APRA CPS 220 Risk ManagementSOC 2

APRA CPS 220 Risk Management covers 18% of SOC 2

11 of the 61 controls in SOC 2 are already satisfied by evidence you collected for APRA CPS 220 Risk Management. 50 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.

18%
of the target already covered
11
controls evidenced
50
genuine gaps
0
claims rejected in review

This number is directional. It says how much of SOC 2 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.

51 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.

CC - Common Criteria (Security)11 of 33 evidenced, 22 to do
A - Availability0 of 3 evidenced, 3 to do
C - Confidentiality0 of 2 evidenced, 2 to do
P - Privacy0 of 18 evidenced, 18 to do
PI - Processing Integrity0 of 5 evidenced, 5 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 9SOC2-CC1.2argued against and upheld
COSO principle 2: Board exercises oversight responsibility

Board is ultimately responsible for the framework and for overseeing its operation by management.

CPS 220 para 37SOC2-CC1.3argued against and upheld
COSO principle 3: Management establishes structures, reporting lines, and authorities

Designated risk function with defined roles, authority and reporting lines to act independently.

CPS 220 para 23SOC2-CC1.3argued against and upheld
COSO principle 3: Management establishes structures, reporting lines, and authorities

Framework must document roles, responsibilities and formal reporting structures throughout the institution.

CPS 220 para 25SOC2-CC2.1argued against and upheld
COSO principle 13: Obtains and generates relevant, quality information

Robust data framework must produce accurate, timely, aggregated risk information sound enough for decisions.

CPS 220 para 25SOC2-CC2.2argued against and upheld
COSO principle 14: Internally communicates information including objectives and responsibilities

Management information system delivers regular risk reporting to board, committees and senior management.

CPS 220 para 30SOC2-CC2.2argued against and upheld
COSO principle 14: Internally communicates information including objectives and responsibilities

Strategy must describe board and management risk governance relationships and how all staff are made aware.

CPS 220 para 33SOC2-CC3.1argued against and upheld
COSO principle 6: Specifies objectives to identify and assess risks

Must identify and explicitly manage material risks associated with strategic objectives and business plan.

CPS 220 para 35SOC2-CC3.2argued against and upheld
COSO principle 7: Identifies risks and analyzes to determine how managed

Documented process for identifying and assessing material risks and their controls.

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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