What evidence do auditors commonly ask for on CPS 234 para 21 Implement controls proportionate to risk and lifecycle?

Control library or framework mapped to asset classifications; Risk assessments showing control selection for high-criticality and high-sensitivity assets; Secure development and system acquisition standards covering design-stage controls; Decommissioning and media disposal records; Remediation plans with dates for control gaps identified, and evidence of timely closure.

What is the most common gap auditors find on CPS 234 para 21?

Same baseline controls applied to every asset regardless of classification

APRA CPS 234 · Implementation of controls (paras 21 to 22)

`CPS 234 para 21` Implement controls proportionate to risk and lifecycle

The entity has security controls protecting its information assets, third-party-managed ones included, put in place in good time and calibrated to (a) the threats and vulnerabilities in play, (b) the assets' criticality and sensitivity, (c) where each asset sits in its life-cycle, from planning and design to decommissioning and disposal, and (d) what an incident could lead to.

Source: APRA CPS 234, CPS 234 para 21. 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 234 in the compliance library.

Applies to APRA-regulated entities.

artefacts

held by a system

at each review

hard

to go live

Document repository

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

Risk assessments showing control selection for high-criticality and high-sensitivity assets · Document repository
Decommissioning and media disposal records · Data governance / DLP tooling

governing documentDocuments that govern the control

Control library or framework mapped to asset classifications · Document repository
Secure development and system acquisition standards covering design-stage controls · Policy repository / GRC workspace
Remediation plans with dates for control gaps identified, and evidence of timely closure · 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

Same baseline controls applied to every asset regardless of classification
Controls designed for production but absent at design, test or disposal stages
Known control gaps open for long periods without a plan or risk acceptance

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 234 para 20 Classify information assets by criticality and sensitivity · CPS 234 para 22 Evaluate the design of third-party controls