Financial Services
When a breach hits a super fund or a bank, the damage isn't just financial — it's the end of trust
Australia’s financial services sector holds more personally sensitive data per institution than almost any other industry: retirement savings, credit records, insurance histories, tax file numbers. That makes it a persistent, high-value target for both organised cybercriminals and state-sponsored actors. In April 2025, coordinated credential stuffing attacks struck multiple major superannuation funds simultaneously — AustralianSuper, Rest, Insignia Financial and Australian Retirement Trust among them — compromising thousands of member accounts and triggering urgent regulatory contact from APRA and the ACSC. The attacks were neither novel nor unpredictable; they succeeded because known exposures had not been closed.
Orro works with Australian banks, insurers, superannuation trustees and fintechs to build the security posture, operational resilience and network infrastructure that APRA, ASIC and regulators increasingly expect — and that customers and members now demand.
Average cost of a data breach for Australian financial services organisations in 2024 — the second-highest of any Australian industry
Finance sector ranking for data breaches across all Australian industries in 2024 — consistently in the OAIC’s top five sectors every reporting period.
OAIC Notifiable Data Breaches Report, July–December 2024
Date APRA CPS 230 took effect — mandating critical operations identification, disruption tolerance thresholds, scenario testing and material service provider registers across all banks, insurers and superannuation trustees
APRA CPS 230 Operational Risk Management
ASD cyber threat notifications to Australian entities in FY2024–25 — an 83% increase year-on-year, with critical infrastructure entities notified over 190 times (up 111%)
ASD Annual Cyber Threat Report 2024–25
The financial services cyber threat landscape in Australia
Australia’s financial services sector sits at the intersection of high data value, critical operational dependency and an increasingly aggressive threat environment. The sector encompasses institutions that Australians trust with their most sensitive financial lives: retirement savings, credit records, mortgage details, insurance histories and tax file numbers. That concentration of value makes it a persistent, high-priority target for financially motivated cybercriminals, state-sponsored actors pursuing economic intelligence, and increasingly sophisticated organised criminal networks operating across borders.
Why the financial services sector is targeted:
Financial services organisations hold a uniquely attractive combination of assets. Customer financial data can be monetised directly through account takeover and fraud. Personally identifiable information — names, dates of birth, tax file numbers, bank account details — commands premium prices on criminal marketplaces and enables follow-on identity fraud at scale. Payment systems and settlement infrastructure offer direct access to funds. And for state-sponsored actors, intelligence on capital flows, investment positions and institutional financial health carries strategic value entirely separate from financial gain.
The sector’s complexity compounds these risks. A mid-tier bank or super fund may depend on dozens of third-party technology and service providers — core banking platforms, payment processors, identity verification services, cloud hosting providers, managed security vendors — each of which represents a potential entry point. APRA’s introduction of CPS 230 in 2025, with its explicit requirements around third-party and material service provider risk, reflects regulators’ growing recognition that the supply chain is now as important as the perimeter.
The April 2025 super fund attacks — and what they revealed:
In late March and early April 2025, a coordinated series of credential stuffing attacks struck multiple major Australian superannuation funds in rapid succession. AustralianSuper, Rest, Insignia Financial, Hostplus and Australian Retirement Trust all reported suspicious activity, with approximately 600 AustralianSuper member accounts compromised and AU$500,000 stolen from four accounts. Rest’s CEO shut down the member portal immediately and launched incident response protocols. APRA and ACSC intervened directly, contacting fund boards about authentication control expectations.
The attacks were notable not for their technical sophistication, but for their effectiveness against known, addressable weaknesses. Attackers used stolen credentials from unrelated prior breaches, purchased from criminal marketplaces, to test access against super fund portals using automated bots — a technique that would have been blocked by mandatory multi-factor authentication. The incidents reinforced a pattern visible across the OAIC’s breach data: the finance sector continues to report high volumes of breaches attributable to compromised credentials and phishing, not novel zero-day exploits. Most preventable breaches succeed because exposure has not been closed.
