Penetration Testing: Australian Compliance Requirements

Jul 8 2025

Penetration Testing Requirements for Compliance in Australia

In today’s digital landscape, cyber threats are evolving at an unprecedented pace, making robust cybersecurity a non-negotiable priority for Australian businesses. At Core Sentinel, we specialize in delivering cutting-edge penetration testing services to help organizations safeguard their assets and meet stringent compliance requirements. Penetration testing, or “pen testing,” is a critical tool for identifying vulnerabilities before malicious actors can exploit them. In Australia, various regulatory standards mandate regular pen testing to ensure data security and operational resilience, particularly for organizations in finance, government, and industries handling sensitive data.

This blog post explores the key penetration testing requirements for compliance in Australia, covering standards set by the Australian Prudential Regulation Authority (APRA), Australian Government, ASD Essential 8, PCI DSS, Australian Privacy Act, and more. We’ll break down what each standard requires and the recommended cadence for pen testing to keep your organization compliant and secure.

Why Penetration Testing is Essential for Compliance in Australia Penetration testing simulates real-world cyberattacks to uncover weaknesses in your systems, networks, and applications. For Australian organizations, compliance with local and industry-specific standards is not just about avoiding penalties—it’s about building trust with customers, protecting sensitive data, and ensuring business continuity. Regulatory bodies like APRA, the Australian Signals Directorate (ASD), and the Office of the Australian Information Commissioner (OAIC) set clear expectations for cybersecurity, often requiring regular pen testing as part of a broader risk management strategy.

At Core Sentinel, we understand that navigating these requirements can be complex. Below, we outline the major Australian compliance standards, their pen testing mandates, and how often testing should occur to stay compliant.

APRA Prudential Standard CPS 234: Information Security

The Australian Prudential Regulation Authority (APRA) regulates financial institutions, including banks, insurers, and superannuation funds. Prudential Standard CPS 234, effective since July 2019, is a cornerstone of cybersecurity compliance for these entities. It aims to ensure resilience against cyber incidents, including those involving third-party providers.

Penetration Testing Requirements

• Identify and protect information assets: APRA-regulated entities must classify their information assets by criticality and sensitivity, ensuring controls like penetration testing are in place to protect them.
• Regular testing of controls: CPS 234 mandates systematic testing to validate the effectiveness of security controls. Penetration testing is explicitly required to identify vulnerabilities in networks, applications, and systems.
• Third-party compliance: If data is managed by third parties (e.g., cloud providers), they must also comply with CPS 234, including undergoing pen testing.
• Incident notification: Significant vulnerabilities uncovered during pen testing that could lead to material security incidents must be reported to APRA within 72 hours.

Cadence for Pen Testing

• Minimum annually: APRA expects regular testing, with annual penetration tests as a baseline for most organizations.
• After significant changes: Additional testing is required following major system upgrades, new application deployments, or changes to third-party arrangements.
• Risk-based frequency: Entities with high-risk profiles (e.g., large banks) may need more frequent testing, such as semi-annually or quarterly, depending on their threat landscape.

Core Sentinel’s Expertise: Our APRA-compliant penetration testing services include comprehensive network and application assessments, ensuring your organization meets CPS 234 requirements while addressing vulnerabilities proactively.

Australian Government Standards: Information Security Manual (ISM)

The Australian Government Information Security Manual (ISM), developed by the Australian Signals Directorate (ASD), is a cybersecurity framework mandatory for all government agencies. It’s also increasingly adopted by commercial organizations working with the government, particularly in defense.

Penetration Testing Requirements

• Vulnerability assessments and pen testing: The ISM recommends regular penetration testing to evaluate the security of systems and networks, ensuring they are resilient against cyber threats.
• Scope of testing: Tests must cover critical systems, applications, and infrastructure, including those managed by third parties.
• Remediation: Identified vulnerabilities must be addressed promptly, with follow-up testing to verify fixes.

Cadence for Pen Testing

• Annual testing: The ISM advises at least annual penetration testing for government systems.
• Event-driven testing: Additional tests are required after significant changes, such as new system deployments or major updates.
• Continuous monitoring: While not a direct pen testing requirement, the ISM emphasizes ongoing vulnerability scanning, which complements periodic pen tests.

Core Sentinel’s Approach: We align our penetration testing methodologies with ISM guidelines, delivering tailored assessments for government agencies and contractors to ensure compliance and security.

ASD Essential 8: Recommended Cybersecurity Strategies

The ASD Essential 8 is a set of prioritized cybersecurity strategies designed to protect organizations from common cyber threats. While not a mandatory standard, it’s strongly recommended for all Australian organizations, including government agencies and private businesses, as a benchmark for cybersecurity maturity.

Penetration Testing Requirements

• Application control and vulnerability management: The Essential 8 emphasizes identifying and mitigating vulnerabilities through regular testing, including penetration testing, to ensure applications and systems are secure.
• User application hardening: Pen testing helps verify that user-facing applications (e.g., web browsers) are hardened against attacks.
• Patch management: Penetration tests validate that patches are applied effectively and don’t introduce new vulnerabilities.

