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 controls match the potential harm from system compromise to national security, social order, and public interests.** It classifies systems into five levels (1-5) based on impact severity, mandating technical, management, physical, and personnel controls via standards like GB/T 22239-2019, GB/T 25070-2019, and GB/T 28448-2019.

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

**All network operators in mainland China, including domestic firms, foreign-invested enterprises, and multinationals with local systems, must comply with MLPS 2.0 under Article 21 of the 2017 Cybersecurity Law.** This covers virtually all IT, cloud, IoT, big data, and industrial control systems; critical sectors like finance and energy often classify at Level 3+.

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

**Yes, MLPS 2.0 requires external security reviews by licensed Chinese firms for Level 2+ systems, with PSB approval and scoring ≥75/100 for certification.** Level 1 needs only self-assessment; higher levels demand invasive audits covering controls, documentation, and on-site inspections.

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

**Assessments under MLPS 2.0 must occur biennially for Level 2, annually for Level 3, semi-annually for Level 4, and as mandated for Level 5, plus after major changes.** Self-inspections are continuous; external re-evaluations ensure ongoing compliance.

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

**Non-compliance with MLPS 2.0 results in fines up to ~100,000 yuan, operational suspensions, business license denial, and intensified PSB inspections.** Severe cases link to broader sanctions under Cybersecurity Law, as seen in RMB 223M bank fines for data failures.

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

**Yes, MLPS 2.0 control domains (e.g., physical, network, data security, governance) map to frameworks like ISO 27001 Annex A and NIST CSF.** Organizations leverage existing ISMS for gap analysis, though MLPS adds prescriptive grading, PSB oversight, and data localization.

What is the primary objective of **MAS TRM**?

**MAS TRM aims to establish sound technology risk governance and cyber resilience through defence-in-depth controls preserving confidentiality, integrity, and availability (CIA) of data and systems.** Per the January 2021 Guidelines (Preface 1.4), financial institutions (FIs) must implement proportional practices across governance (Section 3), risk frameworks (Section 4), secure development (Sections 5-6), operations (Section 7), resilience (Section 8), and cyber defence (Sections 9-13).

Who is legally or professionally required to comply with **MAS TRM**?

**MAS TRM applies to all financial institutions supervised by MAS, including banks, insurers, payment providers, and capital market entities.** Section 2 targets FIs offering services with technology dependencies; proportionality scales implementation to risk, complexity, and service scope (Section 2.2). Boards and senior management bear accountability (Section 3.1).

Does **MAS TRM** require an external audit or third-party certification?

**MAS TRM mandates an independent internal audit function to assess TRM controls, governance, and risk management (Sections 3.1.7, 15), but does not require external certification.** FIs may use third-party penetration testing (Section 13.2) and assurance for high-risk areas; MAS considers observance of Guidelines' spirit during supervision (Section 2.2).

How often should an assessment for **MAS TRM** be performed?

**TRM assessments must occur regularly, with frequency commensurate to system criticality: annual penetration testing for Internet-facing systems (Section 13.2.4), periodic vulnerability assessments (Section 13.1.1), and annual DR plan reviews (Section 8.2.2).** Policies, frameworks, and risk registers require ongoing monitoring and updates (Sections 3.2.1, 4.1.5, 4.5).

What are the consequences of non-compliance with **MAS TRM**?

**Non-compliance risks supervisory actions including fines, license conditions, or revocation, as MAS evaluates TRM observance in supervision (Section 2.2).** Examples include S$27.45M AML/CFT fines across nine FIs and CMS license revocation for governance lapses; boards/senior management face personal prohibitions.

Can **MAS TRM** be mapped to other international frameworks?

**MAS TRM aligns with frameworks like NIST CSF 2.0 and ISO 27001 via shared outcomes in governance, risk cycles, and controls (Sections 3-13).** FIs incorporate industry standards/best practices (Section 3.2.1); mappings support proportional implementation without replacing legislation (Section 2.3).

What is the first step to begin implementing **MAS TRM**?

**Establish board-approved technology risk appetite and inventory all information assets, including third-party-managed ones (Sections 3.1.7, 3.3).** Appoint CIO/CISO (Section 3.1.3) and form governance structures for oversight (Section 3.1).

MLPS 2.0 (Multi-Level Protection Scheme) vs MAS TRM

Q: 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 Levels 1-5 based on impact to national security, social order, and public interests.** Inventory assets, document rationale per GB/T 22239-2019, then file with local PSB within 30 days for Level 2+.

Standards Comparison

MLPS 2.0 (Multi-Level Protection Scheme)

Mandatory

2019

China's mandatory graded cybersecurity for network operators

MAS TRM

Mandatory

2021

Singapore guidelines for financial technology risk management

Quick Verdict

MLPS 2.0 mandates graded cybersecurity for China's networks via PSB oversight; MAS TRM guides Singapore FIs' tech risk proportionally. Chinese firms comply legally, Singapore FIs build resilience and evade fines.

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

Impact-based five-level classification for networks
Mandatory under Cybersecurity Law for all operators
PSB enforcement with audits and inspections
Third-party evaluations scoring 75/100 minimum
Extended controls for cloud IoT big data

Technology Risk Management

MAS TRM

MAS Technology Risk Management Guidelines 2021

Cost

€€€€

Complexity

High

Implementation Time

12-18 months

Key Features

Board and senior management accountability
Proportional risk-based implementation
Third-party risk management requirements
Annual penetration testing for internet systems
Comprehensive cyber resilience framework

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 mandatory regulatory framework for graded cybersecurity protection of information systems and networks, operationalizing Article 21 of the 2017 Cybersecurity Law. It classifies systems into five levels based on potential harm to national security, social order, and public interests, applying technical, governance, and physical controls scaled by risk.

Key Components

Core domains: physical security, network protection, data security, access control, monitoring, governance.
Standards: GB/T 22239-2019 (baseline), GB/T 25070-2019 (technical), GB/T 28448-2019 (evaluation).
Common controls for all levels plus extended for cloud, IoT, big data.
Compliance model: self-classification, third-party audits (75/100 score), PSB approval for Level 2+.

Why Organizations Use It

Legal obligation for all China network operators to avoid fines, suspensions.
Enhances resilience, supports market access, procurement.
Builds regulator trust, integrates with data laws.

Implementation Overview

Phased: inventory, classify, gap analysis, remediate, audit, ongoing re-evaluation. Applies to all sizes in China; Level 3+ needs annual audits, local staff.

MAS TRM Details

What It Is

MAS Technology Risk Management (TRM) Guidelines (revised January 2021) are supervisory guidelines issued by the Monetary Authority of Singapore. They provide principles-based guidance for managing technology and cyber risks in financial institutions, emphasizing proportional implementation based on risk profile, complexity, and criticality to ensure CIA (confidentiality, integrity, availability).

Key Components

15 sections covering governance, risk frameworks, secure development, IT operations, resilience, access controls, cryptography, cyber defense, assessments, and audit.
Synthesized into 12 core principles like board accountability, asset inventories, third-party oversight, and layered defenses.
No fixed control count; focuses on outcomes with continuous improvement.
Compliance via supervisory review, not formal certification.

Why Organizations Use It

Meets MAS supervisory expectations to avoid fines/enforcement.
Enhances cyber resilience, operational stability, customer trust.
Supports digital transformation with secure-by-design practices.
Builds competitive edge through robust risk governance.

Implementation Overview

Risk-based phases: asset inventory, gap analysis, control design, testing, monitoring.
Applies to all MAS-supervised FIs; scalable by size/complexity.
Involves board approval, training, audits; 12-24 months typical.