The structural technology challenge:
Financial services IT infrastructure is characterised by complexity, legacy burden and a continuous modernisation tension. Major banks and insurers maintain core systems built across decades, with integration layers, middleware and cloud migrations layered on top. Superannuation funds have undergone rapid digital uplift to meet member expectations for self-service account management — often outpacing the security architecture designed to protect those new digital channels. Regional banks, customer-owned banks and insurers frequently operate with lean technology teams responsible simultaneously for daily operations, compliance uplift, cloud migration and incident response.
Branch network infrastructure introduces additional exposure. Payment terminals, ATMs, access control systems and customer-facing digital kiosks are increasingly networked into corporate infrastructure — creating convergence points that blur traditional security perimeters. A compromise of branch network infrastructure is no longer just an operational disruption; it is a potential entry point into broader payment and data systems.
The pace of digital banking adoption has accelerated these pressures. Customers now expect real-time payments, 24/7 mobile banking and seamless omnichannel service. Outages are newsworthy. A payments failure or prolonged application downtime carries immediate reputational and regulatory consequences — which creates pressure on operations teams to prioritise availability, sometimes at the cost of the security architecture upgrades that would reduce exposure.
Third-party and supply-chain risk:
APRA’s CPS 230 framework reflects the reality that financial institutions’ operational resilience is only as strong as their material service providers’. Core banking platform vendors, cloud hyperscalers, managed security providers, payment processors and software-as-a-service platforms each represent a risk concentration point. An institution may have excellent internal controls and still suffer a significant incident via a compromised vendor. The requirement under CPS 230 to maintain and submit a material service provider register to APRA, assess downstream provider risks, and demonstrate that critical operations can continue through vendor disruption has elevated third-party risk from a compliance checkbox to a sustained operational discipline.
Regulatory and compliance obligations for Australian financial services
APRA Prudential Standard CPS 234 — Information Security
Governing body
Australian Prudential Regulation Authority — apra.gov.au/information-security
What it requires
Maintenance of an information security capability commensurate with the entity’s size, nature and risk profile; implementation of controls to protect information assets across the enterprise and third-party supply chain; regular testing of those controls; and notification to APRA of material information security incidents within 72 hours of becoming aware.
Applies to
All APRA-regulated entities — banks, insurers, superannuation trustees and other authorised deposit-taking institutions — regardless of size.
Consequence of non-compliance
Supervisory escalation, enforceable undertakings, formal directions and potential licence conditions. APRA has flagged it will increasingly test control effectiveness, not just documentation.
ASIC Cybersecurity Guidance (Regulatory Guide 255 and related guidance)
Governing body
Australian Securities and Investments Commission — asic.gov.au
What it requires
Appropriate cyber resilience frameworks, with boards actively overseeing cyber risk as a strategic governance matter. ASIC has explicitly warned it will consider enforcement action against directors who fail to adequately prepare for cyber incidents.
Applies to
All Australian Financial Services Licence holders, market operators and ASX-listed entities.
Consequence of non-compliance
Enforcement proceedings, civil penalties and AFSL cancellation. ASIC’s chairman has publicly stated cyber risk is a board governance obligation, not solely an IT matter.
Security of Critical Infrastructure Act 2018 (SOCI Act), amended 2022
Governing body
Cyber and Infrastructure Security Centre, Department of Home Affairs — cisc.gov.au
What it requires
Registration of designated critical infrastructure assets; maintenance of a risk management programme; notification to ASD of serious cyber incidents; and cooperation with government intervention directions in the most severe cases.
Applies to
Systemically important financial institutions — including major banks and certain designated payment and clearing systems — classified as critical infrastructure assets under the Act.
Consequence of non-compliance
Civil and criminal penalties under the Act. The 2022 amendments significantly expanded both the scope of covered entities and the government’s intervention powers.
Cyber Security Act 2024
Governing body
Australian Signals Directorate / Department of Home Affairs — homeaffairs.gov.au
What it requires
Mandatory reporting of ransomware payments to the ASD within 72 hours of making or becoming aware of a payment. Applies to both monetary and non-monetary payments, including gifts or services.
Applies to
All organisations with annual turnover above AUD $3 million — covering the vast majority of Australian financial services entities. Effective 30 May 2025.
Consequence of non-compliance
Civil penalties under the Act for failure to report within the prescribed timeframe.
