APRA CPS 230 — Effective 1 July 2025 — Australian Banking, Insurance & Superannuation

APRA CPS 230 Evidence Pack:
MSP Register & Compliance Evidence at $49/month

APRA CPS 230 requires every Australian bank, insurer, and superannuation fund to maintain a Material Service Provider register, ensure all vendor contracts include 7 mandatory clauses, and submit annual compliance evidence to APRA. VendorAuditly generates a one-click CPS 230 Evidence Pack — the only SMB-priced tool that does this, at 25× less than Gatekeeper.

What CPS 230 requires in plain terms
APRA CPS 230 requires every regulated entity — banks, insurers, and super funds — to identify which vendors are “Material Service Providers,” ensure their contracts contain 7 specific clauses, and submit a formal MSP register to APRA annually. Vendors supplying these entities must now be able to prove CPS 230 readiness or risk being dropped. The pre-existing contract remediation deadline is 1 July 2026. Annual register submission is due October 2026.

Who needs a CPS 230 evidence pack

Two types of organisations need CPS 230 compliance evidence

CPS 230 creates compliance obligations on both sides of the banking vendor relationship. VendorAuditly serves both — but the most urgent buyer is Mode B.

Mode A — Regulated Entity

Banks, insurers & super funds

If you are an APRA-regulated entity, CPS 230 requires you to maintain a documented Material Service Provider register, review every vendor contract for the 7 mandatory clauses, and submit to APRA annually. You need a tool that builds and exports this register in APRA’s required format.

  • MSP register matching APRA April 2026 template (11 fields)
  • 7-clause contract compliance status per vendor (RAG)
  • One-click PDF for APRA supervisory review
  • CSV export for annual register submission
Mode B — Primary ICP — Vendor to Regulated Entity

Fintechs, SaaS & payment companies selling to Australian banks

If you supply an APRA-regulated bank, insurer, or super fund, your client now has a legal obligation to certify you as a compliant service provider — or drop you. Fintechs are already being dropped. You need a CPS 230 Supplier Readiness Pack: a structured document you complete once and share with every banking client that asks.

  • 9-section self-certification covering BCP, security, data handling
  • AI usage disclosure (required per APRA April 2026 AI letter)
  • Sub-contractor / fourth-party disclosure register
  • Contract readiness attestation for all 7 mandatory clauses
  • APRA access rights confirmation

Curium CEO (Insurtech Australia board member): “Some underwriting agencies are being told — not that there’s anything wrong with them — but that [APRA-regulated entities] don’t want to handle smaller underwriting agencies.” The compliance burden of certifying non-compliant vendors is leading regulated entities to drop SMBs. A Supplier Readiness Pack is now a commercial survival document.


APRA CPS 230 requirements

What CPS 230 requires — and what APRA checks

CPS 230 replaced CPS 231 (Outsourcing) and CPS 232 (Business Continuity) from 1 July 2025. It is a cross-industry standard applying to all ~300+ APRA-regulated entities across banking, insurance, and superannuation.

Para 36 — MSP Identification

Material Service Provider test

A vendor is material if the entity relies on it to undertake a critical operation, OR the arrangement exposes the entity to material operational risk. Either criterion alone is sufficient. Mandatory categories — risk management, core technology, internal audit — are automatically material for all entity types regardless of size.

~300+ APRA entities in direct scope
Para 54–58 — Contract Clauses

7 mandatory contract clauses

Every material arrangement must include: service scope & SLAs, rights & liabilities, legal & compliance obligations, subcontracting notice/consent, subcontractor liability, force majeure, and termination & exit rights. APRA access rights for documentation and on-site visits must also be included. Missing any clause is a reportable non-compliance.

Deadline: 1 July 2026 for pre-existing contracts
Annual submission — October 2026

MSP register submission to APRA

APRA requires a formal register submission annually using the April 2026 official template (11 fields per vendor). The register must trace each vendor to a specific critical operation with tolerance levels. First submission was October 2025 — the next is October 2026. APRA checks for linkage between critical operations and the MSPs that support them.

