What is the primary objective of **MLPS 2.0 (Multi-Level Protection Scheme)**?

**The primary objective of MLPS 2.0 is to establish a graded cybersecurity protection system ensuring security controls match the potential harm from system compromise to national security, social order, and public interests.** It classifies systems into five levels based on impact severity, mandating commensurate technical, management, physical, and personnel controls per GB/T 22239-2019 standards. This integrates cybersecurity into national stability objectives via common baselines and technology-specific extensions for cloud, IoT, and big data.

Who is legally or professionally required to comply with **MLPS 2.0 (Multi-Level Protection Scheme)**?

**All network operators in mainland China must comply with MLPS 2.0 under Article 21 of the 2017 Cybersecurity Law.** This encompasses domestic enterprises, foreign-invested entities, cloud providers, and operators of IT, OT, IoT, or big data systems. Critical sectors like finance, energy, and telecom face heightened scrutiny, with Levels 2+ requiring PSB filing.

Does **MLPS 2.0 (Multi-Level Protection Scheme)** require an external audit or third-party certification?

**Yes, MLPS 2.0 mandates external security reviews by licensed Chinese firms for Level 2 and above systems.** Reviews score compliance at least 75/100 across technical and management domains per GB/T 28448-2019, followed by PSB approval. Level 3+ systems undergo periodic evaluations; Level 1 relies on self-assessment.

How often should an assessment for **MLPS 2.0 (Multi-Level Protection Scheme)** be performed?

**Assessments for MLPS 2.0 must occur biennially for Level 2, annually for Level 3, semi-annually for Level 4, and as mandated for Level 5.** Re-evaluations are also triggered by major system changes. Self-inspections apply to all levels, with PSB oversight intensifying for higher classifications.

What are the consequences of non-compliance with **MLPS 2.0 (Multi-Level Protection Scheme)**?

**Non-compliance with MLPS 2.0 incurs fines up to 100,000 yuan, operational suspensions, and business license denial.** PSBs enforce via inspections; severe cases link to broader sanctions under the Cybersecurity Law, as seen in RMB 223 million bank fines for data breaches.

Can **MLPS 2.0 (Multi-Level Protection Scheme)** be mapped to other international frameworks?

**Yes, MLPS 2.0 control domains align with international frameworks like ISO 27001 and NIST CSF.** Organizational, physical, and technical controls map to ISO Annex A categories; risk treatment plans support MLPS gap analyses. However, MLPS adds prescriptive grading, PSB oversight, and data localization absent in voluntary standards.

What is the first step to begin implementing **MLPS 2.0 (Multi-Level Protection Scheme)**?

**The first step is conducting a provisional self-assessment to classify systems into one of five protection levels based on impact to national security and public interests.** Inventory assets, evaluate harm severity per GB/T 22239-2019, document rationale, then file with local PSB for Levels 2+.

What is the primary objective of **APRA CPS 234**?

**APRA CPS 234 requires regulated entities to maintain an information security capability commensurate with vulnerabilities and threats to information assets, minimizing the likelihood and impact of incidents on confidentiality, integrity, or availability (CIA).** This capability must enable continued sound operation and explicitly covers assets managed by related parties and third parties (paragraphs 15–16). Boards hold ultimate responsibility (paragraph 13), with requirements commencing 1 July 2019.

Who is legally or professionally required to comply with **APRA CPS 234**?

**APRA CPS 234 applies to all APRA-regulated entities, including authorised deposit-taking institutions (ADIs), general insurers, life companies, private health insurers, and RSE licensees (paragraph 2).** Heads of groups must apply it group-wide, including non-regulated entities (paragraph 4). Foreign ADIs, Category C insurers, and eligible foreign life insurers comply for Australian branch operations only (paragraph 3). Third-party assets comply from the earlier of contract renewal or 1 July 2020 (paragraph 6).

Does **APRA CPS 234** require an external audit or third-party certification?

**APRA CPS 234 does not mandate external audits or third-party certifications but requires internal audit to review information security control design and operating effectiveness, including third-party controls (paragraphs 32–34).** Internal audit must assess third-party assurance if relying on it for material-impact assets (paragraph 34). Systematic testing must use skilled, functionally independent specialists (paragraph 30), which may involve external providers.

How often should an assessment for **APRA CPS 234** be performed?

**APRA CPS 234 requires review of the systematic testing program at least annually or upon material changes to information assets or the business environment (paragraph 31).** Testing frequency is commensurate with vulnerability/threat change rates, asset criticality/sensitivity, incident consequences, untrusted environment exposure, and asset changes (paragraph 27). Incident response plans must be reviewed and tested annually (paragraph 26).

