FedRAMP ModerateAPRA CPS 234

FedRAMP Moderate covers 66.7% of APRA CPS 234

16 of the 24 controls in APRA CPS 234 are already satisfied by evidence you collected for FedRAMP Moderate. 8 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.

66.7%
of the target already covered
16
controls evidenced
8
genuine gaps
0
claims rejected in review

This number is directional. It says how much of APRA CPS 234 your FedRAMP Moderate 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.

34 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.

Testing Control Effectiveness4 of 4 evidenced
Third Party Arrangements3 of 3 evidenced
Incident Management3 of 3 evidenced
Implementation of Controls2 of 2 evidenced
Information Asset Identification and Classification1 of 1 evidenced
Internal Audit2 of 3 evidenced, 1 to do
Information Security Capability1 of 2 evidenced, 1 to do
Roles and Responsibilities0 of 2 evidenced, 2 to do
Policy Framework0 of 2 evidenced, 2 to do
APRA Notification0 of 2 evidenced, 2 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.

SR-6CPS 234 para 16argued against and upheld
Assessment of Related Party and Third Party Capability

Assessing and reviewing supplier risk posture at a defined frequency is the capability assessment.

SA-9(1)CPS 234 para 16argued against and upheld
Assessment of Related Party and Third Party Capability

Organizational assessment and approval of an external service before use matches the required judgement.

CA-7CPS 234 para 17argued against and upheld
Active Maintenance of Capability Against Change

Continuous monitoring with defined metrics and frequencies keeps the capability current as threats change.

RA-9CPS 234 para 20argued against and upheld
Information Asset Classification

Criticality analysis identifies the critical components and functions among the assets.

RA-2CPS 234 para 20argued against and upheld
Information Asset Classification

FIPS 199 categorization documented and reviewed annually is classification by impact.

PL-11CPS 234 para 21argued against and upheld
Implementation of Information Security Controls

Tailoring the baseline sizes the controls to the actual criticality and threat picture.

PL-10CPS 234 para 21argued against and upheld
Implementation of Information Security Controls

A control baseline is selected against the system categorization rather than assembled ad hoc.

SR-6CPS 234 para 22argued against and upheld
Evaluation of Third Party Control Design

Supplier review covers the design of controls protecting the assets they hold.

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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