April 2026 AI Letter — Expanded scope

AI vendor supply chain mapping

APRA’s April 2026 AI governance letter requires regulated entities to map their full AI supply chain including foundation models embedded within vendor products. Many AI vendors now meet the MSP threshold. Five additional contract clauses are required for AI vendors: model update notices, data handling change notices, AI incident triggers, termination/portability, and AI audit rights.

Board obligations

Board approval and evidence trail

Boards must approve the service provider management policy, business continuity plan and tolerance levels, and receive periodic risk and performance reporting on MSPs. APRA supervisors expect a board-level evidence trail — not just policies. Auditors trace controls end-to-end from policy through to evidence artefacts.


CPS 230 Para 54–58

The 7 mandatory contract clauses — and the AI overlay

Every material service provider agreement must contain all 7 of these clause areas. APRA supervisors check for completeness. Missing any clause in a material arrangement is a non-compliance finding. Pre-existing contracts must be remediated by 1 July 2026.

Service scope and SLAs

Defined services with measurable performance standards. Establishes what is in scope, expected service levels, and how performance is measured and reported.

Para 54

Rights, responsibilities, liability & audit access

Covers data ownership and control, dispute resolution, indemnity, and rights for the regulated entity (and APRA) to conduct audits and on-site visits at the service provider.

Para 55

Legal and compliance obligations

Ensures the regulated entity can continue meeting its prudential and legal obligations regardless of vendor circumstances. Must survive insolvency, regulatory change, and operational failure of the vendor.

Para 55

Subcontracting notice and consent

The service provider must notify and obtain consent before engaging material subcontractors (fourth parties). The regulated entity must maintain visibility into the fourth-party risk chain.

Para 56

Subcontractor liability

The service provider remains liable for failures by their own subcontractors. The regulated entity must not be left exposed by fourth-party failures that the direct vendor allows to pass through.

Para 57

Force majeure

Protections for unforeseen disruptions, linked to business continuity obligations and APRA’s tolerance level requirements. Must define what constitutes force majeure and what obligations continue regardless.

Para 57

Termination, exit rights & data portability

Must cover full termination rights, partial termination, data portability, data return and deletion, exit assistance, and transition timelines. Allows the regulated entity to exit without operational disruption.

Para 58

AI clause overlay — 5 additional requirements

Required for any vendor using AI in service delivery (APRA April 2026 AI governance letter): model update notices, data handling change notices, AI incident triggers, AI termination/portability rights addressing model lock-in, and AI audit/inspection rights covering AI system behaviour.

AI Letter 2026

How VendorAuditly helps

CPS 230 compliance without a compliance team

VendorAuditly is the only SMB-priced tool with a built-in APRA CPS 230 Evidence Pack. No enterprise contract, no implementation project, no $1,245/month Gatekeeper subscription.

1

MSP classification wizard

Walk through the CPS 230 Para 36 materiality test vendor by vendor. Select the critical operation each vendor supports (payments, claims, fund administration, core technology). VendorAuditly saves the materiality rationale for each vendor — the documented basis APRA requires when you can’t classify a vendor as material.

  • Para 36 two-criteria test (critical operation OR material operational risk)
  • Mandatory category auto-flagging (risk management, core technology, internal audit)
  • Materiality rationale saved per vendor for annual review
  • Entity-type specific critical operation dropdown (ADI, insurer, RSE)
2

7-clause contract compliance checker

For each material service provider, track which of the 7 mandatory clause areas are present, partial, or missing. The RAG status dashboard shows your clause compliance across all MSPs at a glance. AI-flagged vendors automatically surface the additional 5 AI clause requirements from the April 2026 APRA AI governance letter.

