Standards Comparison

    ISO 37001

    Voluntary
    2025

    International standard for anti-bribery management systems

    VS

    APRA CPS 234

    Mandatory
    2019

    Australian prudential standard for information security resilience

    Quick Verdict

    ISO 37001 offers voluntary global anti-bribery certification for all sectors, mitigating legal risks through due diligence. APRA CPS 234 mandates information security for Australian financial firms, ensuring cyber resilience via strict testing and notifications.

    Anti-Bribery/Compliance

    ISO 37001

    ISO 37001 Anti-Bribery Management Systems

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

    Key Features

    • Risk-based Anti-Bribery Management System framework
    • Mandatory third-party due diligence and monitoring
    • Leadership commitment and anti-bribery culture emphasis
    • PDCA cycle for continual improvement
    • Internationally certifiable standard with audits
    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
    • Systematic independent testing of controls
    • Third-party managed asset requirements
    • Asset classification by criticality and sensitivity

    Detailed Analysis

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

    ISO 37001 Details

    What It Is

    ISO 37001:2025 Anti-Bribery Management Systems is a certifiable international standard providing requirements and guidance for establishing, implementing, and improving an Anti-Bribery Management System (ABMS). Its primary purpose is to help organizations prevent, detect, and respond to bribery risks proportionately, using a risk-based PDCA (Plan-Do-Check-Act) approach across public, private, and not-for-profit sectors.

    Key Components

    • Clauses 4–10 covering context, leadership, planning, support, operations, evaluation, and improvement.
    • Core controls: anti-bribery policy, risk assessments, third-party due diligence, financial/non-financial controls, training, reporting, and audits.
    • Built on ISO Harmonized Structure for integration with standards like ISO 9001.
    • Optional third-party certification with annual surveillance audits.

    Why Organizations Use It

    • Mitigates legal risks (e.g., FCPA, UK Bribery Act) via evidentiary "reasonable steps".
    • Enhances reputation, stakeholder trust, and ESG alignment.
    • Delivers 15% compliance cost reductions and cultural shifts.
    • Provides competitive edge in tenders and partnerships.

    Implementation Overview

    Phased approach: gap analysis, risk assessment, control design, training, monitoring, certification. Applicable to all sizes/sectors; scalable and integrable.

    APRA CPS 234 Details

    What It Is

    APRA Prudential Standard CPS 234 (Information Security) is a binding Australian regulation for APRA-regulated financial institutions. Effective from 1 July 2019, it requires maintaining an information security capability commensurate with threats and vulnerabilities to minimize impacts on confidentiality, integrity, and availability (CIA) of information assets, including those managed by third parties. It adopts a risk-based, assurance-driven approach emphasizing governance and resilience.

    Key Components

    • Board ultimate responsibility (para 13) and defined roles
    • Asset classification by criticality and sensitivity (para 20)
    • Commensurate lifecycle controls, systematic testing, internal audit (paras 21-34)
    • Incident detection/response plans with annual testing (paras 23-26)
    • APRA notifications: 72 hours for material incidents, 10 business days for weaknesses (paras 35-36) No fixed controls; ~24 core requirements.

    Why Organizations Use It

    Mandatory for banks, insurers, super funds to avoid penalties, ensure operational resilience, manage third-party risks, and meet prudential obligations. Builds trust, reduces incident impacts, enhances competitiveness.

    Implementation Overview

    Phased: gap analysis, policy framework, asset inventory/classification, controls/testing, monitoring. Applies Australia-wide to regulated entities of all sizes; requires independent assurance, no certification but APRA supervision. Typically 12-18 months.

    Key Differences

    Scope

    ISO 37001
    Anti-bribery management systems only
    APRA CPS 234
    Information security and cyber resilience

    Industry

    ISO 37001
    All sectors worldwide
    APRA CPS 234
    Australian financial services only

    Nature

    ISO 37001
    Voluntary certifiable standard
    APRA CPS 234
    Mandatory prudential regulation

    Testing

    ISO 37001
    Internal audits, management reviews
    APRA CPS 234
    Systematic independent control testing

    Penalties

    ISO 37001
    Certification loss, no legal penalties
    APRA CPS 234
    Regulatory sanctions, fines, enforcement

    Frequently Asked Questions

    Common questions about ISO 37001 and APRA CPS 234

    ISO 37001 FAQ

    APRA CPS 234 FAQ

    You Might also be Interested in These Articles...

    Run Maturity Assessments with GRADUM

    Transform your compliance journey with our AI-powered assessment platform

    Assess your organization's maturity across multiple standards and regulations including ISO 27001, DORA, NIS2, NIST, GDPR, and hundreds more. Get actionable insights and track your progress with collaborative, AI-powered evaluations.

    100+ Standards & Regulations
    AI-Powered Insights
    Collaborative Assessments
    Actionable Recommendations

    Check out these other Gradum.io Standards Comparison Pages