Case Study: How a Mid-Tier ADI Saves 40 Hours/Month on CPS 230 Compliance

This case study illustrates a typical compliance challenge facing mid-tier Australian ADIs, based on publicly available information about regulatory pressures in the sector and GoComply's capabilities.

The Challenge

A mid-tier Australian ADI with $30 billion in assets faces a familiar compliance challenge: too many regulations, too few people, and a deadline that won't move.

With CPS 230 effective July 2025 for SFIs and July 2026 for non-SFIs, the compliance team of 8 people is stretched across:

• 37+ regulatory obligations — APRA prudential standards, Commonwealth legislation, AML/CTF, Privacy Act
• CPS 230 implementation — critical operations register, tolerance levels, BCP testing, service provider management
• FAR compliance — accountability statements, accountability maps, deferred remuneration
• Ongoing APRA supervisory engagement — responding to queries, preparing for reviews
• A $50 million additional capital charge — APRA has imposed enhanced requirements following compliance deficiencies

The compliance team spends an estimated 50+ hours per week on regulatory research alone — reading APRA handbooks, cross-referencing standards, tracing which requirements superseded which, and documenting clause references for board papers.

The Pain Points

1. Research time: A single board paper on CPS 230 tolerance levels takes 3-4 hours to research and draft — finding the right paragraphs, cross-referencing with CPS 220 risk appetite, checking CPG 230 guidance, and verifying nothing has changed since the last review.

2. Cross-regulation complexity: When APRA asks "How does your BCP address service provider disruptions?", the answer spans CPS 230, CPS 231 (transition), CPS 234 (information security), and the Banking Act (APRA enforcement powers). Four standards, four handbooks, four hours.

3. Regulatory evolution: CPS 230 replaced CPS 231 and CPS 232. FAR replaced BEAR. The Privacy Act penalties jumped from $2.2M to $50M. Keeping track of what replaced what — and what changed — is a full-time job.

4. New hire ramp-up: When a new compliance analyst joins, it takes 3 months before they can independently research APRA requirements. There's no single source of truth.

The Solution

The compliance team adopted GoComply's AI compliance chatbot — covering 37 Australian financial regulations with instant, clause-referenced answers.

The Results

Real Queries, Real Answers

Here are actual questions the compliance team asks GoComply daily:

Query: "What does CPS 230 require for business continuity planning?"

GoComply returns a structured answer covering critical operations register requirements, tolerance levels (RTO, RPO, minimum service), BCP content requirements, annual testing obligations, 24-hour APRA notification for tolerance breaches, and board oversight responsibilities — with paragraph references to CPS 230.

Query: "What replaced BEAR and how does FAR work?"

GoComply explains the BEAR-to-FAR transition, commencement dates (ADIs March 2024, insurers/super March 2025), the six core FAR obligations, accountability statements and maps, deferred remuneration requirements, and enforcement powers — with section references to the FAR Act 2023.

Query: "What powers does APRA have to impose capital charges?"

GoComply returns Banking Act s11CA directions power, the specific types of directions APRA can make (hold additional capital, restrict dividends, remove directors), enforcement precedents (Medibank $250M, Bendigo $50M), and the relationship to CPS 230 compliance.

The Capital Charge Context

For an ADI facing an additional capital charge, every month of non-compliance has a real cost. $50 million in additional capital means:

• Lost lending capacity — capital tied up in the charge can't be deployed for loans
• Reduced return on equity — shareholders see lower returns
• Enhanced APRA scrutiny — more frequent supervisory reviews, more questions to answer
• Reputational impact — market awareness of the charge affects investor confidence

Faster compliance remediation means faster application to have the charge reduced. Every week the compliance team saves on research is a week closer to demonstrating CPS 230 compliance to APRA.

Why GoComply vs. Manual Research

Next Steps

The compliance team is now using GoComply for:

• CPS 230 gap analysis — mapping current state against requirements using the free CPS 230 checklist
• Board paper preparation — researching regulatory requirements with verified clause references
• APRA response drafting — quickly finding relevant provisions when responding to supervisory queries
• Staff training — new analysts use the chatbot to learn regulations as they research them, with the CPS 230 Masterclass for structured learning

This case study is based on typical compliance team challenges and GoComply's capabilities. Results may vary. GoComply pricing starts at $99/month.