What evidence do auditors commonly ask for on CPS 234 para 22 Evaluate the design of third-party controls?

Control design evaluation reports for each in-scope third or related party; Reviewed third-party assurance reports with the entity's own analysis of scope, exceptions and complementary user-entity controls; Contract rights to information, audit and assessment; Records of design gaps raised with the party and their resolution; Tracking of which parties have had a design evaluation and when.

What is the most common gap auditors find on CPS 234 para 22?

Accepting a certificate or report without reading its scope or exceptions

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

`CPS 234 para 22` Evaluate the design of third-party controls

Where a related or third party manages the entity's information assets, the entity evaluates how that party's security controls protecting those assets are designed. A footnote confirms this reaches every such party, not only CPS 231 or SPS 231 material outsourcing.

Source: APRA CPS 234, CPS 234 para 22. 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

Vendor register / contract 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

Control design evaluation reports for each in-scope third or related party · Vendor register / contract repository
Reviewed third-party assurance reports with the entity's own analysis of scope, exceptions and complementary user-entity controls · Vendor register / contract repository
Records of design gaps raised with the party and their resolution · Vendor register / contract repository

governing documentDocuments that govern the control

Contract rights to information, audit and assessment · Vendor register / contract repository
Tracking of which parties have had a design evaluation and when · Vendor register / contract repository

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

Accepting a certificate or report without reading its scope or exceptions
Evaluation stops at the questionnaire, with no look at control design
Complementary user-entity controls named in a SOC report never put in place by the entity

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 21 Implement controls proportionate to risk and lifecycle · CPS 234 para 23 Detect and respond to incidents promptly