Notifiable Data Breaches Scheme — Privacy Act 1988
Governing body
Office of the Australian Information Commissioner — oaic.gov.au/privacy/notifiable-data-breaches/
What it requires
Notification to the OAIC and affected individuals of eligible data breaches that are likely to cause serious harm, within 30 days of becoming aware that a breach is likely eligible.
Applies to
All financial services organisations — including banks, wealth managers, financial advisers, superannuation funds and consumer credit providers — regardless of turnover threshold. The finance sector is an explicitly covered category under the Privacy Act.
Consequence of non-compliance
Civil penalties of up to AUD $50 million for serious or repeated interference with privacy.
ASD Essential Eight Maturity Model
Governing body
Office of the Australian Information Commissioner — oaic.gov.au/privacy/notifiable-data-breaches/
What it requires
Eight baseline mitigation strategies across application control, patching applications, configuring macros, user application hardening, restricting administrative privileges, patching operating systems, multi-factor authentication and regular backups. Maturity Levels 0–3 provide a structured uplift pathway.
Applies to
De facto baseline for all sectors; not formally mandatory for financial services but treated by APRA as a control effectiveness baseline under CPS 234, and increasingly referenced in cyber insurance requirements and enterprise procurement frameworks.
Consequence of non-compliance
Increased exposure to successful attacks; may affect cyber insurance eligibility and terms; APRA supervisors reference Essential Eight maturity levels during CPS 234 supervision.
AUSTRAC — Anti-Money Laundering and Counter-Terrorism Financing Act 2006
Governing body
Office of the Australian Information Commissioner — oaic.gov.au/privacy/notifiable-data-breaches/
What it requires
AML/CTF programme obligations, customer due diligence requirements, suspicious matter reporting and transaction threshold reporting. Relevant where network and security architecture must support the data integrity and monitoring obligations of AML/CTF programmes.
Applies to
Financial services entities that provide designated services — including banks, remittance providers, digital currency exchanges and certain fintech platforms.
Consequence of non-compliance
Substantial civil penalties; AUSTRAC has pursued some of the largest corporate penalties in Australian legal history against financial institutions for systemic AML/CTF failures.
"The April 2025 super fund attacks are going to define how Australian financial institutions think about authentication and credential exposure for the next several years — but they shouldn't have needed to happen. The attack technique used was well-documented and the controls required to stop it are well-understood. What we consistently see in financial services is not a shortage of frameworks or guidance, but a gap between what regulators and auditors see in documentation and what is actually operationally effective in real environments. CPS 230 is forcing the right conversation: it's not enough to have policies for critical operations — you need tested continuity, validated controls and genuine visibility into your supply chain. The institutions getting this right are the ones treating operational resilience as an ongoing operational discipline, not a compliance project with an end date."
Chief Technology Officer – Orro
How Orro supports financial services organisations
Orro has designed, deployed and managed retail technology infrastructure across some of Australia’s most complex and demanding environments. Our capability spans network, security, cloud and managed services — and we deliver it at the scale that national retail requires.
1. Secure, High-Performance Connectivity for Banking and Payment Environments
Financial services network architecture is more complex than most industries acknowledge. A regional bank or customer-owned financial institution may operate dozens or hundreds of branch locations, each requiring reliable, segmented connectivity for payment terminals, staff workstations, ATMs, digital signage and customer Wi-Fi — all of which must be isolated from one another and from core infrastructure while still being centrally managed. A superannuation fund may rely on a smaller physical footprint but depends absolutely on application performance for member portals, adviser platforms and back-office processing that runs continuously.
Orro designs and manages SD-WAN and SASE architectures for financial services environments that deliver the segmentation, redundancy and visibility that payment systems and regulated data environments require. SASE frameworks allow security policy to follow the user and the transaction across branch, cloud and mobile contexts — removing the complexity of maintaining multiple perimeter controls across a distributed estate. For institutions operating across states, or managing significant workforce mobility, SASE provides a consistent security baseline regardless of where access originates.
Where private, carrier-independent connectivity is required — for backup links, out-of-band management, or remote site access — Orro holds private spectrum, one of only a handful of organisations in Australia to do so. Combined with Orro’s One Touch Control platform, which provides unified multi-vendor, multi-carrier network visibility and management, financial services technology teams gain the operational clarity needed to manage complex environments with lean resources.
