Independent Technology Advisory for Financial Services
Financial services organisations face technology decisions under a regulatory overlay that most technology advisors do not fully understand. APRA's prudential standards, ASIC's guidance on digital assets and AI, and the Privacy Act obligations that apply to financial data create a context in which the wrong technology decision carries consequences well beyond budget overrun.
The technology governance expectations for APRA-regulated entities have increased substantially. CPS 234 sets explicit requirements for information security capability and board-level accountability. CPG 234 provides guidance on how those requirements apply in practice. APRA's focus on operational resilience and third-party risk management extends those expectations to vendor relationships and technology supply chains. Boards of financial services organisations are expected to understand and oversee technology risk at a level of depth that most governance structures have not yet reached.
AI adoption in financial services is accelerating, and the regulatory response is catching up. ASIC and APRA have both signalled that AI risk is within their supervisory scope. The use of AI in credit decisions, claims processing, fraud detection, and customer communication creates obligations around explainability, fairness, and human oversight that most AI governance frameworks in the financial sector have not yet addressed. Organisations that treat AI governance as a compliance checklist rather than a genuine risk management discipline are accumulating exposure.
Vendor selection and third-party risk management in financial services carry regulatory weight. APRA's third-party risk management requirements mean that the process of selecting and managing technology vendors is itself subject to regulatory scrutiny. Vendor proposals that look competitive on price and feature capability often carry risks in contractual terms, data handling, and exit provisions that are not visible without independent assessment.
Where we focus
APRA technology governance requirements
CPS 234 and operational resilience expectations require boards to demonstrate active oversight of information security and technology risk. Many governance structures are not yet calibrated to this standard.
AI governance in regulated contexts
AI use in credit, claims, fraud, and customer decisions creates explainability, fairness, and accountability obligations. Regulatory expectations are ahead of most organisations' governance frameworks.
Third-party and vendor risk
APRA's third-party risk management expectations require structured vendor assessment and ongoing oversight. Vendor selection processes that do not account for this regulatory context carry both delivery and compliance risk.
Microsoft 365 Copilot in regulated environments
Deploying AI tools in environments where data governance, access controls, and information classification are regulatory requirements requires assessment before deployment, not after.
Relevant services
AI Governance
AI governance frameworks designed for regulated financial services environments.
Technology Governance
Governance structures and decision rights aligned to APRA expectations.
Vendor & Procurement Advisory
Independent vendor evaluation with third-party risk assessment.
Information Protection Review
Information classification, DLP, and data governance for regulated data environments.
Common questions
How does APRA CPS 234 affect technology governance requirements?
CPS 234 requires APRA-regulated entities to maintain information security capability commensurate with the size, nature, and complexity of their operations, and to ensure that boards are informed of and accountable for information security risk. In practice, this means governance structures that give boards genuine visibility into technology and cyber risk, not just summary reporting. It also extends to third-party arrangements, requiring assessment and ongoing oversight of vendors who handle sensitive data or perform critical functions.
What does AI governance look like for a financial services organisation?
For APRA-regulated entities, AI governance needs to address accountability for AI decisions, explainability requirements for decisions that affect customers, human oversight mechanisms for high-risk AI applications, and ongoing monitoring of AI system performance and bias. It also needs to account for ASIC's expectations around disclosure of AI use to customers and APRA's focus on operational resilience. A governance framework that addresses these dimensions is substantively different from a general-purpose AI policy.
Can you support vendor selection under APRA's third-party risk requirements?
Yes. Vendor selection for financial services organisations needs to assess not only capability fit and commercial terms but also the vendor's security posture, data handling practices, contractual provisions for regulatory access and audit, and exit terms. Our vendor evaluation framework incorporates these requirements. We have no relationships with technology vendors, which means our assessment is not shaped by partnership incentives.
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