Standards Comparison

    NIS2

    Mandatory
    2022

    EU directive for high cybersecurity resilience in critical sectors

    VS

    APRA CPS 234

    Mandatory
    2019

    Australian prudential standard for information security resilience

    Quick Verdict

    NIS2 mandates cybersecurity resilience for EU essential entities with strict reporting and fines up to 2% turnover, while APRA CPS 234 requires Australian financial firms to maintain assured information security capabilities with board accountability and 72-hour notifications.

    Cybersecurity

    NIS2

    Directive (EU) 2022/2555 - Network and Information Systems 2

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    Key Features

    • Expanded scope with size-cap rule for medium/large entities
    • Strict multi-stage incident reporting within 24/72 hours
    • Direct senior management accountability for compliance
    • Continuous risk management including supply chain security
    • Fines up to 2% of global annual turnover
    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
    • Extends to all third-party managed assets
    • Systematic independent control testing program
    • Asset classification by criticality and sensitivity

    Detailed Analysis

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

    NIS2 Details

    What It Is

    NIS2 Directive (EU) 2022/2555 is an EU regulation expanding the original NIS Directive to achieve a high common level of cybersecurity across member states. It targets essential and important entities in broadened sectors like energy, transport, health, and digital infrastructure, using a risk-based approach with continuous assurance.

    Key Components

    • Four pillars: risk management, incident reporting, business continuity, corporate accountability.
    • Strict timelines: 24-hour early warnings, 72-hour notifications, one-month final reports.
    • Built on standards like ISO 27001, NIST CSF; no formal certification but national enforcement.

    Why Organizations Use It

    • Legal compliance mandatory for covered entities to avoid fines up to 2% global turnover.
    • Enhances resilience against threats, protects critical services.
    • Builds stakeholder trust, competitive edge via proactive cybersecurity.

    Implementation Overview

    • Applies to medium/large entities (>50 employees, >€10M turnover) in EU sectors.
    • Involves risk assessments, supply chain security, training, governance.
    • Transposition by October 2024; ongoing spot checks by national authorities.

    APRA CPS 234 Details

    What It Is

    APRA Prudential Standard CPS 234 (Information Security) is a binding regulation for APRA-regulated financial entities. Effective 1 July 2019, it requires maintaining capabilities commensurate with threats to minimize impacts on confidentiality, integrity, and availability of information assets, including those managed by third parties. Adopts a risk-based, assurance-driven approach with board oversight.

    Key Components

    • Board ultimate responsibility and defined roles (paras 13-14)
    • Asset classification by criticality/sensitivity (para 20)
    • Lifecycle controls, testing, and incident response (paras 21-31)
    • Internal audit assurance, including third parties (paras 32-34)
    • Notifications: 72 hours for material incidents, 10 days for weaknesses (paras 35-36) Outcomes-focused; no fixed control count.

    Why Organizations Use It

    • Mandatory compliance for ADIs, insurers, super funds
    • Protects operations, customers, and prudential stability
    • Builds cyber resilience and third-party oversight
    • Enhances trust, avoids penalties, aligns with CPS 220/230

    Implementation Overview

    Phased: gap analysis, policy framework, asset register, controls/testing, TPRM. Applies Australia-wide to regulated entities of all sizes. APRA supervision; no external certification, focuses on evidence and governance. (178 words)

    Key Differences

    Scope

    NIS2
    Cybersecurity risk management, incident reporting, governance across sectors
    APRA CPS 234
    Information security capability, controls, third-party management for financial assets

    Industry

    NIS2
    Essential/important entities in EU sectors (energy, transport, digital providers)
    APRA CPS 234
    Australian financial institutions (banks, insurers, superannuation)

    Nature

    NIS2
    Mandatory EU directive, transposed nationally with fines
    APRA CPS 234
    Mandatory prudential standard enforced by APRA supervisor

    Testing

    NIS2
    Risk management measures, supply chain security implied
    APRA CPS 234
    Systematic, independent testing of controls annually, commensurate with risk

    Penalties

    NIS2
    Up to €10M or 2% global turnover for essential entities
    APRA CPS 234
    Supervisory actions, remediation orders, no fixed fines specified

    Frequently Asked Questions

    Common questions about NIS2 and APRA CPS 234

    NIS2 FAQ

    APRA CPS 234 FAQ

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