  • Per-vendor 7-clause checklist with complete / partial / missing status
  • AI vendor sub-checklist (5 AI-specific clauses)
  • Fourth-party sub-contractor disclosure tracking
  • APRA access rights confirmation field
3

One-click CPS 230 Evidence Pack PDF

Generate a complete, APRA-submission-ready evidence pack in a single click. The 6-page PDF contains everything an APRA supervisor or internal auditor expects to see: MSP register with materiality classifications, contract clause compliance status, AI vendor supply chain map, fourth-party dependency register, and a board-level statement of compliance with signature block.

  • MSP register — APRA April 2026 template format
  • Contract clause compliance RAG per vendor
  • AI vendor supply chain mapping (April 2026 APRA AI letter)
  • Board summary with outstanding gaps and open actions
  • Statement of compliance with signature block
4

Vendor questionnaire for fourth-party disclosure

Send CPS 230-aligned questionnaires to your material service providers to capture sub-contractor disclosures, BCP capabilities, and security control evidence. Questionnaire responses are timestamped and stored per vendor, providing the due diligence evidence trail APRA supervisors look for.

5

Already have DORA, NIS2, SOC2, ISO 27001 & HIPAA evidence packs

VendorAuditly is the only vendor risk tool with evidence packs for DORA, NIS2, APRA CPS 230, SOC2, ISO 27001, and HIPAA — all at $49/month. If you operate across jurisdictions — UK, EU, US, and Australia — you can generate regulatory evidence for all of them from a single vendor register, without switching tools.


APRA April 2026 AI letter

The AI expansion — who it affects and why it matters now

APRA’s April 2026 AI governance letter permanently expanded CPS 230 scope. Any vendor delivering AI-enabled services — even if they call themselves a “data platform” or “analytics tool” — may now be a Material Service Provider.

Who is affected

Which vendors now need the AI clause overlay

Any vendor that uses OpenAI, Anthropic, Google Gemini, Microsoft Copilot, AWS Bedrock, or any foundation model in their service delivery is now subject to additional CPS 230 contract requirements. This includes “non-AI” vendors that have added AI features to their products. APRA found this opacity to be the biggest identified gap in supervised entities — “AI embedded in vendor platforms with opaque upstream dependencies.”

Ask every vendor: “Do any components of your service use AI or foundation models?”
The concentration risk problem

OpenAI and Anthropic as implicit fourth parties

When multiple vendors in your MSP register all use OpenAI, a single OpenAI outage becomes a systemic concentration risk across your critical operations. APRA requires regulated entities to actively manage this concentration and — where substitution from an AI provider is not credible — document the fact and name compensating controls. This is now an APRA examination question.

What APRA expects

The evidence APRA supervisors look for on AI vendors

APRA expects: a full map of AI vendors and their foundation model dependencies, concentration risk assessment across the AI supply chain, upgraded contracts with the 5 AI-specific clauses, tested substitution/fallback plans for AI providers, and documented compensating controls where substitution is not credible. The VendorAuditly AI vendor section in the CPS 230 Evidence Pack captures and evidences all of this.


The pricing reality

Gatekeeper $1,245/month vs VendorAuditly $49/month — 25× price gap

Gatekeeper is the cheapest named CPS 230 tool with real features. Every other option is enterprise-only with no public pricing. VendorAuditly generates the same MSP register and evidence pack at $49/month — the only SMB option in the market.

📅
Gatekeeper / Enterprise tools
Cheapest option with CPS 230 features
MSP register✓ Yes
7-clause checker✓ Yes
Evidence pack PDF✓ Yes
AI vendor mappingPartial / not confirmed
Other frameworks✕ No DORA/NIS2/SOC2
Monthly cost$1,245/month minimum
Annual cost$14,940/year minimum
✓
VendorAuditly
APRA CPS 230 + 5 other frameworks
MSP register✓ Yes
7-clause checker✓ Yes
Evidence pack PDF✓ One click
AI vendor mapping✓ April 2026 AI letter
Other frameworksDORA, NIS2, SOC2, ISO 27001, HIPAA
Monthly cost$49/month
Annual cost$588/year