Outcome: A resilient, segmented financial network that supports always-on payment operations, protects cardholder data environments, and provides the unified visibility that CPS 230 operational continuity requirements demand.
2. Cybersecurity and CTEM for Financial Services Environments
The financial services threat landscape calls for more than reactive detection. Credential stuffing, phishing-as-a-service, business email compromise and supply chain compromise are persistent, industrialised threats that demand continuous exposure management — not point-in-time assessments that are outdated before the ink dries.
Orro’s National Cyber Defence Centre provides 24/7 security monitoring, threat detection and incident response calibrated to financial services environments, including the high-volume transaction contexts and sensitive data handling that distinguishes this sector from others. The Centre operates as an Australian SOC, with Australian-based escalation, aligned to the data sovereignty and regulatory expectations of APRA-regulated entities.
For financial services organisations working to meet APRA CPS 234 control effectiveness requirements and ASIC cyber resilience expectations, Orro’s CTEM (Continuous Threat Exposure Management) service provides the ongoing exposure visibility and risk-prioritised remediation workflow that replaces periodic penetration testing cycles with a continuous operational programme. CTEM identifies which vulnerabilities and misconfigurations represent genuine business risk across your environment — branch infrastructure, cloud workloads, third-party connections, identity systems — and prioritises remediation based on exploitability and business impact rather than raw vulnerability count. This directly supports the control effectiveness assurance expectations under CPS 234, and the operational risk management obligations under CPS 230.
Authentication controls, identity and access management architecture, and Essential Eight maturity uplift are integrated into Orro’s financial services security programme — with particular attention to the credential exposure and MFA gaps that the 2025 super fund attacks exposed across the sector.
Outcome: A continuously monitored, continuously improved security posture that meets APRA CPS 234 control effectiveness obligations, closes credential and authentication exposure, and provides the board-ready evidence of operational resilience that CPS 230 demands.
3. Cloud and Application Performance for Regulated Financial Environments
Financial services cloud adoption carries regulatory obligations that generic cloud strategies do not address. APRA-regulated entities must ensure that cloud architectures support data residency requirements, maintain CPS 234-compliant controls in cloud environments, address material service provider risk under CPS 230, and preserve business continuity through cloud outages or service disruptions.
Orro designs and manages cloud and hybrid architectures for financial services organisations that balance performance, security and regulatory compliance. For digital banking platforms and member portals where application latency directly affects customer experience and trust, Orro’s application performance management capabilities identify and address the connectivity and infrastructure factors that underpin consistent service delivery. For institutions managing core system migrations to cloud platforms — whether full migration or hybrid arrangements that maintain on-premise systems for sensitive workloads — Orro provides the architecture, security controls and ongoing management that regulators expect.
Disaster recovery and business continuity design for financial services environments must be built around the disruption tolerance thresholds and recovery time objectives that CPS 230 now requires institutions to define and test. Orro’s managed cloud services incorporate backup architecture, recovery testing and continuity planning aligned to these obligations — not as a documentation exercise, but as an operationally validated capability.
Outcome: Cloud and hybrid environments that support financial services regulatory obligations, deliver consistent application performance for digital banking and payment workloads, and provide the business continuity capability that CPS 230 scenario testing requires.
4. Connected Financial Services Technology and Branch Security
Modern financial services branches are no longer simply staffed counters. They are networked environments combining payment infrastructure, ATMs, digital advisory kiosks, customer Wi-Fi, IP cameras, access control systems and staff workstations — often managed by lean technology teams responsible for dozens or hundreds of locations simultaneously. Each of these elements represents a potential network entry point if not properly segmented, monitored and secured.
Orro designs and manages connected branch technology environments that apply the network segmentation, device management and monitoring discipline that payment card environments require — including compliance alignment with PCI DSS for cardholder data protection. For customer-owned banks and regional financial institutions managing branch refresh programmes, Orro’s managed deployment capability provides standardised, repeatable rollouts that reduce configuration risk and accelerate time-to-operational across multiple sites.
For financial services organisations with operations that extend beyond traditional branch environments — including data centres, processing facilities or logistics operations that intersect with financial infrastructure — Orro’s OT security experience provides additional capability where operational technology or building management systems require security architecture attention.
