TheArtOfService
APRA CPS 234C5 (Germany)

APRA CPS 234 covers 11.6% of C5 (Germany)

14 of the 121 controls in C5 (Germany) are already satisfied by evidence you collected for APRA CPS 234. 107 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.

11.6%
of the target already covered
14
controls evidenced
107
genuine gaps
0
claims rejected in review

This number is directional. It says how much of C5 (Germany) your APRA CPS 234 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.

45 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.

C5: Security Incident Management3 of 5 evidenced, 2 to do
C5: Control and Monitoring of Service Providers and Suppliers3 of 5 evidenced, 2 to do
C5: Compliance2 of 4 evidenced, 2 to do
C5: Security Policies and Instructions1 of 3 evidenced, 2 to do
C5: Organisation of Information Security2 of 7 evidenced, 5 to do
C5: Asset Management1 of 6 evidenced, 5 to do
C5: Operations2 of 24 evidenced, 22 to do
C5: Business Continuity Management0 of 4 evidenced, 4 to do
C5: Communication Security0 of 8 evidenced, 8 to do
C5: Cryptography and Key Management0 of 4 evidenced, 4 to do
C5: Procurement, Development and Modification of Information Systems0 of 10 evidenced, 10 to do
C5: Human Resources0 of 6 evidenced, 6 to do
C5: Identity and Access Management0 of 9 evidenced, 9 to do
C5: Dealing with Investigation Requests from Government Agencies0 of 4 evidenced, 4 to do
C5: Portability and Interoperability0 of 3 evidenced, 3 to do
C5: Physical Security0 of 7 evidenced, 7 to do
C5: Product Safety and Security0 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 234 para 20C5-AM-06argued against and upheld
Asset Classification and Labelling

Both require assets classified by criticality and sensitivity under one scheme.

CPS 234 para 32C5-COM-03argued against and upheld
Internal audits of the information security management system

Both require internal audit to review information security control design and effectiveness.

CPS 234 para 33C5-COM-03argued against and upheld
Internal audits of the information security management system

Both require assurance work performed by appropriately skilled specialists.

CPS 234 para 29C5-COM-04argued against and upheld
Information on information security performance and management assessment of the ISMS

Both require control deficiencies reported to the board or senior management.

CPS 234 para 18C5-OIS-01argued against and upheld
Information Security Management System (ISMS)

Both require a maintained information security policy framework covering the operation.

CPS 234 para 15C5-OIS-01argued against and upheld
Information Security Management System (ISMS)

Both require a maintained information security capability sized to the threats faced.

CPS 234 para 13C5-OIS-02argued against and upheld
Information Security Policy

Both place ultimate accountability for information security with the governing body.

CPS 234 para 18C5-OIS-02argued against and upheld
Information Security Policy

Both require an information security policy proportionate to threats and exposure.

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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