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. More prescription. Higher expectations. And a 2028 effective date that may feel distant but isn't. APRA has now entered the final phase of its governance review, with the consultation window closing August 2026.
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.
APRA has now entered the final phase of its governance review, releasing proposed updated requirements for all APRA-regulated entities. APRA's own experience consistently shows that entities under stress tend to have weak governance — and emerging risks such as artificial intelligence, cyber threats and geopolitical disruption are placing additional pressure on governance frameworks.
The new CPS 510 will require more rigorous individual director skills assessments, tighter conflicts of interest frameworks, structured board performance evaluations, a hard 12-year director tenure limit, and new senior manager accountability obligations. For many mutual banks, this is a significant governance uplift — and the window to influence the final standard closes August 2026.
Boards must document and evaluate individual director skills in a structured matrix — not just collective board capability. Vague self-assessments will no longer cut it.
A default 12-year tenure cap for non-executive directors, backed by renewal and succession planning requirements. Many mutual banks have long-serving boards — the clock may already be ticking.
A single cross-industry conflicts management framework requires proactive identification of perceived, potential and actual conflicts — extending obligations previously limited to superannuation trustees.
Updated requirements narrow the definition of 'responsible person', introduce an obligation to take all reasonable steps to ensure fitness and propriety, and require periodic reassessment.
Annual assessments must now cover individual directors, committee members and the board as a whole — a new and substantive obligation for most mutual banks.
The automatic assumption that a subsidiary director is independent because they're independent at the parent level is removed. Active assessment is now required.
A new 'senior manager' category is being introduced with clear expectations that their activities are consistent with organisational objectives and culture, and distinct from the board's role.
Baseline board committee requirements will be harmonised across regulated sectors. Risk committee obligations — previously limited to banks and insurers — are extended to superannuation entities.
A new 'senior manager' category is being introduced with clear expectations that activities are consistent with organisational objectives and culture, and distinct from the board's role.
Baseline board committee requirements will be harmonised across regulated sectors. Risk committee obligations — previously limited to banks and insurers — extended to superannuation entities.
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 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 finalised in late 2026 and the 2028 effective date approaches, 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.
APRA has commenced the final phase of its governance review, releasing proposed updated requirements. Submissions close end of August 2026. This is the window to engage and influence the final standard.
New governance framework finalised with supporting prudential guidance.
All APRA-regulated entities, including mutual banks, must comply with the new CPS 510 requirements.
The consultation period closes end of August 2026 — and the best time to start preparing is before then. Whether you're considering a submission or want to understand what these changes mean for your board, we offer a no-obligation initial conversation to help you understand where you stand and what you need to do.
MM Legal+ is actively preparing for the full rollout of CPS 510 and will provide a further update to the market as the standard is finalised.
Fixed-fee engagements available. Plain-English advice. Mutual banking specialists.
enquiries@mmlegalplus.com.au
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