Compliance & Legislation | Risk Management & Reporting

April 19, 2023

Cyber Security for Critical Infrastructure

Under Part 2A of the Security of Critical Infrastructure Act 2018 (SOCI Act), a number of Critical Infrastructure organisations are required to adopt a Risk Management Program (CIRMP) by 17th August 2023.

The obligation to adopt a CIRMP was further detailed in the Security of Critical Infrastructure (Critical infrastructure risk management program) Rules (LIN 23/006) 2023 (Cth) (CIRMP Rules), which came into force on 17th February 2023.

The CIRMP Rules detail the requirements of the CIRMP, and nominate cyber security as one of four hazards to be specifically addressed. A list of cyber security frameworks that responsible entities must choose from for inclusion in their CIRMP, is also provided. These frameworks are of varying levels of complexity. One however – the ACSC’s Essential Eight Maturity Model – embraces the common technical controls and is straightforward to deploy and manage.

Ongoing Requirements

There are ongoing requirements following CIRMP implementation, including regular reviews of the CIRMP and Board approved annual risk management reporting to the Cyber and Infrastructure Security Centre (and potentially other regulatory bodies), in the approved form.

Critical infrastructure providers must make a prompt decision as to which cyber security framework to adopt.

Important dates & obligations

The first deadline under Part 2A of the SOCI Act was 17th February 2023 when the CIRMP Rules commenced. A grace period of 6 months then applies. 

By 17th August 2023, responsible entities whose assets sit within the critical infrastructure categories must adopt a CIRMP. It is prudent and important that you select and document a cyber security framework as part of your CIRMP planning. 

The SOCI Act requires that responsible entities regularly review any hazards and the adequacy of their risk mitigations activities. Those entities have until 24th August 2024 to implement and comply with their selected cyber security framework, before providing their first annual report to the relevant authorities no later than 28th September 2024, and annually thereafter. 

There is little time for organisations to agree on and implement a CIRMP – and for most organisations, this will involve planning now, to ensure the controls and resources are ready for both August 2023 and August 2024 compliance.

Essential Eight Maturity Model: The Australian Cyber Security Centre (ACSC) recommended cyber security framework

Given the increased cyber risks to all facets of private and public organisations, the Australian Government, through ASD’s Australian Cyber Security Centre, established a cyber security framework – the Essential Eight. It is widely adopted across many industries and defines a baseline set of technical mitigation strategies designed to reduce the risk of an attacker gaining access to your IT assets and systems.

The Essential Eight Maturity Model enables your organisation, irrespective of its size, to measure the effectiveness of its cyber risk controls. Once an organisation establishes it security level objective, which is defined as Maturity Level 1 for organisations subject to Part 2A SOCI regulations, it should measure its ongoing “compliance” with the framework and report its performance as part of its annual SOCI Act reporting obligations.

With the collaborative actions of the security and operations teams, the Essential Eight Maturity Model can be applied to measure and maintain the adequacy of your cyber risk mitigation efforts.

Cyber security measurement and reporting system – available to you before the next board meeting

Huntsman Security’s Essential 8 Auditor and Essential 8 Scorecard boost your cyber risk management and corporate governance oversight with automated and data-driven cyber security measurement and maturity level reporting – giving you daily, weekly or monthly visibility of your cyber controls and their performance against the Essential Eight.

The effectiveness of each security control is measured to inform both your security and management teams of any mitigations necessary in the operation of the key security controls. In parallel, the measured score reliably provides clear visibility to the executive, board, and risk managers, of the state of your current security posture to inform risk management oversight and regulatory reporting.

Reliable, empirical, and automated cyber security control reporting

Benchmarked against the ACSC Essential Eight, the Essential 8 Auditor and Essential 8 Scorecard equip you and your organisation with a recognised evidence-based framework to identify and mitigate cyber security hazards – and support compliance with CIRMP review and reporting requirements utilising the ACSC Essential Eight Maturity Model.

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With or without the SOCI Act, and the associated deadlines, do you regularly see information about your security control effectiveness to prompt questions necessary for effective oversight?

Cyber Security for Critical Infrastructure


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