CPS 230 governs the outcome. Your agent is inside it.
A disruption to a critical operation outside tolerance starts a 24-hour clock on your notification to APRA (para 41 (opens the standard at apra.gov.au in a new tab)). If an agent ran part of that operation, the account you file has to cover what the agent did.
Written for APRA-regulated investment managers and super funds. If you would rather start from your own operation than from the standard, the twelve-question worksheet asks the same thing from the other end.
01, standards/policy-packs/packs/apra-cps/sources/cps-230.txt, para 35(c), retrieved 2026-08-03
Investment management is named, not implied.
For an RSE licensee, CPS 230 names investment management and fund administration as critical operations. Not as an example. As a minimum classification, at para 35 (opens the standard at apra.gov.au in a new tab), unless the entity can justify otherwise.
That settles the scope. What it leaves open is the part of that operation an agent now runs, and whether your evidence reaches it.
02, standards/policy-packs/packs/apra-cps/sources/cps-230.txt, paras 28 and 29, retrieved 2026-08-03
Testing a control means testing what it stopped.
para 28 (opens the standard at apra.gov.au in a new tab) requires you to design internal controls, implement them and embed them, so that they mitigate operational risk in line with your risk appetite. Designing them is not the end of it. para 29 (opens the standard at apra.gov.au in a new tab) requires you to monitor, review and test those controls for design and operating effectiveness, at a frequency commensurate with the materiality of the risks being controlled, to report the results to senior management, and to rectify the gaps in a timely manner.
A control earns its place by stopping something. The events that matter therefore include the ones that never happened. A control that prevented an action has to be able to show it prevented it.
para 31 (opens the standard at apra.gov.au in a new tab) asks the same of the events themselves: incidents and near misses identified, escalated, recorded and addressed in a timely manner. An agent that did something unintended and left a debug line has not been identified, escalated, recorded or addressed. It has been logged.
You have 24 hours to explain what the agent did.
para 41 (opens the standard at apra.gov.au in a new tab) requires you to notify APRA as soon as possible, and not later than 24 hours after a disruption to a critical operation outside tolerance. The notification covers the nature of the disruption, the action taken, the likely impact and the timeframe for returning to normal.
para 32 (opens the standard at apra.gov.au in a new tab) is a separate obligation on a separate trigger: 72 hours for an operational risk incident likely to have a material financial impact, or a material impact on the entity's ability to maintain its critical operations.
Unsequenced logs across several systems will not reconstruct an agent's behaviour inside a day. Whatever you send APRA is written from the record you already hold on the morning it is due.
04, standards/policy-packs/packs/apra-cps/sources/cps-230.txt, paras 48, 49, 54 and 59, retrieved 2026-08-03
Your provider's agent is still your evidence problem.
para 48 (opens the standard at apra.gov.au in a new tab) requires you to keep a register of material service providers and to manage the material risks of using them. para 49 (opens the standard at apra.gov.au in a new tab) sets the floor for what counts: for an RSE licensee it names fund administration, custodial services and investment management, and for every regulated entity it names core technology services.
para 59 (opens the standard at apra.gov.au in a new tab) puts senior management on the receiving end of ongoing monitoring, with reporting commensurate with the nature and usage of the service. And para 54 (opens the standard at apra.gov.au in a new tab) requires the formal agreement to let APRA reach the documentation, data and other information related to the provision of the service.
When a provider runs an agent inside a process you rely on, the evidence question is yours, asked of a system you do not own, with a right of access already written into the agreement.
05, packages/protocol/vectors
Remove a record and the chain says so.
Each record is signed at the point the action happens and carries the hash of the record before it. Removing one, reordering two, or editing a payload after the fact breaks the chain, and the break is detectable by anyone holding the stream and the public keys.
The verifier that detects it is a separate implementation, built from source by whoever is checking, and it does not call NOMARK to reach a verdict. The corpus it is validated against ships 9 categories of invalid stream, each with its own vectors:
- broken-chain
- expired-key
- replayed-record
- sequence-gap
- signature-mismatch
- suppressed-stream
- tampered-payload
- truncated-tail
- unknown-key
The category names and their count are read from the protocol corpus at build. You can run the verifier against them yourself, offline, on a machine you control.
