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APRA's Governance Reform Agenda: Why APRA-Regulated Entities Should Start Planning Now

Posted by Kismet McCarroll | Aug 04, 2026 | 0 Comments

APRA is consulting on proposed changes to governance and fit and proper requirements for banks, insurers and superannuation trustees. The consultation opened on 16 June 2026 and closes on 28 August 2026. APRA plans to release the final standard and related guidance in late 2026, with new requirements expected to commence from early 2028. 

The direction is clear: APRA is seeking stronger board governance, clearer expectations for senior leaders and frameworks that remain effective as operational resilience, technology, cyber and third-party risks evolve. 

What Is APRA Consulting On? 

The current consultation covers draft CPS 510 Governance, related amendments to CPS 001 Defined terms and removal of routine fit and proper reporting where Financial Accountability Regime reporting now applies.

Concept 

Why it matters 

Practical consideration 

Board governance and challenge 

Effective oversight, clear accountability and constructive challenge support prudent decision-making. 

Test whether board packs, committees and escalation paths support timely, informed decisions. 

Fit and proper / accountability 

The consultation proposes stronger leadership expectations and reduced duplication in reporting. 

Confirm role clarity, accountable person mapping and governance documentation remain current. 

Conflicts and independence 

Visible conflicts management and independent judgment remain central governance considerations. 

Review conflict registers, committee charters and board renewal practices. 

Operational resilience and suppliers 

CPS 230, now in force, requires entities to maintain critical operations and manage service provider risk. 

Check oversight of material service providers, critical operations, assurance and reporting. 

 

Why This Matters 

CPS 230 Operational Risk Management is in force. It requires APRA-regulated entities to manage operational risk, maintain critical operations through disruption and manage risks arising from service providers. This reinforces the importance of supplier governance, assurance and decision-useful management information. 

Questions to Ask Now 

A focused governance health check can test whether responsibilities are clear, management information supports decision-making, critical suppliers are governed effectively and key controls can be evidenced in practice. 

How Mutual Marketplace Can Help 

Mutual Marketplace supports APRA-regulated and adjacent financial services organisations with practical governance, risk, compliance, legal, technology and supplier management expertise. We can assist with governance reviews, CPS 230 and CPS 234 uplift, FAR/accountability work, supplier governance, policy and controls uplift, and project delivery resources. 

Early preparation can help entities respond efficiently when APRA finalises the new governance requirements. 

Contact us to discuss how Mutual Marketplace can support your governance and regulatory change priorities. 

 

About the Author

Kismet McCarroll
Kismet McCarroll

Kismet is a Legal Intern with MM Legal+, supporting the team across regulatory and property matters. She assists clients with policy and contract reviews, regulatory compliance analysis, and legal research, with a particular focus on banking and financial services.

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