APRA governance reforms are back in focus, with APRA opening consultation on proposed changes to CPS 510 Governance that will affect boards, senior executives and APRA-regulated entities across banking, insurance and superannuation.
After 25 years working alongside APRA-regulated entities, InConsult has seen regulatory expectations continue to evolve — from protecting information assets under CPS 234, to strengthening operational risk and resilience under CPS 230, and now to a renewed focus on governance maturity, board accountability and effective oversight through the proposed CPS 510 changes.
APRA released its governance consultation package on 16 June 2026. Submissions are open until 28 August 2026, with final standards and guidance expected in late 2026 and implementation expected from early 2028.
In Summary: What APRA’s CPS 510 Governance Reforms Mean
- APRA’s proposed CPS 510 changes aim to strengthen governance, board accountability, conflicts management and fit and proper requirements, while reducing duplication with the Financial Accountability Regime.
- The reforms are intended to create a more consistent governance framework across APRA-regulated industries and give boards greater flexibility to delegate lower-value prudential obligations where appropriate.
- For boards and senior leaders, the message is clear: governance needs to be effective, evidence-based and aligned to the organisation’s risk profile, strategy and accountability obligations.
APRA Governance Reforms: Why CPS 510 Is Changing
The proposed changes to CPS 510 form part of APRA’s broader push to strengthen governance practices while also streamlining regulatory requirements and reducing unnecessary duplication.
For boards and senior leaders, this is not simply another prudential standards update. It is another reminder that governance is central to risk management, operational resilience, performance and trust.
APRA has made it clear that many issues across regulated entities can be traced back to poor oversight, unclear accountability or weak challenge.
This is a familiar theme for boards and executives. Governance failures are rarely caused by the absence of a policy or committee. More often, they arise when roles are unclear, information is incomplete, challenge is not effective, or decisions are not adequately connected to risk appetite, customer outcomes, operational resilience and regulatory obligations.
APRA’s proposed CPS 510 governance reforms are designed to address these issues by raising expectations for boards and senior leaders, while also allowing them to focus more time and attention on the matters that are most important to financial soundness, operational resilience and member, policyholder and customer outcomes.
Ultimately, APRA is seeking greater governance maturity, not more process for its own sake, but clearer accountability, better information flows and stronger oversight so the right people are focused on the right risks at the right time.
What Are the Proposed CPS 510 Governance Changes?
The proposed changes to CPS 510 aim to consolidate and harmonise governance requirements across APRA-regulated industries. This includes combining several existing prudential standards into one cross-industry standard and setting more consistent minimum governance expectations for banks, insurers and superannuation trustees.
Key areas of change include:
- strengthening requirements for board governance, conflicts management and the fitness and propriety of directors and executives;
- reducing duplication with the Financial Accountability Regime where similar accountability reporting is already in place;
- improving flexibility by enabling boards to delegate certain lower-value prudential requirements where appropriate;
- aligning governance expectations with other relevant codes and regulatory regimes; and
- establishing a more consistent governance baseline across APRA-regulated entities.
This combination of stronger expectations and reduced duplication is important.
APRA is not only asking boards to do more. It is also seeking to remove some administrative burden so boards can focus on the areas where their oversight, judgement and challenge matter most.
How CPS 510 Links to Other Standards, CPS 230 and CPS 234
The proposed CPS 510 governance changes should not be viewed in isolation or stand alone.
CPS 234 sharpened expectations for information security. CPS 230 has lifted expectations for operational risk, business continuity, critical operations and third-party risk management. The proposed changes to CPS 510 now bring governance capability, accountability and oversight into sharper focus.
Together, CPS 510, CPS 230 and CPS 234 point to a more integrated prudential framework.
Boards and senior leaders are expected to understand how key risks are identified, managed, monitored and escalated, and how governance arrangements support effective decision-making before, during and after periods of stress.
This means governance frameworks need to be more than static documents. They must actively support the organisation’s ability to:
- identify and assess material risks;
- maintain effective controls;
- manage critical operations and material service providers;
- respond to disruptions;
- oversee information security and technology risks;
- challenge management reporting;
- monitor accountability across the organisation; and
- demonstrate that key decisions are supported by appropriate information and oversight.
For many APRA-regulated entities, the practical challenge will be ensuring that governance, risk, resilience, cyber, compliance and accountability frameworks are aligned rather than operating as separate programs of work.
What APRA Governance Reforms Mean for Boards
One of the most important themes in APRA’s proposed CPS 510 reforms is the quality of board oversight.
Boards cannot provide effective oversight without clear accountability and reliable information. They also need sufficient capability, independence of thought and time to challenge management constructively.
The proposed APRA governance reforms place renewed importance on:
- board and committee charters;
- delegation frameworks;
- board skills matrices;
- board and committee reporting;
- senior management accountability mapping;
- conflicts management processes;
- fit and proper assessments;
- board performance reviews; and
- succession and renewal planning.
The focus should be on whether these arrangements work in practice.
Do board papers clearly identify risk implications? Are material issues escalated at the right time? Have accountabilities been clearly understood across the first, second and third lines? Can conflicts be identified, assessed and managed consistently? Do performance reviews meaningfully support improvement?
These are the types of questions APRA-regulated entities should be asking now.
Board Tenure, Renewal and Governance Maturity
One of the more debated aspects of APRA’s governance reform has been board tenure and renewal.
