Converging operational, technology and compliance priorities

Regulatory change will accelerate across prudential oversight, payroll obligations, Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) reforms, and critical infrastructure requirements in the year ahead. Despite reported maturity, significant gaps remain across Australian businesses regarding supplier due diligence, third-party governance, data security, and operational controls, leaving many businesses exposed.

Organisations are encouraged to strengthen end-to-end assurance; adopting integrated governance structures and reporting across operational, cyber, and financial crime risks. Businesses must treat compliance not as a cost centre, but as a strategic long term investment in continuity and trust.

Here, we outline a number of key changes for executives to prepare for ahead of 1 July 2026.

Operational Risk and Prudential Oversight (APRA & CPS 230)
Significant for: All APRA-regulated entities

Organisations will need to extend control and assurance across their supply chain. Pressure will increase to finalise contract renewals and uplift arrangements with Material Service Providers (MSPs) to meet CPS 230’s service levels, business continuity, as well as audit and monitoring rights requirements. APRA has also indicated targeted consultation on adjustments for Non-Traditional Service Providers (NTSPs), with an aim to provide a more practical and streamlined approach to market-mandated or non-negotiable arrangements. The 72-hour notification window for material cyber incidents will drive significant investment in internal reporting, triage, and forensic capabilities.

Scenario testing of critical business services will become a major focus for internal audit and external assurance, with APRA expecting greater organisational maturity in response, recovery, and communication.

Real-Time Payroll Compliance
Significant for: All employers

The commencement of “Payday Super” will fundamentally reshape payroll operations and cash flow management. The requirement for superannuation contributions to be paid at the same time as wages, and received within seven business days, will significantly increase the risk of non-compliance for organisations with fragmented payroll systems. The closure of the Small Business Superannuation Clearing House will also accelerate reliance on third party payroll platforms, particularly among small and medium sized employers.

In parallel, increased ATO funding and the expanded use of Single Touch Payroll Phase 2 data will drive a rise in automated compliance reviews. These reviews are expected to focus on superannuation guarantee shortfalls, award compliance, and employee entitlements. Payroll governance failures are likely to attract substantial penalties.

AML/CTF - Tranche 2 Reforms
Significant for: Accountants, Lawyers, Real Estate Agents, Trust and Company Service Providers

AUSTRAC’s long-awaited AML/CTF reforms will mark a major regulatory uplift for the professional services sector. Newly regulated entities must rapidly implement full AML/CTF programs, including ML/TF risk assessments, Customer Due Diligence (CDD) processes, and Suspicious Matter Reporting capabilities.

The reforms will also intensify scrutiny of Ultimate Beneficial Ownership across complex corporate and trust structures, aligning AML/CTF obligations with the Government’s broader focus on critical infrastructure security and foreign investment oversight under the SOCI Act and the Foreign Investment Review Board.

Key actions to take

• Integrate compliance – move away from siloed compliance functions. Treat cyber, operational risk, and payroll compliance as interconnected systems of risk that require integrated governance and reporting.

• Invest in automation – system upgrades are non-negotiable for Payday Super implementation and the accuracy required under STP Phase 2. For AML/CTF Tranche 2, automation of CDD and transaction monitoring will be essential.

• Validate your supply chain – conduct immediate, documented due diligence and contractual uplift reviews for all Material Service Providers (CPS 230) and critical technology partners.