Outcome: Connected branch and facility environments that meet PCI DSS segmentation requirements, reduce the attack surface across distributed physical locations, and support consistent network management at scale.
5. Operational Excellence and Managed Services for Financial Services
Financial services technology teams are responsible for outcomes that most industries would not demand simultaneously: continuous payment processing, 24/7 digital banking availability, regulatory compliance evidence, security incident response capability, and ongoing infrastructure modernisation — often with headcount that has not scaled to match the complexity of the environment.
Orro’s managed services model is built for this operational reality. One Touch Control — Orro’s proprietary network management platform — provides unified, multi-vendor, multi-carrier visibility across the full network estate, enabling proactive identification and resolution of issues before they affect business operations. The platform supports the kind of operational transparency that CPS 230’s critical operation monitoring requirements expect, and that boards and risk committees need to demonstrate genuine oversight.
Proactive management is the operational mode: Orro’s approach targets issue identification and resolution before they escalate into incidents, not after. For financial services operations where system availability is a regulatory and commercial commitment, this distinction matters materially. Orro’s Australian-owned structure, with Australian-based account management and support escalation, provides the accountable relationship model that APRA-regulated entities need from technology partners classified as material service providers.
Outcome: Continuously managed financial services infrastructure with the operational visibility, proactive monitoring and accountable support model that underpins CPS 230 critical operations management — and frees internal technology teams to focus on strategic initiatives rather than operational firefighting.
Proof of impact
24×7 security operations for Australia’s leading alternative lender
Australia’s number one alternative lender — a non-bank financial services organisation with offices across Australia, New Zealand, Asia and Europe — engaged Orro to establish a 24×7 Security Operations and Management capability to address growing cyber threats, complex compliance obligations and a shortage of specialist internal security resources. Orro delivered collaborative SOC-based security operations and incident response for the Australian operation; based on the outcomes achieved, the client’s global parent subsequently adopted a scaled version of the same service. Orro’s programme enabled faster and more consistent incident detection and response, demonstrated control effectiveness and risk management outcomes to regulators and the board, and supported proactive threat hunting capability that reduced reliance on internal cybersecurity headcount.
Securing a top general insurer across 27 countries
An Australian-headquartered general insurer ranked among the world’s top general insurers — with more than 11,000 staff and operations across 27 countries — engaged Orro to deliver security architecture and consultancy, 24×7 SOC-based security operations management for the Australian region, security assurance and governance services, and a Global Security Service Desk covering BAU security requests across all international regions. Orro’s embedded team documented standard operating procedures, supported APRA regulatory and risk management obligations, delivered visibility of security control state across the organisation’s application estate, and enabled the internal team to redirect focus toward higher-value security project work.
Delivering resilience at scale — Australia Post
Orro designed, deployed and manages Australia’s largest retail network: over 4,000 Australia Post locations. The outcome: a 70% reduction in network outages, 4x faster connections, 43% fewer critical incidents and 44,000 business impact hours avoided. The relevance to financial services extends beyond scale — Australia Post’s Licensed Post Office network provides everyday banking services to millions of Australians, including cash deposits, withdrawals and bill payments on behalf of major banks and financial institutions. The same Orro-managed network that keeps a parcel lodgement counter operational is simultaneously supporting financial transactions in communities across the country, many of them in areas where physical bank branches no longer exist. Managing that network at 4,000 sites, with the uptime and security discipline it demands, is exactly the operational model Orro brings to multi-branch financial services environments.
Frequently asked questions
What does APRA CPS 230 actually require from banks, insurers and super funds?
CPS 230, which took effect on 1 July 2025, requires APRA-regulated entities to identify their critical operations — the functions whose disruption would materially harm customers or financial markets — and set tolerance thresholds for how long and to what degree those operations can be disrupted. Institutions must develop and regularly test business continuity arrangements against those thresholds, maintain and submit to APRA a register of material service providers and their associated risks, and demonstrate that critical operations can continue through a severe disruption to any of those providers. Directors and executives are explicitly responsible for ensuring operational resilience is embedded in governance and decision-making. Non-significant financial institutions have an additional 12 months to comply with certain business continuity and scenario analysis requirements; service provider contract uplift obligations apply from 1 July 2026 or earlier renewal.