Cadence for Pen Testing

• No specific cadence mandated: The Essential 8 does not explicitly require penetration testing but advises aligning testing frequency with risk levels.
• Recommended annually: Most organizations adopt annual pen testing to complement vulnerability scans and ensure Essential 8 compliance.
• After changes: Testing is recommended after significant system or application updates to verify security controls.

Core Sentinel’s Value: Our penetration testing services are designed to support Essential 8 compliance, focusing on application hardening, vulnerability management, and robust remediation strategies.

Payment Card Industry Data Security Standard (PCI DSS)

The PCI DSS is a global standard for organizations that process, store, or transmit credit card information. In Australia, it applies to merchants, service providers, and financial institutions handling payment card data.

Penetration Testing Requirements

• Requirement 11.3: PCI DSS mandates regular penetration testing to identify vulnerabilities in networks, applications, and systems that could compromise cardholder data.
• Scope: Testing must cover the entire cardholder data environment (CDE) and any systems connected to it, including external and internal networks.
• Segmentation testing: Organizations using network segmentation to isolate the CDE must validate its effectiveness through pen testing.
• Remediation and retesting: Identified vulnerabilities must be fixed, with follow-up tests to confirm remediation.

Cadence for Pen Testing

• Annually: PCI DSS requires at least annual penetration testing for all organizations.
• After significant changes: Additional testing is mandatory following major changes to the CDE, such as new infrastructure or application deployments.
• Quarterly vulnerability scans: While distinct from pen testing, quarterly scans by an Approved Scanning Vendor (ASV) complement annual tests.

Core Sentinel’s PCI DSS Expertise: Our PCI DSS-compliant penetration testing services include external and internal assessments, segmentation testing, and detailed remediation guidance to ensure your organization meets Requirement 11.3.

Australian Privacy Act 1988 and Notifiable Data Breaches Scheme

The Australian Privacy Act 1988, administered by the Office of the Australian Information Commissioner (OAIC), governs how organizations handle personal information. The Notifiable Data Breaches (NDB) Scheme, introduced in 2018, requires organizations to report data breaches involving personal information.

Penetration Testing Requirements

• Protect personal information: The Privacy Act requires organizations to take reasonable steps to secure personal data, which includes conducting penetration testing to identify vulnerabilities.
• Risk assessments: Regular pen testing helps organizations assess risks to personal information and implement appropriate controls.
• NDB compliance: Penetration testing supports breach prevention, reducing the likelihood of reportable incidents under the NDB scheme.

Cadence for Pen Testing

• No specific cadence mandated: The Privacy Act does not prescribe a testing frequency, but annual penetration testing is considered best practice to demonstrate reasonable security measures.
• Risk-based approach: Organizations handling large volumes of sensitive data (e.g., health or financial information) may require more frequent testing, such as semi-annually.
• Post-incident testing: If a data breach occurs, pen testing is recommended to identify and address underlying vulnerabilities.

Core Sentinel’s Privacy Act Support: We conduct thorough penetration tests to help organizations comply with the Privacy Act, focusing on securing personal data and minimizing breach risks.

Summary of Penetration Testing Cadence by Standard

Standard	Penetration Testing Cadence	Key Requirements
APRA CPS 234	Annually, after significant changes, risk-based	Test controls, protect assets, third-party compliance, notify APRA of incidents
ISM (Australian Government)	Annually, after significant changes	Vulnerability assessments, test critical systems, remediate findings
ASD Essential 8	Annually (recommended), after changes	Support vulnerability management, application hardening, and patch validation
PCI DSS	Annually, after significant changes, quarterly scans	Test CDE, validate segmentation, remediate vulnerabilities
Australian Privacy Act	Annually (best practice), risk-based, post-incident	Secure personal data, conduct risk assessments, prevent reportable breaches

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Why Choose Core Sentinel for Penetration Testing in Australia?

At Core Sentinel, we’re more than just a cybersecurity provider—we’re your partner in achieving compliance and resilience. Our penetration testing services are tailored to meet the specific requirements of APRA CPS 234, ISM, ASD Essential 8, PCI DSS, and the Australian Privacy Act. Here’s why Australian organizations trust us:

• Expertise Across Standards: Our team of certified ethical hackers is well-versed in Australian and global compliance frameworks, ensuring your pen tests align with regulatory expectations.
• Comprehensive Testing: We cover external and internal networks, applications, cloud environments, and third-party systems to provide a holistic view of your security posture.
• Actionable Insights: Our detailed reports include prioritized remediation steps, empowering you to address vulnerabilities quickly and effectively.
• Ongoing Support: Beyond testing, we offer continuous monitoring, vulnerability management, and compliance consulting to keep you ahead of evolving threats.

Stay Compliant and Secure with Core Sentinel

Navigating Australia’s complex cybersecurity compliance landscape doesn’t have to be daunting. With Core Sentinel as your trusted partner, you can meet the penetration testing requirements of APRA, the Australian Government, PCI DSS, the Privacy Act, and more—while strengthening your defenses against cyber threats.

Ready to ensure compliance and protect your business? Contact Core Sentinel today for a free consultation and let our expert team design a penetration testing program tailored to your needs. Visit our website to get started.

Boost your cybersecurity with Core Sentinel—because compliance is just the beginning of a secure future.

 

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