Early insights on what CPS 230 might mean in practice

What does APRA CPS 230 really ask of organisations? It’s more than compliance. It’s about building resilience, clarity, and operational agility.

Financial services organisations across Australia are preparing for APRA’s new standard, CPS 230. At a glance, it appears to be about compliance: updated expectations for operational risk management, business continuity, and third-party arrangements.

But a closer look reveals something more significant.

CPS 230 signals a shift. It moves away from treating risk as a back-office function and toward embedding resilience into how an organisation operates, adapts, and recovers.

And that’s not a checkbox exercise.

It’s a capability.

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What CPS 230 Is Really Asking For

The intent behind CPS 230 goes well beyond documentation. It asks:

• Do you understand your critical operations?
• Can you respond and recover quickly when things go wrong?
• Are accountabilities for risk, continuity, and third-party dependencies embedded into the way you work?

This is where many organisations feel the gap.

Policies might exist. Plans might be in place.

But when disruption hits, they’re often navigating in the dark, with unclear ownership, outdated information, and siloed responses.

The real test isn’t whether you can point to a document.

It’s whether your people know what to do, who decides, and how to recover quickly.

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From Compliance to Capability

CPS 230 creates an opportunity to rethink how risk is managed and resilience is built.

It invites leaders to:

• Reconnect risk and operations by mapping where risks intersect with day-to-day activities
• Make accountability visible by clarifying who owns what, beyond policy titles
• Enable adaptive response by empowering teams to act within defined guardrails rather than wait for permission
• Learn and improve continuously by treating every incident as data, not just disruption

This is how organisations build agility and resilience. Not as projects, but as part of their operating rhythm.

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A Lens Through Incident Management

Take a typical cyber incident, such as a system outage, data breach, or supplier failure.

The response involves more than IT.

It draws in operations, legal, communications, compliance, risk, and sometimes the board.

The quality of that response often comes down to:

• Whether responsibilities were mapped and understood
• Whether escalation paths were defined and trusted
• Whether the process could flex without chaos

CPS 230 doesn’t prescribe how to do this.

But it makes the outcome non-negotiable.

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What Needs to Be Done Now

Organisations don’t need to start from scratch.

Most already have the ingredients: risk registers, continuity plans, vendor contracts, and policy frameworks.

The work now is to:

• Connect these elements into an integrated view of operations
• Embed them into governance, not just compliance reporting
• Enable people across the business to understand, act, and improve

The organisations that succeed under CPS 230 won’t just comply.

They’ll gain clarity.

They’ll operate with more consistency and confidence.

And they’ll recover faster, with less noise, when the next disruption hits.

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This post is an early reflection on how CPS 230 could reshape how organisations think about operational resilience and accountability. I’d be curious to hear how others are approaching it, or where you’re seeing friction.