Case Study: CPS 230 Readiness Review for an International Insurer
THE CHALLENGE
An Australian branch of a major international insurer sought to ensure its operational risk management program was fully aligned with the Australian Prudential Regulation Authority (APRA)’s new Prudential Standard CPS 230 Operational Risk Management. With substantial operations in Australia and growing demands from regulators and stakeholders, the insurer was determined to demonstrate best-practice governance, readiness and resilience.
While the insurer had made good progress in its CPS 230 implementation project, it recognised the need for independent assurance that its project plan, governance structure and implementation progress met APRA’s evolving expectations. Key issues included:
- Verifying that the project plan covered all CPS 230 requirements (governance, risk identification, scenario analysis, business continuity, outsourcing, etc).
- Conducting a gap analysis of implementation progress—how much of the program was “done”, how much remained, and where controls and documentation still needed strengthening.
- Providing clear recommendations to management and the Senior Officer Outside Australia/ Board so that the program would not just comply, but embed operational risk capability across the entity.
OUR APPROACH
InConsult was engaged to lead a structured readiness review and gap-analysis engagement:
- We reviewed the insurer’s CPS 230 project plan and implementation status, examining governance, roles & responsibilities, risk identification and event reporting, outsourcing arrangements, scenario testing, business continuity and recovery.
- We conducted workshops with the Executive Team, Risk Team and operational risk owners to assess current maturity, identify gaps and validate that controls and documentation were aligned to CPS 230 requirements and expectations in Prudential Practice Guide CPG 230 Operational Risk Management.
- We delivered a detailed gap analysis report highlighting areas of strength and improvement – with defined actions, responsibilities and timing to close gaps and strengthen compliance.
- We supported senior management with a briefing summarising findings and recommendations, ensuring clear linkage between the review outcomes and the insurer’s strategic risk governance agenda.
OUTCOMES & BENEFITS
The Australian branch obtained clarity and confidence that its CPS 230 program was broadly on track and that major elements were well controlled.
The gap analysis enabled prioritisation of enhancements – particularly in relation to integrated risk reporting, incident reporting and investigation, and service provider monitoring program.
The executive gained improved assurance on the completeness of their CPS 230 compliance implementation program and a roadmap to full alignment with APRA obligations.
The insurer strengthened its operational risk governance, enabling resilient operations, improved regulatory readiness and increased stakeholder confidence.
The review transformed a solid implementation effort into a well-governed, strategically aligned CPS 230 program, providing the insurer assurance that it could operate with confidence in a demanding regulatory environment. InConsult’s independent review and actionable advice enabled the insurer to embed stronger operational risk management and momentum towards full regulatory alignment.
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This case study is drawn from a real-life engagement/project between InConsult and our client. While client details are not disclosed for commercial and confidentiality reasons, this case study is based on a real engagement and reflects genuine results and outcomes. Specific client references and project details can be shared with prospective clients during the proposal process.