Australia’s financial sector is facing a defining moment. The Medibank credential leak and Optus data breach weren’t just headlines – they were wake-up calls, exposing how vulnerable even the largest organisations can be. These incidents revealed more than technical vulnerabilities; they underscored the urgent need for operational resilience that anticipates and mitigates risks far beyond regulatory checklists.
In our recent Q&A webinar, our powerhouse panel—featuring former Australian Prudential Regulation Authority (APRA) CSO Mikhail Lopushanski, Lumen’s John Hines and Henry Hon, and Secure Forte Managing Director Mani Amini – distilled actionable insights for navigating CPS 230. Here’s what you need to know:
What CPS 230 is Really Asking of You
APRA’s CPS 230 isn’t just another regulatory update. It’s a framework designed to embed operational risk management into the DNA of every financial institution—and every partner in their ecosystem. The standard challenges organisations to ask: Are we truly ready for disruption, or just hoping to avoid it?
Here’s what sets CPS 230 apart:
• Critical Operations Mapping: Move beyond generic risk registers. CPS 230 demands a forensic understanding of your most essential business functions –those whose disruption could ripple across the financial system. Under APRA’s Day One Checklist, entities must finalise critical operation registers and tolerance levels by mid-2024.
• Service Level Tolerances: Vague assurances are no longer enough. Organisations must now set, measure, and defend clear thresholds for acceptable disruption (e.g., <4 hours for payment systems).
• Board Accountability: Operational resilience is a boardroom imperative. Leadership must actively oversee resilience strategies and review quarterly dashboards.
• Business Continuity Planning: Static plans are out. CPS 230 requires dynamic, scenario-tested continuity strategies – like simulating multi-day cloud outages or cyberattacks.
• Third-Party and Ecosystem Resilience: Your risk perimeter now extends to fourth- and fifth-party vendors. CPS 230 mandates rigorous oversight, including APRA audit rights in contracts and annual Material Service Provider Register submissions starting October 2025.
The Real-World Roadblocks
Transitioning from compliance to true operational resilience is challenging Australian financial firms. Here’s what the panel highlighted:
• Legacy GRC Fatigue: Many institutions struggle with outdated Governance, Risk, and Compliance frameworks that lack the granular, real-time visibility CPS 230 demands.
• Talent Shortages: Expertise in operational risk, cybersecurity, and third-party monitoring remains scarce.
• Supply Chain Blind Spots: Gaining visibility into fourth-party risks (e.g., cloud providers’ data centres) is a persistent hurdle.
• Boardroom Buy-In: Regulators now demand documented evidence of board engagement—not just awareness. APRA’s three-year supervision plan will prioritise entities lagging in critical operation mapping.
Your Partner for APRA CPS 230 Operational Resilience
At Lumen, we believe resilience is more than a requirement – it’s a competitive advantage. Leveraging our unified infrastructure, connectivity and security solutions, our approach is proactive and holistic:
• Resilient Infrastructure: Secure, scalable networks designed to keep critical operations running, even during severe disruptions.
• Advanced Security: Threat detection, incident response, and recovery aligned with CPS 230’s “severe yet plausible” scenarios.
• Visibility & Control: Tools to manage risk across your ecosystem, including third-party compliance dashboards.
• Financial Sector Expertise: Proven experience supporting Australian institutions through APRA’s evolving standards.
Suppliers: The Spotlight’s On You, Too
If you’re a supplier to an APRA-regulated entity, CPS 230 matters to you. Expect:
• Stricter Due Diligence: Financial institutions are mandated to assess your financial stability and compliance certifications (e.g., ISO 27001).
• Tighter Contracts: APRA audit rights, 72-hour breach notifications, and uptime SLAs (e.g., 99.99%) are now non-negotiable.
• Ongoing Scrutiny: Real-time monitoring via API-based tools is becoming the norm.
CPS 230 Isn’t a Box to Check—It’s a Catalyst
The standard is a call to build future-proof organisations – ones that withstand shocks, protect customers, and inspire trust in an uncertain world.
Ready to move from compliance to confidence?
Watch the 1-hour webinar for the panel’s full insights, including actionable strategies for APRA’s 2025 compliance deadline.