06, standards/policy-packs/packs/apra-cps, node standards/policy-packs/tools/pack-load.cjs --pack apra-cps --json
Find your clause, and the gate that enforces it.
Every clause on this page links to the paragraph in APRA's own text and carries the date that paragraph was read. The register does the same for enforcement. Each row names the clause, the pinpoint, the gate that enforces it, the chain and step that gate sits in, the file it lives in, its state, and the date the clause text was read from the instrument on disk. This is the CPS 230 view of pack 0.1.0, which carries 17 mapped controls across its instruments in total.
| Control | Obligation | Clause | Enforced by | State | Clause read |
|---|---|---|---|---|---|
| CPS 230 | |||||
| CPS230-BCP (opens apra.gov.au in a new tab) | Business continuity plan and testing | paras 33(c) and 42 (opens apra.gov.au in a new tab)para 42 | gate-investment-certifyinvestment-ops / certifypackages/method/chains/gates/investment-certify.control.json | VERIFIED | 2026-08-03 |
| CPS230-CRITOPS-IDENT (opens apra.gov.au in a new tab) | Identification of critical operations | para 33(a) (opens apra.gov.au in a new tab) | gate-session-integritycode-build / verifypackages/method/chains/gates/session-integrity.control.json | VERIFIED | 2026-08-03 |
| CPS230-INCIDENT-MGMT (opens apra.gov.au in a new tab) | Operational risk incident and near-miss management | para 31 (opens apra.gov.au in a new tab) | gate-risk-premorteminstinct-groom / inventorypackages/method/chains/gates/risk-premortem.control.json | VERIFIED | 2026-08-03 |
| CPS230-NOTIFY (opens apra.gov.au in a new tab) | Notification to the issuing authority | para 32 (opens apra.gov.au in a new tab) | gate-owner-approvalclient-delivery / alignpackages/method/chains/gates/owner-approval.control.json | VERIFIED | 2026-08-03 |
| CPS230-OPRISK-CONTROLS (opens apra.gov.au in a new tab) | Operational risk controls and effectiveness assessment | paras 28-29 (opens apra.gov.au in a new tab) | gate-build-verifyinstinct-groom / groompackages/method/chains/gates/build-verify.control.json | VERIFIED | 2026-08-03 |
| CPS230-SPM-MATERIAL (opens apra.gov.au in a new tab) | Material service provider register | paras 48 and 50 (opens apra.gov.au in a new tab)para 48 | gate-ops-admin-fileops-admin / filepackages/method/chains/gates/ops-admin-file.control.json | VERIFIED | 2026-08-03 |
| CPS230-SPM-MONITOR (opens apra.gov.au in a new tab) | Ongoing monitoring of material service providers | para 59 (opens apra.gov.au in a new tab) | gate-resource-verifyresource-verify / reverifypackages/method/chains/gates/resource-verify.control.json | VERIFIED | 2026-08-03 |
| CPS230-TOLERANCE (opens apra.gov.au in a new tab) | Tolerance levels for disruption | paras 21(b) and 37 (opens apra.gov.au in a new tab)para 37 | gate-ship-attestationcode-build / ship-readypackages/method/chains/gates/ship-attestation.control.json | VERIFIED | 2026-08-03 |
Instrument and clause references are DRAFTED until a row recomputes VERIFIED — a clause number in an UNVERIFIED-DRAFT row has not been read from the issuing authority's text.
A row reads VERIFIED only when the quote still matches the source on disk, and the loader that checks it runs in the build. This page carries the CPS 230 rows. The rest of the pack, instrument by instrument, is on the full control register.
07, tasks/prd-decision-assurance-v0.1.md
What is not finished.
The collector is implemented for one reference workload. The certification registry is specified and not built. What remains open is below, in the capability's own words.
Collector scope: Decision Assurance direct-instrumentation reference workload; generic MCP stdio interposition, federation, high availability and managed key infrastructure remain open.
Every other open item is on the assessment register with the queue item that would clear it.
Map the gap before an assessor does.
You leave with a gap map you own, in your own terms, covering the operations you name. It is not a proposal. You keep it whether or not you go further.
45 minutes with your risk or investment operations lead. We walk your CPS 230 critical operations, mark where agents act, and name what evidence exists today.
Email is faster than a calendar link. A short note describing the operation tells us more than a meeting request.