Regulations & Standards5 key Insights and Priorities for CPS 230 Compliance

Baking CPS 230 compliance


The recent Forefront CPS 230 Summit in NSW gathered financial services leaders specialising in risk and resilience. With discussions centered around the robust planning and nuanced implementation of the CPS 230 framework, the event highlighted diverse compliance stages. While some organisations have already “baked their cake” by aligning with international standards, they now face the challenge of “applying the icing” to fully meet with CPS 230 standards. Others are at the preliminary stage of assembling their ingredients to bake their cake.

This blog delves into the shared insights, emerging trends, and practical steps gleaned from the summit, providing a guide for organisations at varying stages of their compliance journey.

5 Key Insights from the Summit


1. Board Engagement and Strategic Oversight

A recurring theme from the summit was the critical role of the board in driving CPS 230 initiatives. The priority lies not only in keeping the board informed but in making them active participants in the resilience journey. This involves:

  • Participating in scenario testing and tolerance setting to understand potential impacts and strategic responses.
  • Engaging in strategic discussions that review critical operations and supplier dependencies to ensure a comprehensive understanding of systemic risks.
  • Streamlining communications to ensure the board grasps the ‘big picture’ without getting bogged down in excessive detail.

2. Operationalising the Pillars of CPS 230

The pillars—operating model, risk management, business continuity, critical operations and tolerances, and supply management—form the backbone of CPS 230. Operationalising these pillars involves:

  • Clear mapping of critical functions and operational controls to ensure clarity and accountability in execution.
  • Regular scenario testing to continually assess and refine these frameworks.
  • Implementing robust change management and communication strategies to ensure secure buy-in across all levels of the organisation, ensuring that adjustments to processes are well understood and embraced.

3. Understanding the Scope and Depth of Compliance

The discussions revealed a broad consensus on the need for robust frameworks that extend beyond direct suppliers to encompass fourth and nth parties. This comprehensive approach ensures that resilience is embedded deeply within the organisation’s culture and operational practices, rather than being a superficial checkbox exercise.

4. Leveraging Regulatory Trends for Strategic Advantage

APRA’s approach, rooted in financial services, is setting a precedent that could extend to other industries. Global companies that already adhere to overlapping international regulations find themselves at an advantage. They possess a slipstream that eases the compliance burden, allowing them to focus on refining their operational models under CPS 230.

5. Embracing an iterative approach to compliance

A common theme from the summit was the importance of a phased, iterative approach to compliance, akin to baking a cake:

  • Start with a solid foundation: Ensure that the basic ingredients—the governance frameworks and initial risk assessments—are robust.
  • Test and learn: Early and frequent testing of severe but plausible scenarios to help tease out vulnerabilities and refine tolerance levels.
  • Iterate and improve: Continuous improvement is vital, not to “overbake” solutions or expect perfection on the first try.

Progress and Projections

Iterative Landscape of CPS 230 compliance


  • Reflecting on Progress: Evaluating how definitions and understandings of critical operations have evolved over the past year.
  • Current Focus: Operationalising these definitions through scenario testing and practical application.
  • Future Outlook: Anticipating a shift towards extracting lessons learned and embedding continuous improvement into organisational practices.

A Journey of Collaboration and Continuous Improvement

The journey to full CPS 230 compliance is ongoing and collaborative. The summit emphasized the importance of early piloting and scenario testing.

As we move forward, the focus will increasingly shift to refining these strategies and ensuring they are fit for purpose—not just for today, but as a resilient foundation for the future.

Discover How iluminr Can Transform Your CPS 230 Compliance Journey

Explore how iluminr’s interactive tabletop exercises and Microsimulations can streamline your organisation’s journey from planning through implementation to continuous improvement under APRA’s CPS 230 standards. Schedule a discovery call with our team today.