Standards Comparison

    APRA CPS 234

    Mandatory
    2019

    Australian prudential standard for financial information security resilience

    VS

    MAS TRM

    Mandatory
    2021

    Singapore guidelines for financial technology risk management

    Quick Verdict

    APRA CPS 234 mandates information security for Australian financial firms with strict notifications, while MAS TRM provides comprehensive technology risk guidelines for Singapore FIs emphasizing proportionality. Organizations adopt them for regulatory compliance, cyber resilience, and operational stability.

    Information Security

    APRA CPS 234

    APRA Prudential Standard CPS 234 Information Security

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    Key Features

    • Board ultimate responsibility for information security
    • 72-hour APRA notification for material incidents
    • Covers third-party managed information assets
    • Systematic risk-based testing and assurance
    • Asset classification by criticality and sensitivity
    Technology Risk Management

    MAS TRM

    Technology Risk Management Guidelines (January 2021)

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    Key Features

    • Board and senior management accountability
    • Proportional implementation by risk profile
    • End-to-end technology risk lifecycle framework
    • Third-party services risk management
    • Defence-in-depth cyber resilience controls

    Detailed Analysis

    A comprehensive look at the specific requirements, scope, and impact of each standard.

    APRA CPS 234 Details

    What It Is

    APRA Prudential Standard CPS 234 (Information Security) is a binding prudential regulation for APRA-regulated financial entities in Australia. Effective from 1 July 2019, it mandates maintaining information security capabilities commensurate with threats to ensure resilience against incidents impacting confidentiality, integrity, or availability of information assets, including those managed by third parties. It adopts a risk-based, assurance-driven approach focused on governance, controls, and testing.

    Key Components

    • **Governance and accountabilityBoard ultimate responsibility, defined roles.
    • **Risk managementAsset classification by criticality/sensitivity, commensurate controls.
    • **Incident responseDetection mechanisms, response plans, annual testing.
    • **AssuranceSystematic testing, internal audit of controls including third-party.
    • **Reporting72-hour notification for material incidents, 10-day for weaknesses. No fixed control count; principles-based with PPG 234 guidance.

    Why Organizations Use It

    Mandatory for ADIs, insurers, super funds to meet legal obligations, mitigate cyber risks, protect stakeholders, and avoid APRA enforcement. Enhances operational resilience, third-party oversight, and board-level assurance for trust and stability.

    Implementation Overview

    Phased: gap analysis, policy framework, asset inventory, controls, testing program. Applies to all sizes of APRA entities/groups; requires ongoing internal audit, no external certification but APRA supervision.

    MAS TRM Details

    What It Is

    MAS Technology Risk Management (TRM) Guidelines (revised January 2021) are supervisory guidance issued by Singapore's Monetary Authority of Singapore (MAS) for financial institutions. They provide a principles-based framework focused on managing technology and cyber risks to ensure confidentiality, integrity, and availability (CIA) of systems and data. The risk-proportional approach emphasizes governance, controls, and continuous improvement.

    Key Components

    • 15 main sections covering governance, risk frameworks, secure development, IT service management, resilience, access controls, cryptography, data security, cyber operations, assessments, and audit.
    • Synthesised into 12 core principles like board accountability, asset classification, third-party oversight, and defence-in-depth.
    • No fixed controls; outcomes-based with independent assurance.

    Why Organizations Use It

    • Regulatory compliance for MAS-supervised FIs to avoid enforcement.
    • Enhances cyber resilience, reduces incidents, builds stakeholder trust.
    • Supports digital transformation with secure engineering and third-party management.

    Implementation Overview

    • Phased: governance setup, asset inventory, risk assessment, control deployment, testing.
    • Applies to all MAS FIs, scaled by size/complexity; no formal certification but supervisory review.

    Key Differences

    Scope

    APRA CPS 234
    Information security governance and cyber resilience
    MAS TRM
    Broad technology risk management including cyber and IT operations

    Industry

    APRA CPS 234
    Australian financial institutions (ADIs, insurers, super)
    MAS TRM
    Singapore financial institutions (banks, insurers, payments)

    Nature

    APRA CPS 234
    Mandatory prudential standard with enforcement powers
    MAS TRM
    Supervisory guidelines considered in supervision

    Testing

    APRA CPS 234
    Systematic testing and internal audit assurance annually
    MAS TRM
    Annual PT for internet-facing systems, regular VA

    Penalties

    APRA CPS 234
    Supervisory actions, directions, penalties for breaches
    MAS TRM
    Fines, license conditions, enforcement via supervision

    Frequently Asked Questions

    Common questions about APRA CPS 234 and MAS TRM

    APRA CPS 234 FAQ

    MAS TRM FAQ

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