How does CPS 234 differ from CPS 230, and do we need to comply with both?
Yes — both standards apply to APRA-regulated entities and address distinct but related obligations. CPS 234 focuses specifically on information security: it requires institutions to maintain an information security capability commensurate with their risk profile, implement controls across information assets (including those managed by third parties), conduct regular testing of those controls, and notify APRA of material security incidents within 72 hours. CPS 230, which came into force in 2025, takes a broader operational resilience view — requiring identification of critical operations, continuity planning, scenario testing and comprehensive third-party risk management. Many institutions are discovering that CPS 230 compliance requires revisiting their CPS 234 control architecture, because third-party service providers now need to be assessed not just for information security controls but for their contribution to critical operation continuity.
What should our board be asking about cyber risk after the April 2025 super fund attacks?
The super fund attacks were a board-level event across the sector, not just for the directly affected funds. Every board should now be asking: what is our exposure to credential stuffing attacks, and do we have mandatory multi-factor authentication across all member and customer-facing portals? Do we have visibility into the credential exposure of our workforce across third-party services? Has our security team confirmed that the attack technique used against AustralianSuper and Rest could not succeed against our environment? More broadly: what is our current Essential Eight maturity level, and how confident are we in the accuracy of that assessment given it was last done? ASIC has explicitly put boards on notice that it will consider enforcement action against directors who fail to adequately prepare for known cyber threats.
How does Continuous Threat Exposure Management (CTEM) differ from a penetration test?
A penetration test provides a snapshot of your security posture at a point in time — typically valuable but immediately perishable, as environment changes and new vulnerabilities emerge continuously. CTEM is an ongoing operational programme that continuously identifies, prioritises and tracks remediation of vulnerabilities and misconfigurations across your environment, using real-time threat intelligence to rank exposures by exploitability and business impact. For financial services organisations, this distinction matters because the threat environment does not pause between annual testing cycles. CTEM provides the continuous assurance visibility that APRA’s CPS 234 control testing expectations increasingly require — with evidence of control effectiveness that can be demonstrated to regulators and boards rather than inferred from a dated point-in-time report.
What does APRA expect from financial services technology providers under CPS 230?
Under CPS 230, financial services institutions must treat material service providers — including managed IT, managed security, network and cloud providers — as a direct component of their operational resilience programme, not just a vendor. Institutions must assess and document each material provider’s contribution to critical operations, maintain service level monitoring, understand downstream provider dependencies, and demonstrate that critical operations can continue if a material provider fails or is disrupted. This means technology partners need to be able to clearly articulate their own resilience, continuity arrangements and incident notification capabilities in terms that satisfy APRA’s requirements. Institutions should also be aware that APRA requires a material service provider register, submitted directly to APRA, which creates formal accountability for those provider relationships.
How should we approach cloud security for APRA-regulated workloads?
APRA-regulated entities using cloud services must ensure their cloud architecture satisfies CPS 234 control requirements, addresses data residency obligations where applicable, and meets the third-party risk management and continuity obligations under CPS 230. In practice, this means conducting a thorough risk assessment before migrating regulated workloads to any cloud provider, implementing controls in the cloud environment that are equivalent to those required on-premise, and ensuring that business continuity arrangements account for the possibility of cloud provider outages or disruptions. Institutions should also maintain clear visibility into which cloud services qualify as material service providers under CPS 230 — which for many institutions will include major hyperscalers used for core workloads — and document the associated dependency risk accordingly.
What is the Essential Eight and is it mandatory for financial services organisations?
The Essential Eight is ASD’s mitigation framework consisting of eight priority strategies for cybersecurity: application control, patching applications, configuring Microsoft Office macro settings, user application hardening, restricting administrative privileges, patching operating systems, multi-factor authentication, and regular backups. It is structured across four maturity levels. For APRA-regulated entities, Essential Eight compliance is not formally mandatory but is treated by APRA as a baseline expectation for information security control effectiveness under CPS 234 — and APRA supervisors increasingly reference Essential Eight maturity levels when assessing an institution’s security posture. Cyber insurance providers across the market are also making Essential Eight maturity a condition of coverage or a pricing factor.
How should we manage third-party vendor cyber risk under CPS 230?
