What evidence do auditors commonly ask for on CPS 234 para 27 Systematic testing of control effectiveness?

Documented control testing program with scope, methods and frequency rationale; Testing schedule tied to asset classification and threat change; Penetration test, vulnerability assessment and red team reports; Control testing results register with pass, fail and remediation status; Test coverage analysis showing untrusted-environment exposures (internet-facing, mobile, third-party) are tested.

What is the most common gap auditors find on CPS 234 para 27?

Testing is an annual penetration test only, not a program covering control effectiveness

APRA CPS 234 · Testing control effectiveness (paras 27 to 31)

`CPS 234 para 27` Systematic testing of control effectiveness

The entity tests whether its security controls work through a systematic testing program. How it tests and how often must reflect: (a) how quickly vulnerabilities and threats change; (b) the asset's criticality and sensitivity; (c) what an incident would cause; (d) the risks of exposure to untrusted environments where the entity cannot enforce its security policies; and (e) how material and frequent changes to the assets are.

Source: APRA CPS 234, CPS 234 para 27. 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

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

Penetration test, vulnerability assessment and red team reports · Vulnerability scanner / patch tooling
Test coverage analysis showing untrusted-environment exposures (internet-facing, mobile, third-party) are tested · Endpoint management (MDM / EDR)

governing documentDocuments that govern the control

Documented control testing program with scope, methods and frequency rationale · Policy repository / GRC workspace
Testing schedule tied to asset classification and threat change · Policy repository / GRC workspace
Control testing results register with pass, fail and remediation status · 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

Testing is an annual penetration test only, not a program covering control effectiveness
Frequency not linked to criticality or rate of change
Systems that change often tested on the same cycle as static ones

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 26 Annual review and testing of response plans · CPS 234 para 28 Assess reliance on third-party control testing