What are the consequences of non-compliance with **APRA CPS 234**?

**Non-compliance with APRA CPS 234 exposes entities to APRA's prudential powers, including directions, increased supervision, or other enforcement actions under enabling Acts like the Banking Act 1959 (paragraph 11).** Entities must notify APRA within 72 hours of material incidents (paragraph 35) or 10 business days of unremediable material control weaknesses (paragraph 36), triggering scrutiny. APRA may adjust requirements in writing but expects timely remediation.

Can **APRA CPS 234** be mapped to other international frameworks?

**Yes, APRA CPS 234's outcomes-based requirements for governance, controls, testing, and third-party management align with frameworks like ISO 27001 and NIST Cybersecurity Framework.** It emphasizes commensurate capability (paragraph 15), asset classification (paragraph 20), systematic testing (paragraph 27), and board accountability (paragraph 13), enabling mapping without prescription. PPG 234 supports industry standards for operationalization.

What is the first step to begin implementing **APRA CPS 234**?

**The first step for implementing APRA CPS 234 is for the Board to assume ultimate responsibility and approve defined roles/responsibilities for information security across governance bodies and individuals (paragraphs 13–14).** This establishes oversight, followed by asset classification by criticality/sensitivity (paragraph 20) to drive commensurate controls and testing.

MLPS 2.0 (Multi-Level Protection Scheme) vs APRA CPS 234

Standards Comparison

MLPS 2.0 (Multi-Level Protection Scheme)

Mandatory

2019

China's mandatory graded cybersecurity framework for networks

APRA CPS 234

Mandatory

2019

Australian prudential standard for information security resilience.

Quick Verdict

MLPS 2.0 mandates graded protection for all China networks via PSB oversight, while APRA CPS 234 requires Australian financial firms to maintain resilient info security with board accountability and 72-hour incident reporting. Organizations adopt them for legal compliance and cyber resilience.

Cybersecurity

MLPS 2.0 (Multi-Level Protection Scheme)

Multi-Level Protection Scheme 2.0 (MLPS 2.0)

Cost

€€€€

Complexity

Medium

Implementation Time

12-18 months

Key Features

Five-tier impact-based system classification model
Mandatory registration and audits for Level 2+
Police-enforced oversight by Public Security Bureaus
Graded technical controls for cloud, IoT, ICS
75/100 score threshold for third-party certification

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 notification to APRA for material incidents
Systematic risk-based testing of controls
Full coverage of third-party managed assets
Internal audit assurance including third parties

Detailed Analysis

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

MLPS 2.0 (Multi-Level Protection Scheme) Details

What It Is

MLPS 2.0 (Multi-Level Protection Scheme 2.0) is China's legally mandated cybersecurity framework under the 2017 Cybersecurity Law (Article 21). It requires network operators to classify systems into five protection levels based on compromise impact to national security, social order, and public interests. The risk-based approach uses standards like GB/T 22239-2019 for baselines.

Key Components

Technical domains: physical security, network protection, data encryption, monitoring.
Management: governance, policies, personnel vetting, incident response.
Extended controls for cloud, IoT, big data, ICS.
Compliance via third-party audits (75/100 score) and PSB approval for Level 2+.

Why Organizations Use It

Mandated for all China-based networks; avoids fines, suspensions. Enhances resilience, supports market access, aligns with data laws. Builds regulator trust, reduces breach risks.

Implementation Overview

Phased: classify systems, gap analysis, remediate controls, external audit, PSB filing. Applies to all sizes/industries in China; ongoing re-evaluations required. (178 words)

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 for regulated financial entities. Effective from 1 July 2019, it requires maintaining information security capabilities 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 testing.

Key Components

Board ultimate responsibility and defined roles (paras 13-14)
Asset classification by criticality/sensitivity (para 20)
Commensurate controls across asset lifecycle (para 21)
Systematic testing, internal audit assurance (paras 27-34)
Incident detection/response and APRA notifications (paras 23-36) No fixed controls; ~24 paragraphs of requirements focused on outcomes.

Why Organizations Use It

Mandatory compliance for APRA-regulated banks, insurers, super funds
Reduces cyber incident risks, protects customers/depositors
Builds operational resilience, avoids penalties/supervisory actions
Enhances stakeholder trust and third-party oversight

Implementation Overview

Phased: gap analysis, policy framework, testing programs, third-party assessments. Applies group-wide to all sizes in Australian financial sector. APRA supervision via audits/notifications; no external certification.