Start by mapping which vendors contribute to your critical operations — as defined under CPS 230 — versus those that are lower-risk ancillary services. For material service providers, you need to conduct and document risk assessments, establish appropriate contractual protections (including incident notification requirements and continuity obligations), monitor service levels on an ongoing basis, and understand those providers’ own downstream dependencies. APRA requires a material service provider register, submitted by 1 October 2025 for ADIs, superannuation trustees and insurers. Contract uplift obligations for existing agreements apply by 1 July 2026. The governance discipline CPS 230 requires is ongoing, not a one-time assessment — organisations should establish a regular review cycle as part of their broader operational risk management programme.
How do SD-WAN and SASE benefit financial services branch environments?
SD-WAN (Software-Defined Wide Area Network) allows financial services institutions to manage branch connectivity centrally, apply consistent security and traffic management policies across all locations, and dynamically route traffic for performance and resilience — without the cost and rigidity of traditional MPLS circuits. SASE (Secure Access Service Edge) extends this by converging networking and security in a cloud-delivered framework, so that security policy follows the user and the session regardless of where they are — branch, home, or mobile. For financial institutions managing dozens or hundreds of branches with lean technology teams, the combination delivers segmentation of payment and cardholder data environments, consistent policy enforcement and centralised visibility that manual per-site management cannot achieve at scale.
What should we do if our organisation experiences a ransomware attack?
Under the Cyber Security Act 2024, organisations with annual turnover above AUD $3 million must report ransomware payments to the ASD within 72 hours of making or becoming aware of a payment — effective from 30 May 2025. Under APRA CPS 234, material information security incidents must be notified to APRA within 72 hours of becoming aware. If cardholder data is potentially involved, PCI DSS incident response procedures must be followed, including notification to your acquiring bank and the relevant card scheme. Begin with containment — isolate affected systems without necessarily shutting down critical operations — then engage your incident response capability, legal team and relevant regulators simultaneously. Do not negotiate or pay without legal advice and regulatory consideration.
Why financial services organisations choose Orro
Deep regulatory alignment
Orro's financial services practice is built around APRA CPS 234 and CPS 230, ASIC cyber expectations and Essential Eight maturity — providing capability that maps directly to current regulatory obligations rather than generic security frameworks.
CTEM for continuous assurance
Orro's Continuous Threat Exposure Management service replaces point-in-time security assessments with an ongoing operational programme — providing the continuous control visibility that CPS 234 and board-level oversight require.
National Cyber Defence Centre
24/7 security monitoring and incident response from Orro's Australian-operated SOC, with Australian-based escalation aligned to the data sovereignty and regulatory expectations of APRA-regulated entities.
CPS 230-ready managed services
As a potential material service provider under CPS 230, Orro provides the resilience architecture, continuity documentation and service level visibility that APRA-regulated entities need from their technology partners.
ISO/IEC 27001:2022 certified and IRAP assessed
Orro holds ISO/IEC 27001:2022 certification — with scope covering all processes and procedures — and has been successfully assessed under the IRAP (Infosec Registered Assessors Program) framework. For APRA-regulated entities conducting vendor due diligence, Orro's independently verified security posture and SecurityScorecard A-rating provide auditable assurance. Full details at orro.group/about/trust-security/.
Proven scale at network complexity
Orro designs and manages enterprise-scale distributed networks — including Australia Post's 4,000+ site network — with the segmentation, redundancy and proactive management discipline that payment and regulated data environments require.
SD-WAN, SASE and private spectrum
Orro delivers modern network architectures for multi-branch financial services environments, including private LTE capability for carrier-independent connectivity — one of only a handful of organisations in Australia to hold private spectrum.
One Touch Control
Orro's proprietary platform provides unified, multi-vendor, multi-carrier network visibility and management — supporting the operational transparency that CPS 230 critical operations oversight requires.
Australian-owned with Australian-based support escalation
Orro is an Australian-owned partner with Australian-based account management and support escalation, and 24/7 global operations capability — directly supporting data sovereignty and regulatory expectations.
Vendor-agnostic architecture
Orro designs solutions based on what best fits the institution's environment and regulatory obligations, not vendor commercial relationships — providing independent advice across network, security and cloud domains.
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