The 25× price gap is structural: enterprise tools are built for compliance teams at large regulated entities. VendorAuditly is built for the ops manager or COO at a 20–200 person company who needs to prove compliance without hiring a consultant. Compare all vendor risk management software →


Common questions

APRA CPS 230 — FAQ

What is APRA CPS 230?
APRA CPS 230 (Operational Risk Management) replaced CPS 231 (Outsourcing) and CPS 232 (Business Continuity) from 1 July 2025. It applies to all APRA-regulated entities — banks (ADIs), general and life insurers, private health insurers, and RSE licensees (superannuation trustees) — approximately 300+ entities. It requires a formal Material Service Provider management programme including an annual MSP register submission to APRA.
Do I need to comply with CPS 230 if I’m a vendor supplying an Australian bank?
Not directly — CPS 230 obligations fall on the regulated entity (the bank or insurer). But your banking clients now have a legal obligation to certify that their material service providers are compliant. If you can’t provide CPS 230 compliance evidence, they may classify you as a risk and drop you. This is already happening — smaller underwriting agencies and fintechs are being dropped because regulated entities can’t certify non-compliant vendors. A CPS 230 Supplier Readiness Pack is the evidence document your clients need from you.
What is the CPS 230 deadline for existing vendor contracts?
CPS 230 took effect 1 July 2025 for new arrangements. For pre-existing contracts, the requirements apply from the earlier of: (a) the contract’s next renewal date, or (b) 1 July 2026. This is a hard cutoff — APRA has confirmed it is not moving. Any pre-existing vendor contract not renewed since July 2025 must be remediated to include all 7 mandatory clauses by 1 July 2026. Annual MSP register submission to APRA is due October 2026.
What is a Material Service Provider under CPS 230?
Under CPS 230 Para 36, a service provider is material if: (1) the regulated entity relies on it to undertake a critical operation, OR (2) the arrangement exposes the entity to material operational risk. Either criterion alone is sufficient. Some categories are automatically (mandatorily) material: risk management, core technology services, and internal audit for all entities; plus payments, claims, fund administration for specific entity types. You cannot argue a mandatory category is non-material without documented rationale approved by senior management.
What is the APRA CPS 230 annual register submission?
APRA requires all regulated entities to submit a Material Service Provider register annually — first due 1 October 2025, then annually thereafter (next: October 2026). The register must match APRA’s April 2026 official template and include 11 fields per vendor: arrangement ID, service provider name, services description, critical operation supported, tolerance levels, materiality classification with rationale, SLA obligations, accountable executive, fourth-party dependencies, and NTSP exempt flag. VendorAuditly exports this register in the correct format in one click.
What is a CPS 230 evidence pack?
A CPS 230 evidence pack is a structured PDF document demonstrating a regulated entity’s compliance with its material service provider management obligations — or a vendor’s readiness to meet those obligations for their regulated clients. “Evidence pack” is the term practitioners use (Adventum Legal, InfoTrust): “service providers should plan to create an annual evidence pack” covering operational resilience, control effectiveness, security, and BCP capability. VendorAuditly generates this pack in one click at $49/month.
How does the APRA April 2026 AI letter affect CPS 230 compliance?
APRA’s April 2026 AI governance letter requires regulated entities to map their full AI supply chain, actively manage AI concentration risk, and upgrade AI vendor contracts with 5 additional clause requirements. Many AI vendors now meet the CPS 230 MSP materiality threshold — meaning they must be in the register and their contracts must include both the 7 standard clauses and the 5 AI-specific clauses. APRA identified “AI embedded in vendor platforms with opaque upstream dependencies” as the biggest gap found in supervised entities.
APRA CPS 230 — MSP register & evidence pack

Prove CPS 230 compliance before your banking clients ask

MSP register, 7-clause compliance tracker, AI vendor map, and one-click evidence pack — at $49/month. 25× cheaper than Gatekeeper.

No credit card required. Set up in under an hour.