APRA’s direction of travel reflects a concern that long tenure can affect independence, challenge and board renewal. At the same time, industry feedback has highlighted the value of experience, institutional knowledge and continuity — particularly in complex sectors such as superannuation, banking and insurance.
The issue should not be viewed as a simple choice between tenure and experience.
The more useful question is whether the board can demonstrate that its composition, capability and performance remain fit for purpose in the context of the entity’s strategy, risk profile, operating model and stakeholder obligations.
Good governance requires both continuity and renewal. Boards need directors who understand the organisation, but they also need diversity of thought, fresh perspectives and the confidence to challenge long-standing assumptions.
This is where governance maturity becomes critical.
A mature board can explain why its composition is appropriate, how it assesses performance, how it plans for renewal and how it ensures the right skills are available to oversee current and emerging risks.
What APRA-Regulated Entities Should Do Now
Although the proposed CPS 510 requirements are not expected to take effect until early 2028, entities should not wait for the final standard before taking action.
A practical starting point is to review current governance arrangements against APRA’s direction of travel and identify where targeted uplift may be required.
1. Review Governance Frameworks and Delegations
Review board, committee and management delegations to ensure they are current, clear and consistently applied. Boards should consider whether they are spending enough time on the most material strategic, financial, operational, technology, resilience and regulatory risks.
2. Assess Board and Committee Structures
Assess whether existing board and committee structures support effective oversight of risk, audit, technology, cyber, operational resilience, customer outcomes and compliance obligations. The structure should help the board focus on the right issues at the right level, not simply create additional reporting layers.
3. Update Board Skills and Renewal Planning
Update the board skills matrix to reflect the organisation’s current and emerging risk profile. This should include operational resilience, technology, cyber, data, artificial intelligence, third-party risk, regulatory change, customer outcomes and financial risk.
Board renewal planning should be evidence-based and linked to strategy, risk and future capability needs.
4. Strengthen Conflicts Management
Test whether conflicts are identified, recorded, escalated and managed in practice. This is particularly important for entities with complex group structures, related-party arrangements, outsourcing arrangements, representative governance models or multiple stakeholder interests.
5. Align Fit and Proper Processes with FAR
Review fit and proper processes alongside Financial Accountability Regime (FAR) obligations to identify duplication, gaps and opportunities to streamline accountability documentation. The objective should be to reduce unnecessary process while improving clarity over who is accountable for what.
6. Improve Board Reporting and Information Quality
Assess whether board reporting provides the right level of insight, escalation and analysis.
Boards need information that supports oversight and challenge, not simply more volume. Effective reporting should help directors understand key risks, emerging issues, control weaknesses, incidents, decisions required and the implications for customers, members, policyholders and the organisation.
7. Make Performance Assessment Meaningful
Ensure board, committee and individual director performance reviews are meaningful, evidence-based and linked to improvement, capability development and renewal planning. A performance review should not be a compliance exercise. It should help the board assess how effectively it is fulfilling its role and where governance practices can be improved.
8. Integrate CPS 510 with Other APRA Standards
Review how governance arrangements support risk management, capital management, operational resilience, information security, critical operations, service provider management and incident escalation. All standards should operate as connected parts of the prudential framework, not as separate compliance streams.
Frequently Asked Questions About APRA Governance Reforms
What are APRA’s proposed CPS 510 governance changes?
APRA’s proposed CPS 510 governance changes are intended to strengthen governance, board accountability, conflicts management and fit and proper requirements across banking, insurance and superannuation. The reforms also aim to streamline prudential obligations and reduce duplication with other regulatory requirements, including the Financial Accountability Regime.
When will APRA’s governance reforms commence?
APRA released its consultation package on 16 June 2026. Submissions are open until 28 August 2026. Final standards and guidance are expected in late 2026, with implementation expected from early 2028.
What should APRA-regulated entities do now?
APRA-regulated entities should review their governance framework, board and committee structures, delegation arrangements, conflicts management processes, fit and proper framework, board reporting and performance assessment processes. They should also assess how CPS 510 governance arrangements support CPS 230 and CPS 234 obligations.
How can boards prepare for APRA’s proposed CPS 510 changes?
Boards can prepare by reviewing whether their current governance arrangements are clear, current, proportionate and effective in practice. This includes assessing whether the board has the right skills, information, delegations, reporting, challenge mechanisms and accountability structures to oversee the organisation’s material risks.
Final Thoughts
APRA’s proposed governance changes are an opportunity for regulated entities to take stock.
For some organisations, the required uplift may be modest. For others, the changes may highlight deeper issues in accountability, board reporting, delegation, conflicts management, board renewal or governance effectiveness.
The better approach is to treat this period as an opportunity to review and strengthen governance arrangements before the final standard takes effect.
Strong governance is not about adding more process. It is about ensuring the right people, with the right information and accountability, are focused on the right risks at the right time.
How InConsult Can Help
Working with over 40 APRA-regulated entities, InConsult has a deep understanding of financial services and APRA’s prudential standards.
Since the implementation of the revised APRA Prudential Framework in 2001, we have helped APRA-regulated clients navigate regulatory change across governance, risk management, operational resilience, information security, internal audit and assurance.
As the APRA governance consultation progresses, regulated entities have an opportunity to take stock early.
A practical review of current governance arrangements can help boards and executives understand how well their frameworks align with APRA’s direction of travel — and where targeted improvements may strengthen oversight, accountability and decision-making.
If you have any questions, or would like to understand how InConsult can assist with a governance review, CPS 510 gap assessment or prudential standards uplift, contact us to discuss your needs.