What evidence do auditors commonly ask for on CPS 234 para 30 Skilled and independent testers?

Tester qualifications and certifications (for example OSCP, CREST, CISSP) on file; Organisation chart or engagement letters showing testers are separate from the teams operating the controls; Independence declarations for internal and external testers; Rotation or selection policy for external testing providers; Test reports naming the testing team and their reporting line.

What is the most common gap auditors find on CPS 234 para 30?

Controls tested by the same team that built and runs them

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

`CPS 234 para 30` Skilled and independent testers

The entity makes sure its control testing is carried out by specialists with suitable skills who are functionally independent of what they test.

Source: APRA CPS 234, CPS 234 para 30. 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

Tester qualifications and certifications (for example OSCP, CREST, CISSP) on file · Document repository

governing documentDocuments that govern the control

Organisation chart or engagement letters showing testers are separate from the teams operating the controls · Document repository
Independence declarations for internal and external testers · Document repository
Rotation or selection policy for external testing providers · Policy repository / GRC workspace
Test reports naming the testing team and their reporting line · Document 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

Controls tested by the same team that built and runs them
No record of tester competence
Long-standing single external provider with no assessment of independence

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 29 Escalate control deficiencies that cannot be fixed promptly · CPS 234 para 31 Review the sufficiency of the testing program