APRA CPS 234NIST SP 800-171 Rev 3

APRA CPS 234 covers 13.4% of NIST SP 800-171 Rev 3

13 of the 97 controls in NIST SP 800-171 Rev 3 are already satisfied by evidence you collected for APRA CPS 234. 84 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.

13.4%
of the target already covered
13
controls evidenced
84
genuine gaps
0
claims rejected in review

This number is directional. It says how much of NIST SP 800-171 Rev 3 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.

32 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.

03.06 IR (Incident Response)4 of 5 evidenced, 1 to do
03.12 CA (Security Assessment and Monitoring)3 of 4 evidenced, 1 to do
03.17 SR (Supply Chain Risk Management)2 of 3 evidenced, 1 to do
03.11 RA (Risk Assessment)1 of 3 evidenced, 2 to do
03.15 PL (Planning)1 of 3 evidenced, 2 to do
03.16 SA (System and Services Acquisition)1 of 3 evidenced, 2 to do
03.14 SI (System and Information Integrity)1 of 5 evidenced, 4 to do
03.01 AC (Access Control)0 of 16 evidenced, 16 to do
03.02 AT (Awareness and Training)0 of 2 evidenced, 2 to do
03.03 AU (Audit and Accountability)0 of 8 evidenced, 8 to do
03.04 CM (Configuration Management)0 of 10 evidenced, 10 to do
03.05 IA (Identification and Authentication)0 of 8 evidenced, 8 to do
03.07 MA (Maintenance)0 of 3 evidenced, 3 to do
03.08 MP (Media Protection)0 of 7 evidenced, 7 to do
03.09 PS (Personnel Security)0 of 2 evidenced, 2 to do
03.10 PE (Physical Protection)0 of 5 evidenced, 5 to do
03.13 SC (System and Communications Protection)0 of 10 evidenced, 10 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 2503.06.01argued against and upheld
Incident Handling

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

CPS 234 para 2303.06.01argued against and upheld
Incident Handling

Robust mechanisms must detect information security incidents and respond in a timely way.

CPS 234 para 2503.06.02argued against and upheld
Incident Monitoring, Reporting, and Response Assistance

Plans must define escalation and reporting of incidents to the Board and incident owners.

CPS 234 para 3503.06.02argued against and upheld
Incident Monitoring, Reporting, and Response Assistance

Material incidents must be reported to the regulator within 72 hours; recipient differs from target.

CPS 234 para 2603.06.03argued against and upheld
Incident Response Testing

Response plans must be reviewed and tested annually with results confirming effectiveness.

CPS 234 para 2403.06.05argued against and upheld
Incident Response Plan

Response plans must be maintained for every information security incident that could plausibly occur.

CPS 234 para 2503.06.05argued against and upheld
Incident Response Plan

Plans must set out stage by stage mechanisms plus escalation and reporting.

CPS 234 para 2903.11.04argued against and upheld
Risk Response

Findings from testing must be remediated in a timely way or escalated to the Board.

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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