TheArtOfService
APRA CPS 234FedRAMP Moderate

APRA CPS 234 covers 5.9% of FedRAMP Moderate

19 of the 323 controls in FedRAMP Moderate are already satisfied by evidence you collected for APRA CPS 234. 304 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.

5.9%
of the target already covered
19
controls evidenced
304
genuine gaps
0
claims rejected in review

This number is directional. It says how much of FedRAMP Moderate 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.

41 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.

SR - Supply Chain Risk Management4 of 12 evidenced, 8 to do
IR - Incident Response5 of 17 evidenced, 12 to do
RA - Risk Assessment3 of 11 evidenced, 8 to do
CA - Assessment, Authorization, and Monitoring3 of 14 evidenced, 11 to do
PS - Personnel Security2 of 10 evidenced, 8 to do
SA - System and Services Acquisition1 of 21 evidenced, 20 to do
SI - System and Information Integrity1 of 24 evidenced, 23 to do
AC - Access Control0 of 43 evidenced, 43 to do
AT - Awareness and Training0 of 6 evidenced, 6 to do
AU - Audit and Accountability0 of 16 evidenced, 16 to do
CM - Configuration Management0 of 27 evidenced, 27 to do
CP - Contingency Planning0 of 23 evidenced, 23 to do
IA - Identification and Authentication0 of 27 evidenced, 27 to do
MA - Maintenance0 of 10 evidenced, 10 to do
MP - Media Protection0 of 7 evidenced, 7 to do
PE - Physical and Environmental Protection0 of 19 evidenced, 19 to do
PL - Planning0 of 7 evidenced, 7 to do
SC - System and Communications Protection0 of 29 evidenced, 29 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 27CA-2argued against and upheld
Control Assessments

Control effectiveness must be assessed through a systematic programme with risk driven scope and frequency.

CPS 234 para 30CA-2argued against and upheld
Control Assessments

Assessors must be skilled specialists functionally independent of the activity being tested.

CPS 234 para 32CA-2argued against and upheld
Control Assessments

Internal audit must review design and operating effectiveness of information security controls.

CPS 234 para 29CA-5argued against and upheld
Plan of Action and Milestones

Deficiencies that cannot be remediated in a timely way must be recorded and escalated.

CPS 234 para 27CA-7argued against and upheld
Continuous Monitoring

Ongoing control effectiveness testing at a frequency reflecting change is continuous monitoring.

CPS 234 para 31CA-7argued against and upheld
Continuous Monitoring

Programme sufficiency is reviewed annually and after material change, keeping monitoring current.

CPS 234 para 26IR-3argued against and upheld
Incident Response Testing

Response plans must be reviewed and tested annually to confirm they remain effective.

CPS 234 para 25IR-4argued against and upheld
Incident Handling

Plans must cover every incident stage from detection through to post incident review.

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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