What evidence do auditors commonly ask for on CPS 234 para 28 Assess reliance on third-party control testing?

Assessment of each third party's testing program against the paragraph 27 factors; Third-party penetration test summaries or assurance reports obtained and reviewed; Contract clauses requiring testing, frequency and sharing of results; Reliance decision records stating where third-party testing is accepted and where extra testing is needed; Gap tracking where third-party testing falls short.

What is the most common gap auditors find on CPS 234 para 28?

Relying on a vendor's statement that it tests, with no review of what or how often

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

`CPS 234 para 28` Assess reliance on third-party control testing

Where a related or third party manages the entity's information assets and the entity relies on that party's own control testing, the entity checks whether the nature and frequency of that testing for those assets meet the same factors set out in 27(a) to 27(e). A footnote extends this to all such parties, not only CPS 231 or SPS 231 material outsourcing.

Source: APRA CPS 234, CPS 234 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 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

Assessment of each third party's testing program against the paragraph 27 factors · Vendor register / contract repository
Contract clauses requiring testing, frequency and sharing of results · Vendor register / contract repository
Reliance decision records stating where third-party testing is accepted and where extra testing is needed · Vendor register / contract repository

governing documentDocuments that govern the control

Third-party penetration test summaries or assurance reports obtained and reviewed · Policy repository / GRC workspace
Gap tracking where third-party testing falls short · 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

Relying on a vendor's statement that it tests, with no review of what or how often
No contract right to see test results
Third-party testing frequency never compared with the entity's own criteria

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 27 Systematic testing of control effectiveness · CPS 234 para 29 Escalate control deficiencies that cannot be fixed promptly