From July 2025, a new regulatory standard – CPS 230 – will come into effect, reshaping how many Australian enterprises manage operational risk. Introduced by the Australian Prudential Regulation Authority (APRA), CPS 230 is more than just a compliance framework. It is a call for organisations to fundamentally re-examine the way they deliver critical services, manage third-party relationships, and prepare for disruption.
While the standard technically applies to APRA-regulated entities, namely banks, insurers, and superannuation providers, its influence is extending rapidly across government agencies and essential service providers, where continuity, trust, and resilience are core expectations. At first glance, CPS 230 may appear to be just another layer of regulatory pressure, but in reality, presents a unique opportunity – a chance to futureproof risk frameworks, build public trust, and treat resilience as a competitive differentiator.
The ACCC’s Digital Platform Services Inquiry Report (2023) highlighted growing public concern around the reliability of digital services and protection of personal data. As dependence on digital platforms intensifies, expectations for resilience and transparency have risen considerably. Compliance with CPS 230 isn't a simple box-ticking exercise, it’s a credibility framework that directly supports the public’s increasing demand for service continuity and data integrity.
At the heart of the regulation is a focus on critical operations. Organisations must identify which services are vital, not just commercially, but in terms of community wellbeing and stability of key infrastructure. These are the services that must remain available under adverse conditions. Once identified, institutions must determine their impact tolerance, or the maximum level of disruption they can endure before public trust is compromised or regulatory expectations are breached. This forms the foundation for a more mature resilience strategy with real-time awareness of operational health and preparedness.
Third-party risk management is another area of significant change. CPS 230 requires organisations to take full responsibility for the risks associated with outsourcing, including the ability to manage disruptions and exit critical contracts without jeopardising services. Essentially this means tightening supplier governance, enhancing due diligence, and investing in tools to monitor vendor performance over time.
The 2023 ASIC Cyber Pulse Survey revealed that nearly 70% of participants had ‘minimal or no capabilities in third party or supply risk management’, with close to 60% indicating they fail to test cybersecurity incident responses of critical suppliers. CPS 230 is a driver for improving these statistics. But again, those that go beyond pure compliance, and consider it a governance upgrade, stand to benefit most. Streamlined procurement, improved performance transparency, and greater accountability will become the new standard.
Cyber resilience, too, plays a critical role. While CPS 230 is not a cybersecurity regulation, it enhances the need to understand how digital threats can affect operations. Any cyber incident that disrupts service delivery becomes a direct test of an organisation’s continuity readiness. This reinforces the need for cross-functional coordination between cybersecurity, operations, and executive leadership.
The framework also encourages a move away from periodic assessments and a step toward continuous monitoring. With CPS 230, organisations must maintain a real-time understanding of their operational state and how risks are evolving. This opens the door to investments in observability, automation, and shared data across siloed departments – innovations that often face resistance without regulatory incentives.
Perhaps the most significant shift under CPS 230 relates to culture. Risk management can no longer be relegated to back-office teams, as boards and executives are now directly involved in, and accountable for understanding operational risks. Senior leaders must actively shape the organisation’s approach to continuity, bringing it in line with both the regulatory framework and community expectations. This internal cultural uplift is particularly important in public entities, where the relationship with citizens is built on reliability and trust. When disruptions occur, whether digital downtimes, supplier failures, or system-wide outages, the ability to maintain critical operations becomes the defining measure of leadership.
What CPS 230 ultimately represents is a chance to embed resilience into the DNA of how Australian organisations operate. This is not purely about disaster recovery, it’s about designing services, partnerships, and systems with continuity in mind from the outset. The benefits of this approach reach wide. Knowing your true dependencies. Sustaining operations under stress. Having confidence in your suppliers. These aren’t just good risk practices, they are competitive advantages in an environment where trust and transparency are public currency.
With just over a year until the regulation takes full effect for every APRA regulated entity, organisations have a valuable runway. This is a strategic window to not only finalise compliance documentation, but also modernise internal processes, strengthen third-party oversight, and align continuity planning with core operational objectives. Organisations that treat CPS 230 as a catalyst for innovation will be the ones that lead through chaos, earn public trust, and shape the future of resilient service delivery in Australia.