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APRA CPS 220 Risk ManagementCloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

APRA CPS 220 Risk Management covers 5.1% of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

10 of the 197 controls in Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 are already satisfied by evidence you collected for APRA CPS 220 Risk Management. 187 are genuine gaps. Every claim below was judged against both control sets and then argued against; the ones that did not survive are published further down with the reason each failed.

5.1%
of the target already covered
10
controls evidenced
187
genuine gaps
0
claims rejected in review

This number is directional. It says how much of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 your APRA CPS 220 Risk Management evidence satisfies. The reverse pair is a different number, often very different, because a security standard has enormous depth for access control and almost none for lawful basis or data subject rights.

38 candidate mappings were examined and 0 were removed. Signed off 2026-08-19, review level machine verified. Mappings were judged by Claude Code rather than read line by line by a practitioner. Every claim shows its reasoning so you can check it. Ask and a practitioner will review this pair.

Where the gaps are

Coverage is never evenly spread. A source standard usually satisfies one part of a target almost completely and barely touches another, and which part is which is the thing worth knowing before you plan the work.

GRC - Governance, Risk & Compliance6 of 8 evidenced, 2 to do
A&A - Audit & Assurance4 of 6 evidenced, 2 to do
AIS - Application & Interface Security0 of 7 evidenced, 7 to do
BCR - Business Continuity Management & Operational Resilience0 of 11 evidenced, 11 to do
CCC - Change Control & Configuration Management0 of 9 evidenced, 9 to do
CEK - Cryptography, Encryption & Key Management0 of 21 evidenced, 21 to do
DCS - Datacenter Security0 of 15 evidenced, 15 to do
DSP - Data Security & Privacy Lifecycle Management0 of 19 evidenced, 19 to do
HRS - Human Resources Security0 of 13 evidenced, 13 to do
IAM - Identity & Access Management0 of 16 evidenced, 16 to do
IPY - Interoperability & Portability0 of 4 evidenced, 4 to do
IVS - Infrastructure & Virtualization Security0 of 9 evidenced, 9 to do
LOG - Logging & Monitoring0 of 13 evidenced, 13 to do
SEF - Security Incident Management, E-Discovery & Cloud Forensics0 of 8 evidenced, 8 to do
STA - Supply Chain Management, Transparency & Accountability0 of 14 evidenced, 14 to do
TVM - Threat & Vulnerability Management0 of 10 evidenced, 10 to do
UEM - Universal Endpoint Management0 of 14 evidenced, 14 to do

Theme level, not control level, deliberately. The per-control list of what is evidenced and what is a gap is the report itself, so publishing it here would be publishing the thing being sold.

Claims that held

A sample. Each one names the control whose evidence does the work, the control it satisfies, and why.

CPS 220 para 45CCM-A&A-02argued against and upheld
Independent Assessments

Comprehensive review must be by operationally independent, appropriately trained and competent persons.

CPS 220 para 44CCM-A&A-02argued against and upheld
Independent Assessments

Internal or external audit reviews framework compliance and effectiveness at least annually.

CPS 220 para 46CCM-A&A-03argued against and upheld
Risk Based Planning Assessment

Review scope is driven by size, business mix, complexity, change and external environment.

CPS 220 para 47CCM-A&A-05argued against and upheld
Audit Management Process

Prescribes the minimum assessment content and conclusions each framework review must produce.

CPS 220 para 45CCM-A&A-05argued against and upheld
Audit Management Process

Defines the triennial review cycle, the assessors and the re-examination of the framework.

CPS 220 para 50CCM-A&A-06argued against and upheld
Remediation

Every deviation must carry documented cause and the remedial steps taken or proposed.

CPS 220 para 36CCM-GRC-01argued against and upheld
Governance Program Policy and Procedures

Last revision date, next review date and named owner tracked for every policy.

CPS 220 para 23CCM-GRC-01argued against and upheld
Governance Program Policy and Procedures

Framework must include the approved policies and procedures governing material risk.

Claims that did not hold

Nothing proposed for this pair was rejected in review. That is unusual and worth knowing rather than hiding: it means the candidate set was small and every candidate held.

The full report

Everything above is a sample. The report is every evidenced control and every gap, with the reasoning and the source document behind each one, in a form you can hand to an assessor. $299, emailed immediately.

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