD-044, MOD-045, MOD-046, MOD-075, MOD-076) together deliver the automated control layer. MOD-044 (SIEM) provides threat detection and alerting. MOD-045 manages secrets and key rotation. MOD-046 provides privileged access management with no standing production access. MOD-075 enforces API gateway controls. MOD-076 provides incident detection and ALERT escalation. The IS policy framework, APRA notification, and annual IS review are institutional.


Compliance register

This register maps every material obligation under the standard to the platform control or institutional process that satisfies it. It is the static traceability layer for the Totara compliance report — dynamic data (module build status, test evidence, control test dates) is overlaid at runtime.

Scope legend

Symbol Meaning
🤖 Automated Platform enforces or performs the obligation. Primary control mode is GATE, AUTO, CALC, or ALERT. Human action is not required in the normal case.
📊 Evidenced Platform captures the evidence trail automatically. Human compliance decision sits on top. Primary control mode is LOG.
🏛 Institutional Obligation is met by a process entirely outside the platform — training programmes, board governance, HR, legal. Platform may generate evidence inputs but does not own the process.
N/A Obligation does not apply to this deployment configuration.

Build legend

Symbol Meaning
Module built and deployed
🔨 Module planned — not yet built (build_status: Not started)
Uncontrolled gap — no module attributed

Part 2 — Information security policy framework

Ref Obligation Scope Policy Platform controls Build
Para 15 IS policy framework — board-approved; covers all information assets and risks; reviewed at least annually 🏛 Institutional DT-001 IS policy framework is a board-approved governance document. Platform controls operationalise the policies; the framework document is institutional.
Para 16 Information asset classification — all information assets identified and classified by sensitivity and criticality 🏛 Institutional DT-001 Asset classification is a CISO process. MOD-104 (GATE) enforces KMS encryption tiers by data classification at the infrastructure level; the classification register is institutional. 🔨
Para 17 Implementation and maintenance of IS controls proportionate to risk 🤖 Automated DT-001, DT-002 MOD-044 (GATE) — JWT RBAC enforces least-privilege across all API calls; MOD-045 (AUTO) — secrets vaulted, developer extraction prevented, key rotation automated; MOD-046 (GATE) — no standing production access; MOD-075 (GATE) — all service-to-service traffic TLS-terminated with mutual authentication 🔨
Para 18 IS capability assessment — information security capability assessed at least annually 🏛 Institutional DT-001 Annual capability assessment is a CISO-led process. MOD-076 provides the evidence base (security events, incident metrics, alert volumes). 🔨

Part 3 — Control testing

Ref Obligation Scope Policy Platform controls Build
Para 19 Vulnerability assessments and penetration testing on a risk basis 🏛 Institutional DT-002 Penetration testing and vulnerability assessment are institutional security operations. MOD-076 (ALERT) surfaces CVE-triggered alerts from SAST pipeline; testing schedule and execution are institutional. 🔨
Para 20 Material weaknesses — board notified of any material IS control weakness within 10 days of identification 🏛 Institutional DT-001, REP-009 Material weakness identification requires human assessment. MOD-076 (ALERT) surfaces control anomalies; MOD-058 (AUTO) routes material incidents to the notification workflow; board notification is institutional. 🔨

Part 4 — IS incident management

Ref Obligation Scope Policy Platform controls Build
Para 21 Incident detection and response — detect and respond to IS incidents in a timely manner 🤖 Automated DT-001, DT-002, OPS-003 MOD-044 (AUTO) — SIEM provides threat detection and alerting; security events correlated automatically; MOD-076 (ALERT) — platform-level anomalies and availability incidents surfaced in real-time; MOD-150 (AUTO) — security anomalies (CloudTrail access failures, Cognito brute-force patterns, Secrets Manager anomalies) auto-classified as potential breaches 🔨
Para 22 Material IS incident notification to APRA — notify within 72 hours of becoming aware of a material information security incident 🤖 Automated OPS-003, REP-009 MOD-058 (AUTO) — regulatory incident notification engine manages the IS incident register and routes notifications to APRA within required timeframes; notification timer starts automatically on incident creation 🔨
Para 23 Post-incident review — material IS incidents reviewed; lessons learned documented 📊 Evidenced OPS-003 MOD-150 (LOG) — all P1/P2 incidents have a mandatory post-implementation review; MOD-151 (GATE) — P1 incidents require documented root cause and resolution action before the case can be closed 🔨

Part 5 — Third-party IS arrangements

Ref Obligation Scope Policy Platform controls Build
Para 24 IS obligations flowed down to all service providers with access to information assets 🏛 Institutional DT-001, DT-008, OPS-005 Contract terms are institutional. MOD-150 (AUTO) monitors third-party health and SLA compliance continuously; contractual IS obligations are negotiated in procurement. 🔨
Para 25 ADI must assess the IS controls of its material service providers at least annually 🏛 Institutional DT-008, OPS-005 Annual vendor IS assessment is a procurement process. MOD-150 (AUTO) provides continuous runtime SLA and health monitoring between assessments. 🔨

Institutional obligations (not platform scope)

Obligation Owner Platform evidence input
Board approval and annual review of IS policy framework Board / CISO Platform controls operationalise the policies; framework is a governance document
Information asset identification and classification register CISO MOD-104 enforces encryption tiers configured from the classification register
Annual IS capability assessment CISO MOD-076 provides security event and incident evidence inputs
Vulnerability assessments and penetration testing CISO / Security Operations MOD-076 surfaces SAST-triggered CVE alerts; testing is institutional
Material weakness notification to board (within 10 days) CISO / Chief Compliance Officer MOD-076 and MOD-058 surface and route incidents; board notification is institutional
Material IS incident notification to APRA (within 72 hours) Chief Compliance Officer MOD-058 automates the notification workflow; ultimate accountability is institutional
Third-party IS obligations — contract negotiation and annual vendor review COO / Procurement MOD-150 monitors vendor SLA runtime; assessment is institutional

Coverage summary

Area Total obligations Platform automated 🤖 Platform evidenced 📊 Institutional 🏛 N/A
IS policy framework 4 1 0 3 0
Control testing 2 0 0 2 0
IS incident management 3 2 1 0 0
Third-party IS arrangements 2 0 0 2 0
Total 11 3 (27%) 1 (9%) 7 (64%) 0 (0%)

The platform automates threat detection, incident response, access control, and APRA notification. Policy governance, capability assessment, penetration testing, and vendor IS assessment are institutional. All attributed modules are currently build_status: Not started.


Policy Title
DT-001 Information Security Policy
DT-002 Cybersecurity Policy
DT-008 Third-Party & Outsourcing Risk Policy
DT-010 Environments and Deployment Standards
DT-011 AI Development Guardrails
OPS-003 Incident Management Policy
OPS-005 Third-Party & Critical Service Provider Policy
REP-005 Data Quality & Assurance Policy
REP-009 Regulatory Incident & Breach Notification

See D05 Data & Technology for the full risk domain.


Official documentation


Policies referencing this standard

  • DT-001 — Information Security Policy
  • DT-002 — Cybersecurity Policy
  • DT-010 — Environments and deployment standards
  • DT-011 — AI development guardrails
  • OPS-003 — Incident Management Policy
  • REP-005 — Data Quality & Assurance Policy
  • REP-009 — Regulatory incident & breach notification

Compiled 2026-05-22 from source/entities/regulations/au-cps-234.yaml