Five risk domains. One regulatory environment. None of them simple.

APRA's 30 April 2026 letter found entities relying primarily on policy direction or after-the-fact detective measures rather than preventative technical restrictions. Identity and access management capabilities have not yet adapted to non-human actors such as AI agents.

• Shadow AI tools ingesting client data, pre-earnings information, and board materials
• Model drift, bias, and lifecycle oversight gaps undiscovered in most entities
• Concentration risk in single AI providers without tested exit and substitution strategies

Cyber risk was rated the top concern by regulated entities in recent stakeholder reporting. The March 2025 super fund attacks demonstrated the scale at which credential stuffing can be coordinated. Many funds had MFA available but not enforced at login.

• MFA and authentication controls not consistently enforced
• AI-augmented threats outpacing traditional detection and response
• CPS 234 compliance gaps in authentication, testing, and third-party assurance

Cloud landing zones deployed without security architecture review. Hybrid environments creating IT/OT convergence risks. Vendor concentration creating CPS 230 operational resilience exposure.

• Cloud landing zones deployed without data sovereignty controls
• Hybrid cloud creating segmentation gaps and IT/OT convergence risks
• Concentration in technology vendors creating systemic exposure points

Designated critical infrastructure assets carry mandatory board-approved CIRMPs, 12-hour critical cyber security incident notification, and exposure to government assistance powers. CPS 230 effective 1 July 2025 adds further operational resilience requirements.

• Board-approved CIRMPs required but not yet fully operationalised across the sector
• Geopolitical tensions increasing the likelihood and severity of targeted attacks
• Operational resilience tolerance levels and tested scenarios still maturing