Compliance & Legislation | Operational resilience

June 30, 2025

Organisations subject to Australia’s Security of Critical Infrastructure Act 2018 (SOCI) face a tough challenge: how to meet strict cyber incident reporting timelines while juggling a mix of governance frameworks, operational pressures, and technical controls.

While the SOCI legislation enables organisations to choose from a range of cyber security frameworks to meet their obligations—such as ISO/IEC 27001 and NIST CSF, the real question is:

Can some of these frameworks alone meet some of SOCI’s tight incident reporting timeframes, particularly for those that cause ‘relevant impact’?

SOCI Compliance: A Real-Time Problem

SOCI-mandates incident reporting deadlines as follows:

  • 12 hours if a cyber incident has a significant impact on a critical infrastructure asset
  • 72 hours for incidents with a relevant impact
  • 84 hours for follow-up detailed reporting if a verbal report is made (or 48 hours for incidents with a relevant impact)

Additionally, organisations designated as responsible entities for critical infrastructure assets also need to maintain and comply with a Critical Infrastructure Risk Management Program (CIRMP) to demonstrate their proactive hazard risk management capabilities, including cyber security.

The problem is that, while traditional ISMS-style frameworks work well for governance and long-term cyber security strategy, they lack the real-time visibility needed to detect and report threats in the timeframes required by SOCI.

That’s where the ACSC Essential Eight (E8) can help.

Why the Essential Eight Matters

Unlike comprehensive ISMS frameworks that focus on policy, governance and documentation, the ACSC Essential Eight delivers a practical, technical baseline of critical security controls. These controls are measurable, automatable, and map directly to your cyber threat posture—making them ideal for operationalising CIRMP mitigation requirements.

FactorISMS-Only ApproachWith Essential Eight Integration
Detection & MonitoringPeriodic, policy-ledContinuous, control-state visibility
Incident ResponseAudit frequency dependentNear real-time detection and escalation
Reporting AlignmentDifficult to meet timelinesSupports automated reporting triggers
Evidence for CIRMPManual and indirectAuditable, metrics-driven outputs
Regulator FamiliarityRequires justificationRecognised by ACSC & CISC

A Hybrid Model: ISMS AND Essential Eight

The most effective approach isn’t to choose one over the other—it’s to combine governance frameworks like ISO 27001 with data-driven technical overlays using the ACSC Essential Eight.

This hybrid model enables:

  • Broad strategic oversight
  • Tactical enforcement via Essential Eight-aligned technical controls
  • Clear documentation for CIRMP reporting
  • Prompt, effective response to cyber incidents and regulator expectations

How Huntsman Security’s Scorecard Accelerates SOCI Compliance

Meeting SOCI requirements isn’t just about frameworks—it’s about having the right tooling in place to monitor, measure, and report the effectiveness of your risk management efforts that support your cyber resilience.

The Huntsman Security Scorecard was specifically developed to address this challenge.

Key Benefits of the Scorecard:

SOCI ObligationHow Scorecard Helps
12–72 hour reportingAlerts triggered by a degradation of control effectiveness
CIRMP evidenceAutomated evidence-based reporting of current control maturity
Executive/Board attestationEasy-to-understand dashboards to inform governance processes
Framework mappingSupports Essential Eight alignment even when using ISO/NIST as primary frameworks

Bonus: The Scorecard integrates with existing SIEM and SOC environments, to make them efficient and cost-effective.

Strategic Takeaway for Security Leaders

Compliance with SOCI isn’t just a checkbox exercise—it’s an ongoing race to protect your enterprise against security incidents or disruption. Traditional frameworks give you the map, but Essential Eight gives you the vehicle.

Final Recommendations:

  • Adopt a hybrid framework strategy: pair ISO 27001 or NIST CSF with the Essential Eight.
  • Implement control monitoring tools: use the Huntsman Essential 8 Scorecard to provide continuous real-time visibility and mitigation reporting.
  • Embed Essential Eight into your CIRMP: ensure your risk management practices explicitly connect the Essential Eight controls to cyber security hazards and mitigations obligations.

The Essential Eight is more than just guidance—it’s a practical enabler of SOCI cyber resilience.

For critical infrastructure providers, integrating the ACSC Essential Eight and leveraging platforms like the Huntsman Scorecard into their CIRMP provides a clear, auditable path to meeting SOCI’s incident reporting and compliance demands—while at the same time informing dynamic risk management and board-level oversight.

In a world of evolving threats and tightening regulations, that’s not just good governance—it’s business as usual.

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