Financial firms face mounting pressure to tighten their cyber security. Regulators, customers, and the media are all watching. Cyber risks are business risks, and for Australian Financial Services (AFS) licensees, staying ahead of those risks means staying compliant with ASIC's evolving requirements.
ASIC has been increasingly clear that it views cyber security as a board-level governance issue, not just an IT department problem. Their enforcement actions against financial firms for cyber security failures have sent a strong signal to the industry: compliance is no longer optional, and "we were trying" is not an adequate defence.
What ASIC Expects
ASIC's cyber security expectations for AFS licensees are articulated through guidance documents, enforcement actions, and the broader obligations of the Corporations Act. Key expectations include:
- Board and senior management accountability for cyber risk governance
- Documented cyber security policies and procedures that are actually implemented
- Regular testing of cyber security controls (penetration testing, vulnerability assessments)
- Incident response plans that are tested and maintained
- Third-party risk management: your suppliers' security posture affects yours
- Timely breach notification to ASIC and affected customers
APRA CPS 234 for APRA-Regulated Entities
For APRA-regulated entities (banks, insurers, superannuation funds), CPS 234 sets mandatory requirements for information security capability, control testing, and notification. Non-compliance carries significant regulatory consequences.
The Practical Response
Financial firms at every scale need a structured approach to cyber compliance: documented policies that are actually implemented, technical controls that are regularly tested, and the evidence trail to demonstrate compliance when ASIC or APRA come asking.
Our vCISO service is designed specifically for this situation: providing the security leadership and governance expertise that ASIC and APRA expect, at a cost that's appropriate for your scale.