TheArtOfService
APRA CPS 220 Risk ManagementNIST SP 800-53 Rev 5

APRA CPS 220 Risk Management covers 4.3% of NIST SP 800-53 Rev 5

13 of the 300 controls in NIST SP 800-53 Rev 5 are already satisfied by evidence you collected for APRA CPS 220 Risk Management. 287 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.

4.3%
of the target already covered
13
controls evidenced
287
genuine gaps
0
claims rejected in review

This number is directional. It says how much of NIST SP 800-53 Rev 5 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.

52 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.

CA - Assessment, Authorization, and Monitoring3 of 8 evidenced, 5 to do
RA - Risk Assessment3 of 9 evidenced, 6 to do
PM - Program Management7 of 32 evidenced, 25 to do
AC - Access Control0 of 23 evidenced, 23 to do
AT - Awareness and Training0 of 5 evidenced, 5 to do
AU - Audit and Accountability0 of 15 evidenced, 15 to do
CM - Configuration Management0 of 14 evidenced, 14 to do
CP - Contingency Planning0 of 12 evidenced, 12 to do
IA - Identification and Authentication0 of 13 evidenced, 13 to do
IR - Incident Response0 of 9 evidenced, 9 to do
MA - Maintenance0 of 7 evidenced, 7 to do
MP - Media Protection0 of 8 evidenced, 8 to do
PE - Physical and Environmental Protection0 of 22 evidenced, 22 to do
PL - Planning0 of 8 evidenced, 8 to do
PS - Personnel Security0 of 9 evidenced, 9 to do
PT - PII Processing and Transparency0 of 8 evidenced, 8 to do
SA - System and Services Acquisition0 of 17 evidenced, 17 to do
SC - System and Communications Protection0 of 47 evidenced, 47 to do
SI - System and Information Integrity0 of 22 evidenced, 22 to do
SR - Supply Chain Risk Management0 of 12 evidenced, 12 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 47NIST800-CA-2argued against and upheld
Control assessments

Prescribes the minimum assessment content the review must produce.

CPS 220 para 45NIST800-CA-2argued against and upheld
Control assessments

Triennial review by operationally independent competent assessors, with assessor selection prescribed.

CPS 220 para 44NIST800-CA-2argued against and upheld
Control assessments

Internal or external audit assesses control effectiveness annually and reports the results.

CPS 220 para 50NIST800-CA-5argued against and upheld
Plan of action and milestones

Requires documented cause, circumstances and remedial steps taken or proposed for each deviation.

CPS 220 para 25NIST800-CA-7argued against and upheld
Continuous monitoring

Regular accurate risk reporting with prompt limit breach escalation to board and management.

CPS 220 para 23NIST800-PM-1argued against and upheld
Information Security Program Plan. Develop and disseminate an organization-wide information security program plan that: Provides an overview of the requirements for the security program and a description of the security program management controls and

Prescribes the mandatory contents of the organisation wide risk programme plan.

CPS 220 para 33NIST800-PM-11argued against and upheld
Mission and Business Process Definition. Define organizational mission and business processes with consideration for information security and privacy and the resulting risk to organizational operations, organizational assets, individuals, other organizations, and the Nation; and

Material risks of the strategic objectives and business plan must be identified and explicitly managed.

CPS 220 para 28NIST800-PM-28argued against and upheld
Risk Framing. Identify and document: Assumptions affecting risk assessments, risk responses, and risk monitoring; Constraints affecting risk assessments, risk responses, and risk monitoring; Priorities and trade-offs considered by the organization for managing risk; and

Risk appetite statement documents tolerance, limits and the trade-offs accepted.

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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