Standards Comparison

    ISO 19600

    Voluntary
    2014

    International guidelines for compliance management systems

    VS

    APRA CPS 234

    Mandatory
    2019

    Australian prudential standard for information security resilience

    Quick Verdict

    ISO 19600 offers voluntary CMS guidelines for all organizations globally, while APRA CPS 234 mandates enforceable information security for Australian financial entities. Companies adopt ISO 19600 for scalable compliance frameworks; CPS 234 ensures regulatory cyber resilience.

    Compliance Management

    ISO 19600

    ISO 19600:2014 Compliance management systems — Guidelines

    Cost
    €€€
    Complexity
    Medium
    Implementation Time
    6-12 months

    Key Features

    • Explicit governance principles for compliance independence
    • Risk-based PDCA management system framework
    • Scalable to any organization size and complexity
    • Integrates with other ISO management systems
    • Broad obligations including voluntary commitments
    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
    • Controls commensurate with asset criticality and lifecycle
    • Systematic independent testing of security controls
    • Third-party capability assessment and assurance required

    Detailed Analysis

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

    ISO 19600 Details

    What It Is

    ISO 19600:2014, titled Compliance management systems — Guidelines, is a non-certifiable international guideline from ISO. It provides scalable guidance for establishing, implementing, evaluating, maintaining, and improving a Compliance Management System (CMS). The primary scope covers all organization types and sizes, using a risk-based, principles-driven approach aligned with PDCA cycle and high-level structure.

    Key Components

    • Core pillars: context, leadership, planning, support, operation, performance evaluation, improvement.
    • **Four principlesgood governance, proportionality, transparency, sustainability.
    • Governance focus: compliance function independence, direct board access, adequate resources.
    • No fixed controls; emphasizes obligations identification, risk assessment, culture embedding.
    • Guidance model, not requirements; predecessor to certifiable ISO 37301.

    Why Organizations Use It

    Drives risk mitigation, operational efficiency, and governance signaling to regulators/courts. Builds stakeholder trust, integrates with other systems, supports penalty reductions. Strategic for demonstrating proactive compliance amid regulatory complexity.

    Implementation Overview

    Phased: gap analysis, policy/objectives, controls/training, monitoring/audits. Applicable universally; proportionate to size/complexity. No certification; internal benchmarking via audits/management reviews. (178 words)

    APRA CPS 234 Details

    What It Is

    APRA Prudential Standard CPS 234 (Information Security) is a binding prudential regulation for APRA-regulated financial institutions in Australia. Effective from 1 July 2019, it requires entities to maintain information security capabilities commensurate with vulnerabilities and threats, minimizing impacts on confidentiality, integrity, and availability (CIA) of information assets, including those managed by third parties. It adopts a risk-based, assurance-driven approach with board accountability.

    Key Components

    • **GovernanceBoard ultimate responsibility; defined roles and policy framework.
    • **Risk ManagementAsset classification by criticality and sensitivity.
    • **ControlsLifecycle implementation commensurate with risks.
    • **Incident ManagementDetection/response mechanisms; annual response plan testing.
    • **Testing/AssuranceSystematic, independent control testing; internal audit reviews.
    • **Reporting72-hour notification for material incidents; 10-day for control weaknesses. No fixed control count; principles-based, aligns with ISO 27001/NIST. Compliance via evidence and supervision.

    Why Organizations Use It

    • Mandatory for ADIs, insurers, super funds to avoid penalties, enforcement.
    • Enhances cyber resilience, operational continuity, stakeholder protection.
    • Builds trust, reduces incident risks, supports prudential outcomes.

    Implementation Overview

    Phased: gap analysis, asset inventory, controls, testing, third-party assessments. Applies to all regulated entity sizes in Australia; board oversight, internal audit essential; no certification but APRA scrutiny.

    Key Differences

    Scope

    ISO 19600
    Compliance management systems guidelines
    APRA CPS 234
    Information security and cyber resilience

    Industry

    ISO 19600
    All organizations worldwide, scalable
    APRA CPS 234
    Australian financial services only

    Nature

    ISO 19600
    Voluntary guidelines, non-certifiable
    APRA CPS 234
    Mandatory prudential standard, enforceable

    Testing

    ISO 19600
    Audits, management reviews recommended
    APRA CPS 234
    Systematic independent testing required

    Penalties

    ISO 19600
    No legal penalties
    APRA CPS 234
    Regulatory sanctions, enforcement actions

    Frequently Asked Questions

    Common questions about ISO 19600 and APRA CPS 234

    ISO 19600 FAQ

    APRA CPS 234 FAQ

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