What evidence do auditors commonly ask for on CPS 230 para 28 Design, implement and embed internal controls?

Control library with control objectives, owners and the risks and obligations each control addresses; Control design assessments; Mapping of key controls to the operational risk appetite metrics.

What is the most common gap auditors find on CPS 230 para 28?

Controls documented but not linked to risks or obligations

APRA CPS 230 · Operational risk management, controls and incidents (paras 23 to 32)

`CPS 230 para 28` Design, implement and embed internal controls

The entity must design, put in place and embed internal controls that reduce its operational risks consistently with its risk appetite and that allow it to meet its compliance obligations.

Source: APRA CPS 230, CPS 230 para 28. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open APRA CPS 230 in the compliance library.

Applies to APRA-regulated entities.

artefacts

held by a system

at each review

hard

to go live

Policy repository / GRC workspace

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

Control design assessments · Document repository

governing documentDocuments that govern the control

Control library with control objectives, owners and the risks and obligations each control addresses · Policy repository / GRC workspace
Mapping of key controls to the operational risk appetite metrics · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Controls documented but not linked to risks or obligations
Control owners not aware of their controls

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

CPS 230 para 27 Risk assessment before providing a material service to another party · CPS 230 para 29 Monitor, review and test controls; report results; rectify gaps promptly