APRA CPS 234CIS Controls v8

APRA CPS 234 covers 11.1% of CIS Controls v8

17 of the 153 controls in CIS Controls v8 are already satisfied by evidence you collected for APRA CPS 234. 136 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.

11.1%
of the target already covered
17
controls evidenced
136
genuine gaps
0
claims rejected in review

This number is directional. It says how much of CIS Controls v8 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.

47 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.

CIS Control 18: Penetration Testing4 of 5 evidenced, 1 to do
CIS Control 17: Incident Response Management7 of 9 evidenced, 2 to do
CIS Control 15: Service Provider Management4 of 7 evidenced, 3 to do
CIS Control 3: Data Protection2 of 14 evidenced, 12 to do
CIS Control 1: Inventory and Control of Enterprise Assets0 of 5 evidenced, 5 to do
CIS Control 10: Malware Defenses0 of 7 evidenced, 7 to do
CIS Control 11: Data Recovery0 of 5 evidenced, 5 to do
CIS Control 12: Network Infrastructure Management0 of 8 evidenced, 8 to do
CIS Control 13: Network Monitoring and Defense0 of 11 evidenced, 11 to do
CIS Control 14: Security Awareness and Skills Training0 of 9 evidenced, 9 to do
CIS Control 16: Application Software Security0 of 14 evidenced, 14 to do
CIS Control 2: Inventory and Control of Software Assets0 of 7 evidenced, 7 to do
CIS Control 4: Secure Configuration of Enterprise Assets and Software0 of 12 evidenced, 12 to do
CIS Control 5: Account Management0 of 6 evidenced, 6 to do
CIS Control 6: Access Control Management0 of 8 evidenced, 8 to do
CIS Control 7: Continuous Vulnerability Management0 of 7 evidenced, 7 to do
CIS Control 8: Audit Log Management0 of 12 evidenced, 12 to do
CIS Control 9: Email and Web Browser Protections0 of 7 evidenced, 7 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 19CIS-15.2argued against and upheld
Establish and Maintain a Service Provider Management Policy

That framework must direct the responsibilities of related parties and third parties.

CPS 234 para 16CIS-15.3argued against and upheld
Classify Service Providers

Third party assessment is scaled to incident consequences, which classifies providers by criticality.

CPS 234 para 20CIS-15.3argued against and upheld
Classify Service Providers

Both classify by sensitivity and criticality including assets held by third parties.

CPS 234 para 16CIS-15.5argued against and upheld
Assess Service Providers

Both require service providers assessed in proportion to the consequences of failure.

CPS 234 para 22CIS-15.5argued against and upheld
Assess Service Providers

Both require evaluation of the design of provider controls over entity assets.

CPS 234 para 28CIS-15.5argued against and upheld
Assess Service Providers

Where third party control testing is relied on, its nature and frequency must be assessed.

CPS 234 para 28CIS-15.6argued against and upheld
Monitor Service Providers

Both require ongoing assessment of provider control testing rather than a single review.

CPS 234 para 34CIS-15.6argued against and upheld
Monitor Service Providers

Both require internal audit to assess assurance provided by material third parties.

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.

Buy this crosswalk