CPS 234 vs. ISO 27001: Differences and overlaps

CPS 234 and ISO 27001 are two industry-accepted standards that help protect organisations from cyber attacks—one of the biggest threats and concerns Australian organisations experienced in 2024. The standards can be said to share the same end goal—increasing cyber resilience while helping manage information security more effectively.

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Despite this shared goal, CPS 234 and ISO 27001 come with notable differences. For compliance teams pursuing both, it's essential to understand where the frameworks align and where they differ.

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In this guide, we’ll cover:

• Overviews of ISO 27001 and CPS 234
• Explanation of their relationship and overlaps
• Key differences between them

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What is CPS 234?

CPS 234 is a mandatory security regulation developed by the Australian Prudential Regulatory Authority (APRA), intended specifically for organisations in the financial sector. It sets out requirements for how APRA-regulated entities should protect their IT infrastructure against vulnerabilities and the evolving threat landscape.

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The main purpose of CPS 234 is to reduce the risk of security incidents and improve the cyber resilience of financial entities. The regulation enforces this by requiring organisations to establish clear roles and responsibilities, implement robust policies, and ensure effective controls throughout the lifecycle of information assets.

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CPS 234 came into effect on 1 July 2019. If your organisation is in scope, achieving compliance swiftly is crucial to avoid regulatory disruptions and continue operations smoothly.

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What is ISO 27001?

ISO 27001 is a voluntary and globally recognised security framework for developing an information security management system (ISMS). The framework provides prescriptive guidance for securing sensitive information through a balanced approach, combining technical, administrative, and procedural controls to protect an organisation's data.

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ISO 27001, first published in October 2005, is significantly older than CPS 234. Owing to its international credibility, it has been widely adopted by organisations across various sectors and regions.

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ISO 27001 has remained relevant and up-to-date through regular revisions. The latest one, released in 2022, introduced updates to address modern cybersecurity challenges and evolving regulatory requirements, ensuring its continued relevance for organisations aiming to strengthen their information security posture.

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The relationship between CPS 234 and ISO 27001

Due to the shared goal of increasing an organisation's cyber resilience, many of the controls outlined by CPS 234 are closely aligned with those of ISO 27001. This results in notable overlap between the two, which means that organisations that have already implemented ISO 27001 will have a head start in achieving CPS 234 compliance.

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The primary areas in which CPS 234 and ISO 27001 intersect are:

• Strong focus on risk management
• Demand for robust information security policies
• Prescriptive information security controls
• Requirements for regular internal security audits

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However, despite these areas of overlap, the differences are notable enough that achieving ISO 27001 certification doesn’t make your organisation CPS 234 compliant. Understanding these differences is essential to successfully reach and secure ongoing compliance with both.

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CPS 234 requirements were specifically designed to align with ISO 27001 standards, so if an organisation has implemented ISO 27001, CPS 234 should be easier to meet. It has no formal certification process, so demonstrating ISO 27001-certified best practices would help to maintain compliance.”

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Jill Henriques

GRC Subject Matter Expert, GTM, Vanta

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LinkedIn

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4 key differences between CPS 234 and ISO 27001

The four most important differences between CPS 234 and ISO 27001 are:

1. Legal weight
2. Applicability
3. Structure
4. Attestation

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We will closely examine these factors and their impact on your organisation in the sections below.

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1. Legal weight

The most important difference between the two standards is their legal enforceability. CPS 234 is a mandatory standard for all APRA-regulated entities. Depending on the severity of the violation, non-compliance can result in serious consequences, including:

• Investigation
• Operational limitations  
• Legal escalations
• Loss of business
• Reputational damage

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However, the actual penalties for non-compliance are not outlined in CPS 234 but may be imposed under broader legislation, such as the Banking Act, Insurance Act, Life Insurance Act, or Superannuation Industry (Supervision) Act. These can include enforceable undertakings, regulatory directions, or, in serious cases, civil or criminal penalties. 

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Under current legislation, civil penalties for non-compliance are defined in terms of penalty units. For corporations, the maximum penalty can reach up to 50,000 penalty units (approximately AUD 15.65 million as of 2025) or 2,500 penalty units for individuals (approximately AUD 782,500).

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In contrast, compliance with ISO 27001 is voluntary. While not legally required, certification is strongly encouraged. An ISO 27001 certificate demonstrates an organisation's commitment to best-practice information security and ISMS management, which can provide a competitive advantage by increasing trust with customers, partners, and stakeholders.

