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Rules Mate

Do superannuation trustees need to comply with APRA CPS 234 (Information Security)?

A computed answer from the Rules Mate applicability engine, with the exact condition, the outcome for every structure and size, and the primary source.

Short answer: Yes

Yes. This obligation applies to superannuation trustees whatever their structure or size. The deciding fact: RSE licensee — APRA-regulated.

The obligation in brief

Comply with APRA CPS 234 (Information Security). CPS 234 requires APRA-regulated entities (ADIs, insurers, RSE licensees) to clearly define information security-related roles, maintain capability, implement controls commensurate with vulnerabilities and threats, and notify APRA within 72 hours of a material information security incident.

Trigger: Being APRA-regulated.

Why superannuation trustees get a different answer

Rules Mate runs its applicability engine across 9 business structures and 6 size bands for each of the 35 industries it maps. For 32 of those industries the answer for "Comply with APRA CPS 234 (Information Security)" is no. Superannuation trustees is one of the 3 where the answer is different: yes.

The deciding fact for superannuation trustees: RSE licensee — APRA-regulated.

About the industry: Trustees of APRA-regulated super funds.

Compare a professional services (general) business with 6–19 employees structured as a Pty Ltd company: the obligation does not apply (Requires APRA regulation).

Answer by business structure and size

Each cell is the engine's outcome for a business in superannuation trustees with that structure and size, assuming it sells to consumers and small businesses and holds customer contact details. "Check" means the obligation turns on a fact the industry does not settle.

"Comply with APRA CPS 234 (Information Security)": outcome for superannuation trustees by structure and size
StructureNo employees1–5 employees6–19 employees20–99 employees100–499 employees500+ employees
Sole traderYesYesYesYesYesYes
PartnershipYesYesYesYesYesYes
TrustYesYesYesYesYesYes
Pty Ltd companyYesYesYesYesYesYes
Public companyYesYesYesYesYesYes
Not-for-profit (unregistered)YesYesYesYesYesYes
Registered charityYesYesYesYesYesYes
Super fundYesYesYesYesYesYes
Foreign companyYesYesYesYesYesYes

What the obligation requires

When due
Continuous; APRA notification within 72 hours of a material incident.
Evidence to keep
Information security policy, control testing, internal audit reports, incident notifications.
Maximum penalty
APRA enforcement actions including additional capital, licence conditions, directions
Regulator
APRA
Jurisdiction
Commonwealth (national)

Other obligations where superannuation trustees differ from the norm

Other industries with a non-default answer

Questions

Do superannuation trustees need to comply with APRA CPS 234 (Information Security)?
Yes. This obligation applies to superannuation trustees whatever their structure or size. The deciding fact: RSE licensee — APRA-regulated.
Is the answer the same for every industry?
No. For 32 of the 35 industries Rules Mate maps, the answer is no. Superannuation trustees is one of 3 industries with a different answer.

Related

Sources

Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.