APRA's governance standards are changing. We help mutual banks understand what's coming, close the gaps, and stay ahead — without big-firm overheads or big-firm bills.
In March 2025, APRA released its Governance Review — the first major overhaul of CPS 510 since 2012. Eight proposals. More prescription. Higher expectations. And a 2028 effective date that may feel distant but isn't.
For mutual banks, the stakes are especially high. APRA's own 2021 review found that nearly half of mutual bank boards had at most one director with contemporary industry experience. APRA has made clear it intends to address this — and the new framework is designed to do exactly that.
The new CPS 510 will require more rigorous individual director skills assessments, tighter conflicts of interest frameworks, structured board performance evaluations, and a hard 12-year director tenure limit. For many mutual banks, this is a significant governance uplift — and the window to prepare is now.
Boards must now document and evaluate individual director skills — not just collective board capability. Vague skills matrices and self-assessments will no longer cut it.
A hard 12-year tenure cap for non-executive directors. Many mutual banks have long-serving board members — transition planning is urgent for those approaching the limit.
New requirements to proactively identify perceived, potential, and actual conflicts — extending obligations previously only applicable to superannuation trustees.
More prescriptive fitness and propriety requirements. APRA will no longer accept tick-box approaches. Policies and processes will need genuine uplift.
Annual assessments must now cover individual directors, not just the board collectively. A new and substantive obligation for most mutual banks.
The automatic presumption that a director is independent at the subsidiary level because they're independent at the parent is being removed. Active assessment required.
The proposals are expected to have a proportionally greater cost and compliance impact on smaller, non-SFI entities. Mutual banks don't have large governance teams or general counsel. They need practical, cost-effective support — not the kind of advice that comes with a partnership rate card.
We've structured our CPS 510 advisory services around what mutual banks actually need — clear guidance, practical documentation, and advice from people who understand your sector and your constraints.
We'll assess where your governance framework sits today against the proposed new standard and give you a clear, prioritised action plan.
We draft and update the governance documents your board needs — plain-English, fit for purpose, and built for your organisation's size and structure.
We help you design a defensible, practical board performance assessment process that meets APRA's expectations without becoming a bureaucratic burden.
The 12-year limit is coming. We help you audit your current board, map transition timelines, and build a succession strategy that protects institutional knowledge.
We deliver targeted briefings for your board — in plain English, not legalese — on what CPS 510 means for them personally and for the organisation.
For mutual banks that want a trusted adviser on call as the consultation process unfolds and draft standards are released, our retainer model provides cost-certainty.
We understand the mutual banking model — member-owned, community-focused, and operating with different constraints and pressures than major banks. Our advice is built around your reality, not adapted from advice written for the big four.
We don't give you a 50-page memo and leave you to figure out what to do with it. We tell you what the issue is, what the options are, and what we recommend — then help you execute.
Regulatory compliance projects don't need to come with an open-ended fee estimate. Our fixed-fee model gives you certainty so you can budget confidently and avoid bill shock.
A short scoping session to understand your current governance setup, board composition, and priorities.
We assess your current frameworks against CPS 510 proposals and produce a clear, plain-English gaps report.
We help you close the gaps — drafting documents, designing processes, and advising on tricky decisions.
As draft standards are released in 2026 and finalised in 2027, we keep you updated and compliant.
APRA's eight proposals published. Consultation period opened.
Industry submissions received, including from mutual bank representatives seeking accommodation of different business models.
APRA revised six of eight proposals — tenure limit extended to 12 years, independence ring-fence dropped, early engagement de-mandated.
Formal consultation on draft CPS 510, CPS 520 and related standards. Engage now so you're ready to respond.
New governance framework finalised with supporting guidance.
All APRA-regulated entities, including mutual banks, must comply with the new CPS 510 requirements.
The best time to start preparing for CPS 510 is now — before draft standards are released and before your competitors get ahead. We offer a no-obligation initial conversation to help you understand where you stand and what you need to do.
Fixed-fee engagements available. Plain-English advice. Mutual banking specialists.
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