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2. Applicability

The two standards differ significantly in terms of who they apply to. CPS 234 is both industry- and location-specific, applying only to APRA-regulated financial entities operating in Australia. However, its requirements also extend to third parties—both local and international—who manage or access sensitive data on behalf of these entities.

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Examples of APRA-regulated entities include:

• Banks and credit unions
• Superannuation funds
• General insurers
• Private health insurers
• Non-operating holding companies

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This region- and industry-specific applicability is similar to other region-specific frameworks, such as Essential Eight, which also target Australian organisations but differ in scope and purpose.

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On the other hand, ISO 27001 is a globally recognised standard. Its holistic approach to risk and security practices makes it applicable to all organisations, regardless of sector and geographic location. 

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Bonus read—learn more about Essential Eight, another crucial Australian cybersecurity framework:

• Essential Eight compliance checklist
• How much does Essential Eight compliance cost?

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3. Structure

CPS 234 is a principle-based standard that outlines nine high-level requirement areas. While it doesn’t prescribe a specific number of controls, each area implies a set of expectations that organisations must meet based on their risk profile and security posture. 

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These nine areas are:

1. Roles and responsibilities
2. Information security capability
3. Policy framework
4. Information assets identification and classification
5. Implementation of information security controls
6. Incident management
7. Testing control effectiveness
8. Internal audit
9. APRA notification

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CPS 234 also doesn’t provide explicit guidance on how to implement these requirements. Instead, organisations are expected to assess the risks of their operations and then develop and implement measures to mitigate them proportionally.

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By comparison, ISO 27001 is more comprehensive. It has over 90 controls that cover a broader range of security and risk management practices, which are organised into four domains in Annex A:

1. Organisational (Annex A.5)
2. People (Annex A.6)
3. Physical (Annex A.7)
4. Technological (Annex A.8)

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ISO 27001 also has seven clauses with additional requirements organisations must meet to achieve certification, such as:

• Continual improvement of security systems
• Monitoring and evaluations
• Operational planning
• Maintaining documentation

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4. Attestation

CPS 234 doesn’t have a formal certification process. Instead, achieving and maintaining compliance is done through self-assessments. However, your organisation will still have to report its compliance status and any compliance violations to APRA.

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In contrast, ISO 27001 is a certifiable standard. To complete the ISO 27001 certification process and achieve compliance, you must partner with an accredited auditing body to ensure that your controls meet the framework’s implementation requirements. 

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Despite the significant differences in compliance attestation, ongoing compliance with both standards will require you to perform regular internal reviews.

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Should you prioritise ISO 27001 or CPS 234?

The decision whether to prioritise ISO 27001 or CPS 234 largely depends on your organisation’s location and industry. If you operate in Australia and are considered in-scope by APRA, you should immediately focus on pursuing CPS 234 to avoid non-compliance penalties. CPS 234 certification is often quicker than ISO 27001, especially for smaller organisations with fewer third-party risks.

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However, this doesn’t mean that you shouldn’t also pursue ISO 27001. Even if your organisation is APRA-regulated, implementing ISO 27001 can be beneficial—the framework’s comprehensive nature and significant overlap with CPS 234 will make pursuing it significantly more efficient.

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Regardless of which standard you focus on first, achieving compliance can be challenging and time-consuming without clear guidance and streamlined workflows. Both standards require continuous monitoring and collecting thorough documentation, which puts pressure on your IT, security, and compliance teams and can result in inefficiencies, delays, and bottlenecks.

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This burden can be significantly reduced by leveraging automation software. With the right solution, you can reach and maintain CPS 234 and ISO 27001 compliance more efficiently while minimising the strain on your teams.

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Streamline CPS 234 and ISO 27001 compliance with Vanta

Vanta is a compliance and trust management platform that automates the necessary workflows for many industry-accepted regulations and standards, including CPS 234. 

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The platform offers a dedicated CPS 234 product that supports your compliance efforts with various features, including:

• Pre-built templates and policies to minimise ambiguity
• Continuous visibility of your CPS 234 compliance status, updated hourly
• Integration with over 375 tools for evidence collection and control monitoring
• Access to a network of accredited auditors who can support you through the compliance process

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Schedule a custom demo and see how Vanta can make your compliance process more efficient.

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If you decide to prioritise ISO 27001, you can leverage Vanta’s ISO 27001 product to automate up to 80 per cent of the necessary workflows and save significant time and resources.

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