APRA CPS 234
Australian prudential standard for financial information security resilience
U.S. SEC Cybersecurity Rules
U.S. SEC regulation for cybersecurity risk and incident disclosures
Quick Verdict
APRA CPS 234 mandates comprehensive info security capability for Australian financial firms, while U.S. SEC rules require rapid incident disclosure and governance narratives for public companies. Both ensure resilience; firms adopt for regulatory compliance and investor trust.
APRA CPS 234
APRA Prudential Standard CPS 234 Information Security
Key Features
- Board ultimate responsibility for information security (paragraph 13)
- 72-hour APRA notification for material incidents (paragraph 35)
- Applies to third-party managed information assets
- Systematic risk-based testing of controls (paragraphs 27-31)
- Internal audit assurance of third-party controls (paragraph 32)
U.S. SEC Cybersecurity Rules
Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure
Key Features
- Four-business-day material incident disclosure on Form 8-K
- Annual cybersecurity risk management disclosures in Form 10-K
- Board oversight and management role descriptions
- Inline XBRL tagging for structured data comparability
- Third-party risk processes and supply chain oversight
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 issued by the Australian Prudential Regulation Authority, effective 1 July 2019. It mandates APRA-regulated financial entities to maintain information security capabilities commensurate with threats and vulnerabilities, minimizing impacts on confidentiality, integrity, and availability (CIA) of information assets, including those managed by third parties. Its risk-based, assurance-driven approach emphasizes governance, testing, and rapid notification.
Key Components
- **Governance pillarsBoard accountability (para 13), defined roles (para 14), policy framework (paras 18-19).
- **Risk managementAsset classification by criticality/sensitivity (para 20), commensurate controls across lifecycle (para 21).
- **AssuranceSystematic testing (paras 27-31), internal audit of controls including third parties (paras 32-34).
- **Incident responseDetection mechanisms, annual plan testing (paras 23-26), 72-hour APRA notification for material incidents (para 35). No fixed control count; outcomes-focused with no certification model.
Why Organizations Use It
Ensures prudential compliance, reduces cyber incident risks to operations and customers, enables resilience. Mandatory for regulated entities; non-compliance triggers APRA enforcement like directions or penalties. Builds stakeholder trust, supports outsourcing scrutiny.
Implementation Overview
Phased: gap analysis, asset inventory/classification, control/testing programs, third-party assessments. Applies to APRA entities (ADIs, insurers, super funds) across sizes; internal audit required, no external certification. (178 words)
U.S. SEC Cybersecurity Rules Details
What It Is
U.S. SEC Cybersecurity Rules (Release No. 33-11216), titled Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure, is a federal regulation mandating standardized disclosures for public companies. It applies to Exchange Act reporting companies, focusing on timely incident reporting and ongoing risk transparency to protect investors.
Key Components
- **Form 8-K Item 1.05Four-business-day disclosure of material cybersecurity incidents.
- **Regulation S-K Item 106Annual disclosures on risk processes, strategy, governance in Form 10-K.
- Inline XBRL tagging for structured data.
- Built on securities materiality principles; no fixed controls, emphasizes processes and board oversight.
Why Organizations Use It
Public companies comply to meet legal obligations, avoid enforcement (e.g., fines like Yahoo's $35M), enhance investor confidence, improve capital efficiency, and integrate cyber risk into enterprise governance.
Implementation Overview
Phased rollout (Dec 2023 start); involves cross-functional playbooks, materiality frameworks, board reporting, third-party oversight. Applies to all public filers; no certification but SEC exams/enforcement ensure adherence.
Key Differences
| Aspect | APRA CPS 234 | U.S. SEC Cybersecurity Rules |
|---|---|---|
| Scope | Information security governance, controls, testing, incidents for financial entities | Cybersecurity incident disclosure and risk governance for public companies |
| Industry | Australian financial institutions (banks, insurers, superannuation) | All U.S. public companies and foreign private issuers |
| Nature | Mandatory prudential standard with supervisory enforcement | Mandatory SEC disclosure rules with civil penalties |
| Testing | Systematic, independent control testing annually, internal audit | No specific testing; disclosure of risk management processes |
| Penalties | Supervisory actions, directions, remediation orders | SEC enforcement, fines, injunctions for misleading disclosures |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about APRA CPS 234 and U.S. SEC Cybersecurity Rules
APRA CPS 234 FAQ
U.S. SEC Cybersecurity Rules FAQ
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