FISMA
U.S. federal law for risk-based cybersecurity management
APRA CPS 234
Australian prudential standard for information security resilience
Quick Verdict
FISMA mandates risk-based security for US federal agencies via NIST RMF, while APRA CPS 234 requires board-accountable info security capability for Australian financial entities with strict testing and 72-hour notifications. Organizations adopt them for mandatory compliance and cyber resilience.
FISMA
Federal Information Security Modernization Act of 2014
Key Features
- Mandates NIST RMF 7-step risk management lifecycle
- Requires continuous monitoring and diagnostics program
- Enforces FIPS 199 system impact categorization
- Extends requirements to federal contractors supply chains
- Demands annual independent IG maturity assessments
APRA CPS 234
APRA Prudential Standard CPS 234 Information Security
Key Features
- Board ultimate responsibility for information security
- 72-hour APRA notification for material incidents
- Systematic risk-based testing of controls
- Third-party managed assets fully in scope
- Asset classification by criticality and sensitivity
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
FISMA Details
What It Is
Federal Information Security Modernization Act (FISMA) of 2014 is a U.S. federal law establishing a mandatory, risk-based framework for protecting federal information and systems. It modernizes the 2002 act, emphasizing continuous monitoring over static compliance, using NIST Risk Management Framework (RMF) as the core methodology.
Key Components
- **7-step NIST RMFPrepare, Categorize, Select, Implement, Assess, Authorize, Monitor.
- NIST SP 800-53 controls tailored by FIPS 199 impact levels (low/moderate/high).
- Continuous diagnostics, incident reporting, and agency-wide security programs.
- Oversight via OMB, DHS/CISA, IGs with maturity models and metrics.
Why Organizations Use It
Federal agencies and contractors must comply to avoid penalties, debarment, and funding loss. It reduces breach risks, enables market access, builds resilience, and aligns cybersecurity with missions for efficiency and trust.
Implementation Overview
Phased RMF execution: inventory assets, categorize systems, deploy controls, assess/authorize, monitor continuously. Applies to agencies, contractors; requires SSPs, POA&Ms, audits. Scales from small contractors to large enterprises via automation and FedRAMP.
APRA CPS 234 Details
What It Is
APRA Prudential Standard CPS 234 (Information Security) is a binding regulation issued by the Australian Prudential Regulation Authority. Effective from 1 July 2019, it mandates APRA-regulated entities like banks, insurers, and super funds to maintain information security capabilities commensurate with threats and vulnerabilities. Its risk-based approach emphasizes governance, controls, testing, and rapid incident notification to protect confidentiality, integrity, and availability (CIA) of information assets, including those managed by third parties.
Key Components
- 11 core requirements spanning board accountability, role definitions, policy frameworks, asset classification, lifecycle controls, incident response, systematic testing, and internal audit assurance.
- Built on CIA triad principles with commensurability to risks.
- No fixed controls; compliance via evidence of effectiveness, with 72-hour incident and 10-business-day weakness notifications to APRA.
Why Organizations Use It
- Mandatory for APRA-regulated entities to avoid penalties, enforcement, and reputational damage.
- Enhances cyber resilience, third-party oversight, and operational continuity.
- Builds stakeholder trust and aligns with global standards like NIST and ISO 27001.
Implementation Overview
- Phased: gap analysis, governance setup, asset inventory, controls, testing, and continuous monitoring.
- Applies to all sizes in Australian financial sector; audited via internal/external assurance, no formal certification.
Key Differences
| Aspect | FISMA | APRA CPS 234 |
|---|---|---|
| Scope | Federal info systems security, RMF lifecycle | Financial sector info security, CIA triad |
| Industry | US federal agencies, contractors, nationwide | Australian financial services, regulated entities |
| Nature | US federal law, mandatory for agencies | Australian prudential standard, mandatory regulated |
| Testing | Continuous monitoring, RMF assessments, IGs | Systematic testing, internal audit, annual reviews |
| Penalties | Loss of contracts, IG reports, funding cuts | Supervisory actions, remediation orders, fines |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about FISMA and APRA CPS 234
FISMA FAQ
APRA CPS 234 FAQ
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