Let’s look at why the updates are so important.
In 20222, APRA recognised the need for a strengthening of the CPS 230 standard in response to the challenges experienced through the COVID-19 pandemic, the heightened cyber threat, and the increasing incidence of natural disasters.
These events demonstrated the critical importance of financial institutions being able to manage and respond to operational risks, with APRA3 explaining: “The new standard is designed to strengthen the management of operational risk, respond to business disruptions, and manage the risks from the use of service providers for all APRA-regulated entities.”
Speaking in July 2023, the APRA Chair, John Lonsdale, said the finalisation of CPS 230 will strengthen the management of operational risk across APRA’s regulated population, explaining:
“Disruptions to financial services can cause a major detrimental impact to the people who rely on them to pay bills, recover from financial loss or support themselves in retirement.”
“The need for APRA’s new standard has been demonstrated by a number of recent operational risk control failures and disruptions, including material cyber breaches. This new standard will ensure that regulated entities set and test controls and maintain robust business continuity plans to respond if disruptions do occur.”
“We expect regulated entities to be proactive in preparing for implementation, rather than waiting until the last minute to get ready to meet the new requirements. There will be a transition phase for existing contractual arrangements with material service providers for entities that need some flexibility,” Mr Lonsdale said.
Because of the complexities involved in managing these operational risk management scenarios, financial institutions are relying more on technology service providers to support internal operations.
These changes therefore extend to the services provided by regulated financial service providers to their clients.
APRA4 finalised the standard following industry consultation5 that commenced in July 2022. The new standard will commence from 1st July 2025.
How should you be approaching the APRA CPS 230 updates?
The first step in complying with APRA CPS 230 is to fully understand your current operations. Therefore running a risk assessment through the organisation is required to review existing business processes and identify weaknesses in existing controls.
Knowing your current processes is the foundation of risk analysis – until you have a big picture understanding of how work happens in your organisation, you can’t see areas of potential risk, vulnerability, and you won’t be able to identify areas that are in breach of APRA CPS 230 regulations.
This risk assessment will identify where improvements in the business continuity plan need to be made to ensure the organisation is able to respond to disruptions or breaches.