Regulatory Mandate: Why APRA’s CPS 231 Demands a Reassessment of Your Board Portal

The Australian Prudential Regulation Authority (APRA) has issued its new standard, CPS 231 Operational Risk (CPS 231), replacing the previous CPS 234. This is not merely an incremental update; it represents a fundamental uplift in the expectations placed upon all APRA-regulated entities -banks, insurers, and superannuation funds regarding the management of operational risk.

For the governing body, the Board of Directors, this new standard necessitates a critical reassessment of every technology and process used for oversight, including the seemingly benign Board Portal. The choice of board governance technology is now explicitly a matter of operational risk management.

The Core Mandate of CPS 231: Governance and Accountability

CPS 231 is designed to ensure that operational risk is managed effectively, with clear accountability and comprehensive controls across the entire business lifecycle. Two key requirements directly intersect with how a Board operates and consumes information:

1. Clear Allocation of Accountability

The new standard places significant emphasis on governance and accountability. The Board must establish, monitor, and enforce a clear operational risk management framework. For Directors, this means needing assurance that they can efficiently access and securely review risk reports, control assessments, and incident logs.

If a Board Portal relies on outdated security, lacks rigorous document controls, or presents information in a fragmented manner, the Board’s ability to discharge this accountability mandate is compromised. The technology must facilitate, not frustrate, comprehensive risk oversight.

2. Information Security and Resilience

While CPS 231 broadens the scope beyond information security (IS) alone, IS remains a critical component of operational risk. The standard demands that controls are implemented to ensure the confidentiality, integrity, and availability of critical systems and information.

Board papers containing highly sensitive commercial, financial, and risk data are arguably the most critical information assets an organisation holds. Sending these documents via insecure methods or storing them on consumer-grade cloud platforms constitutes a tangible operational risk failure under the new regime. Directors need confidence that the system hosting their governance materials meets Australian regulatory expectations for data sovereignty and encryption standards.

Why Board Portals Must Now Be Reassessed

Many regulated institutions adopted their current board portal solutions years ago. Those solutions may have met the criteria of previous standards, but CPS 231 demands a higher level of integrated security and transparent governance.

Risk 1: Audit Trail Deficiency

Under CPS 231, regulated entities must demonstrate the effectiveness of their controls. This requires a meticulous audit trail. A modern board portal must offer comprehensive logging that tracks not just whoaccessed a document, but when they accessed it, what annotations were made, and when approval was given. Systems that lack granular audit logs expose the institution to compliance risk.

Risk 2: Data Sovereignty and Security Posture

International board portal providers may store data offshore or operate under security frameworks that do not explicitly align with APRA’s specific regulatory demands. Local data centres and governance platforms built with an inherent understanding of Australian regulatory expectations can significantly de-risk this aspect of operational resilience. Organisations must query whether their current vendor’s security posture is merely adequate globally, or compliant locally.

Risk 3: Lack of Feature Agility for Risk Reporting

The reporting required by CPS 231 is dynamic and complex. A flexible board portal should be able to integrate risk registers and compliance dashboards directly into the governance workflow, rather than relying on static, exported PDFs. If the existing portal makes it cumbersome for Management to present holistic operational risk reports, it impedes the Board’s critical monitoring function.

The Path Forward: Choosing a Purpose-Built Solution

For APRA-regulated institutions, the time for inertia has passed. CPS 231 transforms the board portal selection from a mere IT preference to a regulatory compliance imperative.

Organisations are finding that dedicated platforms, such as Athena Board, offer a compelling alternative by focusing on the specific security, sovereignty, and administrative rigour required by Australian governance standards. These platforms often provide the necessary auditability and security features required by APRA without the complexities and prohibitive costs associated with some larger, international systems.

Compliance with CPS 231 requires the Board to be equipped with the most secure, efficient, and auditable tools available. Reassessing your board portal choice now is a proactive measure that underpins operational resilience and confirms your commitment to regulatory excellence.

ISO 27001: The Non-Negotiable Standard of Assurance

While APRA does not mandate a specific standard, ISO/IEC 27001, the international standard for information security management provides the globally recognised, auditable framework for meeting the security expectations of CPS 231.

For APRA-regulated entities, selecting an ISO 27001-certified board portal vendor is crucial for several reasons:

Systemic Rigour: ISO 27001 requires the vendor to establish, implement, maintain, and continually improve an Information Security Management System (ISMS). This provides assurance that the vendor’s security is systematic, not sporadic.
Trust and Due Diligence: During a CPS 231 compliance audit, the ability to demonstrate that the organisation’s critical governance platform operates under an independently certified security framework drastically streamlines the due diligence process. It is a demonstrable commitment to security excellence.
Data Handling and Business Continuity: ISO 27001 mandates best practices for asset management, access control, and robust business continuity planning all of which are essential components of operational resilience under CPS 231.

If your current board portal vendor cannot provide a current, certified ISO 27001 certificate covering the services they provide to you, it significantly elevates your compliance risk profile.

The Shift to Zero Trust Security

Traditional security relies on a perimeter defence, once inside the network, trust is granted. This approach is obsolete, particularly in a cloud-centric world. The modern, best-practice security model is Zero Trust, which operates on the principle: “Never Trust, Always Verify.”

For board portals, Zero Trust – such as in implemented with Athena Board – is vital because it addresses the inherent risks of internal access:

Granular Access Control: Zero Trust mandates that every user, device, and application requesting access to a board paper must be authenticated and authorised before access is granted, regardless of their location or network. This eliminates single points of failure.
The Power of Encryption: In a true Zero Trust architecture, sensitive documents remain encrypted both in transit and at rest. This is a critical requirement for securing confidential governance materials against sophisticated threats.

A board portal that natively incorporates Zero Trust principles, such as Athena Board, provides Directors with greater assurance that their sensitive discussions and documents are protected against compromise, thereby supporting the CPS 231 mandate for strong, resilient operational controls.

Is your current board portal adequately supporting your institution’s response to the heightened requirements of CPS 231 operational risk management? The cost of inaction is now demonstrably greater than the investment in governance technology upgrade.

Athena Board can help, contact us at sales@athenaboard.com.