Australiastandard

APRA CPS 234 Information Security

CPS 234 places direct accountability on the Board for information security—APRA can revoke licences, impose conditions, and publicly name non-compliant entities.

Mapped to Microsoft controls
Effective Date1 July 2019
Enforcement BodyAustralian Prudential Regulation Authority (APRA)
Penalty FrameworkAPRA can impose conditions on an entity's licence, issue directions requiring specific remedial actions, appoint external auditors, and ultimately revoke licences. Material breaches must be notified to APRA within 72 hours (security incidents) or 10 business days (control weaknesses). APRA has publicly named entities with poor information security practices, creating significant reputational consequences.

APRA Prudential Standard CPS 234 Information Security mandates that all APRA-regulated financial institutions maintain information security commensurate with the size and extent of threats to their information assets. The standard places direct accountability on the Board of Directors for information security.

CPS 234 requires entities to clearly define information security roles and responsibilities, maintain security capability, implement controls to protect information assets, manage incidents, and test control effectiveness. Material incidents must be notified to APRA within 72 hours, and control weaknesses within 10 business days.

For Microsoft 365 environments, CPS 234 compliance requires Defender XDR for security capability and incident management, Conditional Access for access controls, Intune for endpoint security, and comprehensive audit logging for control effectiveness testing. StremarControl engineers and operates the Microsoft-native controls required for CPS 234 mandates, translating obligations into enforceable Microsoft-native controls, structured evidence, and ongoing assurance discipline for APRA compliance reporting.

Why This Matters Now

APRA CPS 234 is the mandatory information security standard for all APRA-regulated entities including banks, insurers, and superannuation funds in Australia. It requires board-level accountability for information security, security capability commensurate with threats, and notification to APRA of material incidents within 72 hours. For M365 environments, compliance requires Defender XDR for security capability, Conditional Access for access management, and Intune for endpoint security. CPS 234 compliance is non-negotiable for Australia's financial services sector.

Scope & Applicability

Applies to all APRA-regulated entities: authorised deposit-taking institutions (banks, building societies, credit unions), general and life insurers, private health insurers, and registrable superannuation entity licensees. Extends to material service providers and third parties handling information assets. M365 tenants used by APRA-regulated entities must demonstrate CPS 234 compliance.

Core Obligations

01
Paragraph 15

Board Accountability

The Board must ensure the entity maintains information security commensurate with the size and extent of threats to its information assets.

02
Paragraphs 21–23

Information Security Capability

Maintain information security capability commensurate with the size and extent of threats. Actively manage security capability through recruitment, training, and tooling.

03
Paragraphs 28–31

Incident Management

Establish mechanisms to detect, respond to, and recover from information security incidents. Notify APRA of material incidents within 72 hours.

04
Paragraphs 32–35

Testing Control Effectiveness

Systematically test the effectiveness of information security controls through an assurance programme. Test frequency commensurate with risk.

05
Paragraphs 24–27

Third-Party Management

Evaluate the information security capability of third parties managing information assets. Ensure adequate controls across the supply chain.

Microsoft 365 Control Mapping

How each obligation maps to enforceable Microsoft 365 controls and the evidence they produce.

Obligation

Information Security Capability

M365 Control

Defender XDR for advanced threat protection. Conditional Access with MFA and device compliance. Intune security baselines for endpoint hardening.

Evidence

Defender threat analytics, Conditional Access evaluation logs, Intune compliance reports.

Obligation

Incident Management (72-Hour Notification)

M365 Control

Defender XDR incident detection with Sentinel playbooks for APRA notification workflows. Automated incident classification and timeline reconstruction.

Evidence

Incident timeline reports, APRA notification records, playbook execution logs.

Obligation

Testing Control Effectiveness

M365 Control

Microsoft Secure Score for continuous control assessment. Sentinel compliance workbooks for control testing dashboards. Defender vulnerability management.

Evidence

Secure Score trend reports, compliance workbook exports, vulnerability assessment results.

Implementation Timeline

November 2018
CPS 234 finalised by APRA
July 2019
CPS 234 comes into force
2020
APRA begins compliance assessments and targeted reviews
2023
APRA publishes findings from CPS 234 thematic review
Ongoing
APRA annual compliance monitoring and targeted reviews

Related Frameworks

Ready to get APRA CPS 234-ready?

Start with a fixed-scope sprint. We assess your Microsoft 365 controls against APRA CPS 234 requirements, close gaps, and produce audit-ready evidence.