Standards Comparison

    NIST 800-171

    Mandatory
    2020

    U.S. framework protecting CUI in nonfederal systems

    VS

    APRA CPS 234

    Mandatory
    2019

    Australian prudential standard for information security resilience

    Quick Verdict

    NIST 800-171 provides tailored CUI safeguards for US defense contractors via contracts, while APRA CPS 234 mandates comprehensive information security governance for Australian financial entities with strict board accountability and APRA notifications.

    Controlled Unclassified Information

    NIST 800-171

    NIST SP 800-171: Protecting CUI in Nonfederal Systems

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

    Key Features

    • Tailored controls protect CUI in nonfederal systems
    • Requires SSP and POA&M documentation artifacts
    • Scoped to CUI-processing components and enclaves
    • 14-17 families from SP 800-53 Moderate baseline
    • DFARS-mandated for DoD contractors handling CDI
    Information Security

    APRA CPS 234

    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 for material incidents to APRA
    • Systematic independent testing of security controls
    • Coverage of third-party managed information assets
    • Internal audit review of control effectiveness

    Detailed Analysis

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

    NIST 800-171 Details

    What It Is

    NIST SP 800-171 Revision 3 is a U.S. government framework providing security requirements to protect Controlled Unclassified Information (CUI) confidentiality in nonfederal systems. Tailored from SP 800-53 Moderate, it applies to contractors via contracts like DFARS 252.204-7012, focusing on components processing, storing, or transmitting CUI.

    Key Components

    • 17 families (Rev 3) with ~97 requirements covering access control, audit, configuration, and new areas like supply chain risk.
    • Built on FIPS 200 and SP 800-53 baselines.
    • Mandates System Security Plan (SSP) and Plan of Action & Milestones (POA&M).
    • Assessed via SP 800-171A procedures (examine/interview/test).

    Why Organizations Use It

    • Ensures contract eligibility for DoD/federal work.
    • Mitigates breach risks and incident reporting obligations.
    • Builds CMMC Level 2 readiness and supply chain trust.
    • Enhances cybersecurity posture competitively.

    Implementation Overview

    Phased: scope CUI enclave, gap analysis, implement controls, document SSP/POA&M, continuous monitoring. Applies to contractors handling CUI; requires self/third-party assessments, no formal certification but SPRS scoring.

    APRA CPS 234 Details

    What It Is

    APRA Prudential Standard CPS 234 (Information Security) is a binding regulation for APRA-regulated financial entities in Australia. Effective from 1 July 2019, it mandates maintaining information security capabilities commensurate with threats to ensure resilience against incidents impacting confidentiality, integrity, or availability of information assets, including those managed by third parties. It adopts a risk-based, assurance-driven approach focused on governance, controls, and testing.

    Key Components

    • Governance with Board ultimate responsibility (para 13)
    • Asset classification by criticality/sensitivity (para 20)
    • Commensurate controls across asset lifecycle (para 21)
    • Systematic testing and internal audit assurance (paras 27-34)
    • 72-hour APRA notification for material incidents (para 35) No fixed control count; principles-based with third-party extensions.

    Why Organizations Use It

    Mandatory for ADIs, insurers, super funds; enforces prudential stability, minimizes cyber risks, builds stakeholder trust, avoids penalties.

    Implementation Overview

    Phased: gap analysis, policy framework, asset inventory, testing programs. Applies to all sizes in Australian finance; no certification but APRA supervision and notifications required. (178 words)

    Key Differences

    Scope

    NIST 800-171
    CUI protection in nonfederal systems
    APRA CPS 234
    Information security across financial entities

    Industry

    NIST 800-171
    US defense contractors, global applicability
    APRA CPS 234
    Australian financial services (banks, insurers)

    Nature

    NIST 800-171
    Recommended requirements via contracts
    APRA CPS 234
    Mandatory prudential standard with enforcement

    Testing

    NIST 800-171
    Examine/interview/test per 800-171A
    APRA CPS 234
    Systematic, independent testing annually

    Penalties

    NIST 800-171
    Contract ineligibility, no direct fines
    APRA CPS 234
    Regulatory sanctions, supervisory actions

    Frequently Asked Questions

    Common questions about NIST 800-171 and APRA CPS 234

    NIST 800-171 FAQ

    APRA CPS 234 FAQ

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