Axelo Thought Leadership Series
Operational resilience and information security are no longer peripheral concerns, they’re core governance priorities. The introduction of APRA’s CPS 230 and the evolving ISO 27001 standard are clear signals that mid‑market boards and executives need to integrate regulatory mandates with strategic risk frameworks. This article outlines how these instruments complement each other and what that means for governance in mid‑market entities.
1. APRA’s CPS 230: A shift toward operational resilience
From 1 July 2025, CPS 230 Operational Risk Management is mandatory for all APRA‑regulated entities—banks, insurers, superannuation trustees and more (Global Regulation Tomorrow). The standard consolidates previous requirements and emphasises three core expectations:
- Identify, assess and manage operational risks with effective controls, monitoring and remediation (The Protecht Group, APRA).
- Ensure continuity of critical operations within defined tolerance levels via credible and tested business continuity plans (BCPs) (APRA).
- Manage risks posed by material service providers, supported by formal agreements, monitoring and registers (APRA).
Non‑significant institutions have limited transitional concessions for BCP and scenario analysis requirements, but overall, APRA is expecting a robust, multi‑year response rather than a tick‑box effort (KPMG).
Implication for mid-market entities: CPS 230 demands that governance evolves from oversight to active stewardship of operational resilience. Boards must be briefed regularly, scenario test results must inform decisions, and provider risk needs structured controls.
2. ISO 27001: Embedding information security within governance
ISO/IEC 27001, updated in 2022, remains the global benchmark for Information Security Management Systems (ISMS). It offers a risk‑based framework that helps organisations—especially small‑to‑mid‑market businesses—proactively secure data, meet regulatory and customer expectations, and accelerate procurement cycles (Sprinto).
Key elements include:
- Scoping the ISMS, performing risk assessments (likelihood and impact), assigning clear roles, and selecting controls documented in an Annex A‑based Statement of Applicability (The Protecht Group, Sprinto).
- Embedding continuous monitoring, management reviews (e.g., requirement 9.3), and audits to ensure ongoing adequacy and effectiveness (ISMS.online).
- Special relevance for third‑party and incident response risk in the context of AI and cloud systems (Cloud Security Alliance).
Implication for mid-market entities: ISO 27001 brings rigour and strategic clarity to information risk governance. Certification or alignment bolsters trust and ensures that information security is structured, auditable, and board-visible.
3. From regulation to resilience: Strategic convergence
Although CPS 230 and ISO 27001 address different domains—operational resilience on the one hand, information security on the other—they share common governance architecture:
| Governance dimension | CPS 230 requirement | ISO 27001 counterpart |
| Board oversight | Oversight of operational risk and BCPs (APRA) | Management review, ISMS steering and oversight (ISMS.online, Sprinto) |
| Risk identification & assessment | Mapping critical operations & tolerance levels (APRA) | Risk assessments of information assets (Sprinto, Advisera) |
| Controls & monitoring | Internal controls, scenario testing, provider monitoring (APRA, The Protecht Group) | Selection of Annex A controls and audits (Sprinto, OneTrust) |
| Continuous improvement | BCP testing, uppercase remediation (APRA, KPMG) | ISMS updates, audits, management reviews (ISMS.online, Sprinto) |
That overlap offers mid-market boards a strategic opportunity: rather than treating CPS 230 and ISO 27001 as discrete compliance tasks, they can integrate them into a broader resilience and governance framework—improving efficiency, reducing duplication (e.g., overlapping audits), and deepening insights into risk exposure.
4. Governance roadmap: A practical approach
Below is a governance-grade roadmap for mid-market boards and senior teams:
- Map critical operations & information assets: Perform combined mapping workshops to capture dependencies, including service providers and IT systems.
- Define appetite and tolerance: Articulate acceptable disruption timeframes and data security thresholds, aligning both standards.
- Design consolidated risk register and controls matrix: Capture operational, cyber, third-party, and information security controls in one dynamic dashboard.
- Test and validate resilience: Use scenario-based tests that stress both BCPs and cyber incident response—including geographic, ransomware or supply-chain disruptions.
- Establish governance cadence: Quarterly board reporting that integrates operational risk profile (CPS 230) with ISMS performance and incidents (ISO).
- Remediate and embed continuous review: Follow-up on control gaps and audit findings; plan certifications, tabletop exercises, and periodic reviews.
5. Positioning Axelo for execution
Axelo sits squarely at the nexus of strategy and implementation. Mid-market clients require both the high-order thinking expected from top-tier consultancies and the practical tools, assessments, templates and execution support to embed that thinking.
For example, Axelo subsidiaries could offer:
- A CPS 230 readiness toolkit including mapping templates, provider registers, critical operation heat maps and scenario-testing guides.
- An ISO 27001 alignment programme for mid-market entities—scoping, risk assessment tools, ISMS documentation templates, management review schedules, internal audit checklists.
Conclusion
CPS 230 and ISO 27001 are more than compliance boxes—they reflect a broader shift toward resilience-centred governance. For mid-market boards, this convergence is a strategic inflection point. Governance that integrates operational and information risk not only meets regulator expectations—it reinforces trust, improves continuity, and prepares organisations for future disruptions.