Prudential Standard CPS 230 Overview: Mastering Supply Chain and Operational Risk Management

June 21, 2025

Supply Chains at the Heart of CPS 230 Compliance

In the fast-evolving Australian financial services landscape, supply chains are critical to operational success. From cloud computing platforms to payment processing vendors, financial institutions rely heavily on third-party and fourth-party providers to deliver essential services. However, this dependence introduces significant risks, from vendor insolvencies to cyberattacks. The Australian Prudential Regulation Authority’s (APRA) Prudential Standard CPS 230 Operational Risk Management, effective July 1, 2025, places supply chain risk management at the forefront of operational resilience.

For financial services companies and risk professionals, CPS 230 is a game-changer, requiring robust oversight of supply chain partners to ensure continuity and compliance. As a leading supply chain consulting firm, Trace Consultants is uniquely positioned to help Australian financial institutions navigate these requirements. This article delves into CPS 230’s supply chain focus, its implications, and how our expertise can drive your compliance success.

Understanding CPS 230: A Supply Chain Perspective

CPS 230 replaces CPS 231 (Outsourcing) and CPS 232 (Business Continuity Management), introducing a comprehensive framework for operational risk management. It applies to all APRA-regulated entities, including authorised deposit-taking institutions (ADIs), insurers, and registrable superannuation entity (RSE) licensees. Non-significant financial institutions (non-SFIs) have until July 1, 2026, to comply with certain business continuity and scenario analysis requirements.

The standard’s supply chain focus is driven by the growing complexity of financial services supply chains, which now include:

  • Third-Party Providers: Vendors providing critical services like cloud storage, cybersecurity, or claims management.
  • Fourth-Party Providers: Subcontractors (e.g., data centre operators) that support primary vendors.
  • Global Dependencies: Offshore suppliers introducing geopolitical and regulatory risks.

CPS 230 aims to:

  • Mitigate risks from supply chain disruptions, such as vendor failures or cyberattacks.
  • Ensure financial institutions maintain operational resilience through robust supply chain oversight.
  • Enhance business continuity planning to safeguard critical services.

Why Supply Chain Risk Management is Critical

Modern financial institutions rely on intricate supply chains to deliver services efficiently. However, these supply chains are vulnerable to disruptions, including:

  • Vendor Insolvency: Financial collapse of a key supplier, such as a cloud provider, can halt critical operations.
  • Cybersecurity Breaches: Third-party providers are prime targets for cyberattacks, risking data breaches and service interruptions.
  • Supply Chain Complexity: Fourth-party providers introduce hidden risks that are challenging to monitor.
  • External Shocks: Geopolitical events, natural disasters, or regulatory changes can disrupt global supply chains.

CPS 230 mandates a proactive approach to managing these risks, ensuring financial institutions can maintain operations and protect customers, depositors, and policyholders during disruptions.

CPS 230’s Supply Chain Requirements for Financial Institutions

CPS 230 introduces specific requirements to strengthen supply chain risk management. Below are the key obligations for financial services companies and risk professionals:

1. Identifying Material Service Providers (MSPs)

Financial institutions must identify material service providers (MSPs)—vendors critical to operations or posing significant risks. Examples include:

  • Cloud computing and IT infrastructure providers.
  • Payment processing or credit assessment vendors.
  • Fund administration or claims management services.

Key Actions:

  • Create and maintain a register of MSPs, submitted to APRA annually by October 1, 2025, for the first submission.
  • Assess materiality based on APRA’s criteria and the institution’s risk profile.
  • Map fourth-party providers to identify hidden supply chain dependencies.

2. Conducting Supply Chain Due Diligence

Robust due diligence is required before engaging MSPs, particularly for offshore and fourth-party providers. This includes:

  • Evaluating financial stability through financial statements and credit reports.
  • Reviewing cybersecurity measures, such as SOC reports and penetration testing results.
  • Assessing business continuity plans to ensure suppliers can withstand disruptions.

Key Actions:

  • Develop a supply chain due diligence framework tailored to CPS 230.
  • Document findings to support contract negotiations and APRA compliance reviews.

3. Strengthening Supply Chain Contracts

Contracts with MSPs must include provisions to ensure supply chain resilience, such as:

  • Access to critical systems and data during disruptions.
  • Clear obligations for business continuity and disaster recovery.
  • Mechanisms for ongoing performance monitoring and audits.

Key Actions:

  • Update existing contracts to comply with CPS 230 by the earlier of their renewal date or July 1, 2026.
  • Notify APRA before entering material offshore arrangements or significant contract changes.

4. Building Supply Chain Continuity Plans

CPS 230 requires business continuity plans (BCPs) to address supply chain disruptions. This includes:

  • Defining tolerances for disruptions to critical services (e.g., maximum downtime for payment systems).
  • Developing contingency plans, such as alternative suppliers or software escrow arrangements, to mitigate vendor failures.
  • Conducting scenario analysis to test supply chain resilience.

Key Actions:

  • Obtain board approval for BCPs aligned with the institution’s risk appetite.
  • Report significant supply chain disruptions to APRA within 24 hours.

5. Governance and Supply Chain Oversight

The board is responsible for overseeing supply chain risk management, ensuring:

  • No gaps in responsibility for third- and fourth-party provider oversight.
  • Regular reviews of MSP performance and supply chain resilience.
  • Prompt remediation of material weaknesses identified through audits.

Key Actions:

  • Establish governance structures for supply chain risk management.
  • Conduct independent audits to verify CPS 230 compliance.

6. Managing Fourth-Party Supply Chain Risks

CPS 230 extends oversight to fourth-party providers, which are often critical to service delivery. For example, a cloud provider’s subcontractor for data storage could disrupt operations if not properly managed.

