NIS2 DirectiveAPRA CPS 234

NIS2 Directive covers 75% of APRA CPS 234

18 of the 24 controls in APRA CPS 234 are already satisfied by evidence you collected for NIS2 Directive. 6 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.

75%
of the target already covered
18
controls evidenced
6
genuine gaps
0
claims rejected in review

This number is directional. It says how much of APRA CPS 234 your NIS2 Directive 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 2026-08-20, 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.

Third Party Arrangements3 of 3 evidenced
Information Security Capability2 of 2 evidenced
Policy Framework2 of 2 evidenced
Implementation of Controls2 of 2 evidenced
Information Asset Identification and Classification1 of 1 evidenced
Testing Control Effectiveness3 of 4 evidenced, 1 to do
Incident Management2 of 3 evidenced, 1 to do
Roles and Responsibilities1 of 2 evidenced, 1 to do
APRA Notification1 of 2 evidenced, 1 to do
Internal Audit1 of 3 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.

Art.20.1CPS 234 para 13argued against and upheld
Board Responsibility for Information Security

Approval of the measures sits with the management body itself, which stays liable for them.

Art.21.1CPS 234 para 15argued against and upheld
Information Security Capability

Requires technical, operational and organisational measures sized to the entity's exposure.

Art.21.3CPS 234 para 16argued against and upheld
Assessment of Related Party and Third Party Capability

Requires taking account of vulnerabilities specific to each direct supplier and its practices.

Art.21.2.dCPS 234 para 16argued against and upheld
Assessment of Related Party and Third Party Capability

Requires managing the security aspects of each direct supplier and service provider relationship.

Art.21.1CPS 234 para 17argued against and upheld
Active Maintenance of Capability Against Change

Proportionality is judged against the state of the art, which moves as threats change.

Art.21.2.aCPS 234 para 18argued against and upheld
Information Security Policy Framework

Requires the information system security policy set codifying protection decisions.

Art.21.2.aCPS 234 para 19argued against and upheld
Policy Direction to All Responsible Parties

Policies must state what is protected, who owns each decision and what happens on breach.

Art.21.2.iCPS 234 para 20argued against and upheld
Information Asset Classification

Asset management limb requires knowing what the entity has, who owns it and its classification.

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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