We recently sat down with director Kirsten Samuels, who represents the superannuation sector. Kirsten is the Policy Director of Superannuation and Innovation at the Financial Services Council. With a rich history and experience in policy within government sectors, Kirsten brings a diverse wealth of knowledge and passion to the GNGB board.

In our discussion, we wanted to learn more about Kirsten’s thoughts on CPS 230 which is the new prudential standard on Operational Risk management. We asked Kirsten, from a policy lens, what it will mean for the superannuation landscape.

1. For those of us who are unfamiliar with the regulatory landscape, can you explain to us in a few sentences what CPS230 is and what it means for the superannuation ecosystem?

CPS 230 is a new prudential standard which applies to all APRA regulated entities – broadly, superannuation funds, banks, and insurance companies. It requires a strong focus on operational resilience focussing on the critical operations of keeping the entity running and making sure there are plans in place, and those plans are tested, with a view to minimising customer and financial system disruption. There is also a strong focus on oversight of the service providers necessary to provide those critical operations or other key operational requirements.

2. What do you see as the benefits of CPS230 being introduced and how do you see this improving the superannuation ecosystem?

CPS 230 will provide a cross-industry standard for operational resilience and should benefit customers and the wider economy by ensuring that some of the key pieces of our infrastructure have near constant serviceability. As we’ve seen from recent events, like CrowdStrike, the smallest things can set off a chain reaction of outages and it’s important for financial services organisations to be as prepared as possible for those kinds of events.

3. How are the funds you are working with, going about preparing for the implementation deadline in July 2025?

FSC funds are busy with implementation. They have recruited entire teams of people to deliver this project. They are in the process of thinking about their critical operations and setting the tolerance levels for any outages of those operations. Those tolerance levels will inform them when certain plans need to kick in to prevent any significant operation risk incidents. They’re also mapping out their material service providers, which is no small task. Funds already have a pretty good overview of their operational resilience and risk profile but they’re now just refining everything with a CPS230 lens.

4. What are some of the challenges that the superannuation ecosystem might encounter with the introduction of CPS230?

It took some time for APRA to publish their guidance in relation to CPS 230 which meant that funds have only just started being able to firm up their compliance plans and there’s not much time left until the deadline. Funds have had expectations of operational resilience for some time and CPS 230 builds on existing obligations. Although it’s not a new concept, it’s still a lot of work becoming compliant with a whole new prudential standard. It’s also bringing in entire industries that are not APRA regulated, like gateways and tech providers, who will be material service providers and who funds need to work with to ensure their own compliance. There will be a lot of work in those existing relationships to get the due diligence and attestation that suits the individual superannuation fund’s approach to CPS 230 compliance.

5. As a policy maker, what are you most excited for with the introduction of CPS 230?

The introduction of a new Standard or a new piece of legislation is always an interesting time to work in policy development because you have to work with a wide range of stakeholders to deliver something that is fit-for-purpose but doesn’t overly burden industry with red tape and inefficiencies. Working with other people to find solutions and make good policy is what attracted me to this work. CPS 230 will be interesting to watch as we approach the compliance date because every single regulated entity has its unique approach. It will be interesting to see how these approaches evolve over time and how they work after being tested with practiced and real-world scenarios.

6. Lastly, from a policy lens, where do you hope to see the superannuation ecosystem ten years from now?

Superannuation is a very exciting industry to be part of. It touches absolutely everyone and there’s certainly never a dull moment in this policy space. I am very passionate about financial literacy and getting people engaged with their superannuation. I hope measures like Payday Super encourage people to know what fund they’re in and take an active interest in their balances whether they are 15 and just starting work or 55 and thinking about retirement.