Key Actions:

  • Map fourth-party dependencies within the supply chain.
  • Include fourth-party risk assessments in due diligence and monitoring processes.

Implications for Australian Financial Institutions

CPS 230’s supply chain focus has significant implications for Australian financial institutions:

  • Increased Compliance Costs: Mapping complex supply chains, updating contracts, and implementing monitoring systems require substantial investment.
  • Enhanced Resilience: Robust supply chain management reduces the risk of disruptions, protecting customers and stakeholders.
  • Regulatory Scrutiny: APRA will conduct prudential reviews starting in 2025-2026, with ongoing supervision by 2027-2028, focusing on supply chain compliance.
  • Competitive Edge: Institutions that proactively manage supply chain risks can differentiate themselves as reliable, resilient partners.

How Trace Consultants Can Help

As a leading supply chain consulting firm, Trace Consultants is uniquely equipped to help Australian financial institutions achieve CPS 230 compliance. Our deep expertise in supply chain risk management and operations ensures your organisation is prepared for this transformative regulation. Here’s how we can support you:

1. Supply Chain Mapping and Gap Analysis

We conduct detailed supply chain audits to:

  • Identify MSPs and fourth-party providers critical to your operations.
  • Assess current supply chain practices against CPS 230 requirements.
  • Deliver tailored roadmaps to address gaps, leveraging APRA’s “Day One Checklist.”

2. Supply Chain Due Diligence Expertise

Our team provides end-to-end support for due diligence, including:

  • Developing frameworks to evaluate supplier financial stability, cybersecurity, and resilience.
  • Assessing risks from offshore and fourth-party providers.
  • Documenting findings to ensure compliance with APRA’s expectations.

3. Supply Chain Continuity Planning

We design robust BCPs tailored to your supply chain, including:

  • Contingency strategies, such as software escrow, to mitigate vendor insolvency risks.
  • Scenario analysis and stress testing to identify supply chain vulnerabilities.
  • Board-approved plans that meet CPS 230’s disruption tolerance requirements.

4. Supply Chain Governance and Training

We help establish effective governance structures for supply chain risk management, including:

  • Defining roles for board and risk teams in overseeing third- and fourth-party providers.
  • Providing training for risk professionals on CPS 230’s supply chain requirements.
  • Facilit Canadá independent audits to address weaknesses.

5. Technology-Enabled Supply Chain Management

Our expertise in governance, risk, and compliance (GRC) software streamlines CPS 230 compliance. We:

  • Implement tools to manage MSP registers, automate incident reporting, and monitor supplier performance.
  • Integrate supply chain risk management into your operational risk framework.

6. Ongoing Supply Chain Monitoring

Trace Consultants offers continuous support to ensure sustained compliance, including:

  • Regular reviews of supply chain resilience and MSP performance.
  • Updates to risk management frameworks as regulations evolve.
  • Preparation for APRA prudential reviews and audits.

With our specialised focus on supply chain risk management, Trace Consultants is your trusted partner for CPS 230 compliance, ensuring your supply chain is resilient and regulatory-ready.

Practical Steps for CPS 230 Supply Chain Compliance

To prepare for CPS 230, financial institutions should prioritise the following:

  1. Map Your Supply Chain: Identify all third- and fourth-party providers, focusing on those critical to operations.
  2. Strengthen Risk Frameworks: Integrate supply chain risk management into your operational risk policies.
  3. Update Supplier Contracts: Ensure agreements include CPS 230-compliant provisions for continuity and monitoring.
  4. Leverage GRC Tools: Use software to streamline supply chain oversight and compliance tasks.
  5. Engage Stakeholders: Align board, executive, and risk teams on supply chain obligations.
  6. Partner with Trace Consultants: Tap into our supply chain expertise to develop tailored compliance strategies.

Challenges and Opportunities in Supply Chain Risk Management

Challenges

  • Complex Supply Chains: Mapping and monitoring fourth-party providers is resource-intensive.
  • Compliance Costs: Investing in due diligence, contract updates, and GRC systems can strain budgets.
  • Tight Deadlines: The July 1, 2025, deadline requires swift action to achieve compliance.

Opportunities

  • Resilient Supply Chains: Robust risk management ensures continuity during disruptions.
  • Customer Confidence: Compliance demonstrates a commitment to protecting stakeholders.
  • Market Differentiation: Early adoption of CPS 230 principles positions institutions as leaders in resilience.

The Future of Supply Chain Risk Management

CPS 230 sets a new standard for supply chain risk management in Australia’s financial services sector. As supply chains become more complex and interconnected, proactive oversight is essential to mitigate risks and ensure resilience. APRA’s focus on third- and fourth-party providers aligns with global trends, positioning compliant institutions to thrive in an evolving regulatory landscape.

By partnering with Trace Consultants, financial institutions can turn CPS 230 compliance into a strategic advantage, building supply chains that are robust, reliable, and ready for the future.

Partner with Trace Consultants for Supply Chain Success

APRA’s Prudential Standard CPS 230 is reshaping how Australian financial institutions manage supply chain risks. By prioritising third- and fourth-party oversight, the standard ensures operational resilience and regulatory compliance. For financial services companies and risk professionals, CPS 230 is an opportunity to strengthen supply chains and build trust with stakeholders.

At Trace Consultants, our supply chain expertise empowers Australian financial institutions to achieve CPS 230 compliance with confidence. From mapping complex supply chains to implementing robust continuity plans, we provide end-to-end support to ensure your organisation is prepared for July 2025 and beyond.

Ready to transform your supply chain for CPS 230? Contact Trace Consultants today at www.traceconsultants.com.au to start your compliance journey. Let’s build a resilient supply chain together.