APRA CPS 220 Risk ManagementNIST Cybersecurity Framework 2.0

APRA CPS 220 Risk Management covers 16% of NIST Cybersecurity Framework 2.0

17 of the 106 controls in NIST Cybersecurity Framework 2.0 are already satisfied by evidence you collected for APRA CPS 220 Risk Management. 89 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.

16%
of the target already covered
17
controls evidenced
89
genuine gaps
0
claims rejected in review

This number is directional. It says how much of NIST Cybersecurity Framework 2.0 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.

74 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.

Govern3 of 3 evidenced
GV - Govern10 of 28 evidenced, 18 to do
ID - Identify4 of 21 evidenced, 17 to do
DE - Detect0 of 11 evidenced, 11 to do
PR - Protect0 of 22 evidenced, 22 to do
RC - Recover0 of 8 evidenced, 8 to do
RS - Respond0 of 13 evidenced, 13 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 35NIST-CSF-GV.OC-03argued against and upheld
Legal, regulatory, and contractual requirements are understood

Requires mechanisms for monitoring and ensuring ongoing compliance with all prudential requirements.

CPS 220 para 47NIST-CSF-GV.OV-01argued against and upheld
Risk management strategy outcomes are reviewed

Review must assess whether the framework is implemented, effective and consistent with board appetite.

CPS 220 para 44NIST-CSF-GV.OV-01argued against and upheld
Risk management strategy outcomes are reviewed

Audit reviews compliance with and effectiveness of the framework at least annually.

CPS 220 para 45NIST-CSF-GV.OV-02argued against and upheld
Risk management strategy is reviewed for coverage

Comprehensive triennial review tests appropriateness, effectiveness and adequacy of the whole framework.

CPS 220 para 44NIST-CSF-GV.OV-03argued against and upheld
Risk management performance is evaluated

Effectiveness of the framework is independently reviewed and reported to the board audit committee.

CPS 220 para 29NIST-CSF-GV.RM-01argued against and upheld
Risk management objectives are established and agreed upon

Board approved risk management strategy establishes agreed risk management objectives.

CPS 220 para 28NIST-CSF-GV.RM-02argued against and upheld
Risk appetite and risk tolerance statements are established

Appetite statement must state maximum tolerable level per risk as quantitative limits.

CPS 220 para 27NIST-CSF-GV.RM-02argued against and upheld
Risk appetite and risk tolerance statements are established

Mandates a clear board approved risk appetite statement covering all material risks.

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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