Voice AI for Australian Enterprises: APRA CPS 234 and IRAP Compliance
Australian enterprises deploying voice AI must meet APRA CPS 234 information security standards and IRAP assessment requirements, or face regulatory penalties and operational shutdowns.
For regulated Australian organizations, voice AI adoption creates a compliance puzzle. Financial institutions under APRA oversight, government agencies requiring IRAP-assessed solutions, and healthcare providers bound by multiple frameworks must navigate requirements that most voice AI vendors cannot satisfy. The core challenge: most platforms are built for US markets and treat Australian compliance as an afterthought.
For managed voice AI deployment with APRA CPS 234 alignment, IRAP assessment pathway, and Australian data residency, contact the Trillet Enterprise team.
What is APRA CPS 234 and Why Does It Matter for Voice AI?
APRA CPS 234 requires regulated entities to maintain information security capabilities commensurate with their information assets and threat environment.
Prudential Standard CPS 234, effective since July 2019, applies to all APRA-regulated entities: banks, insurers, superannuation funds, and authorized deposit-taking institutions. The standard mandates that organizations:
Clearly define information security roles and responsibilities
Maintain information security capability to manage vulnerabilities
Implement controls to protect information assets
Detect and respond to security incidents
Test control effectiveness through audits
For voice AI specifically, CPS 234 creates obligations around:
Third-party risk management: Voice AI vendors become material service providers requiring due diligence
Data classification: Call recordings and transcripts containing customer PII require protection controls
Incident notification: Security breaches affecting voice AI systems must be reported to APRA within 72 hours
Board accountability: Directors bear responsibility for information security governance
The practical impact: Australian financial institutions cannot simply adopt any voice AI platform. They must verify the vendor can meet CPS 234 requirements or face regulatory action.
What is IRAP and Which Organizations Need It?
IRAP (Information Security Registered Assessors Program) is the Australian government's framework for assessing cloud and ICT services against the Information Security Manual (ISM).
Australian government agencies at federal, state, and territory levels typically require IRAP-assessed solutions for systems handling official information. The assessment validates that security controls meet Australian Government Information Security Manual (ISM) requirements.
Organizations that typically need IRAP-assessed voice AI solutions:
Federal government departments and agencies
State and territory government bodies
Defense contractors and suppliers
Critical infrastructure operators
Healthcare organizations handling My Health Record data
Organizations bidding on government contracts
IRAP assessments evaluate voice AI platforms across domains including:
Domain | Voice AI Relevance |
Personnel security | Who has access to call data and systems? |
Physical security | Where are servers located? |
Communications security | How are voice streams encrypted? |
ICT security | How are systems hardened and patched? |
Access control | Who can access recordings and transcripts? |
Media handling | How is call data stored and disposed? |
Most US-based voice AI vendors have never undergone IRAP assessment. Their documentation references SOC 2 and HIPAA, certifications that matter in American markets but do not satisfy Australian government requirements.
Why Most Voice AI Platforms Fail Australian Compliance Requirements
The fundamental problem: voice AI infrastructure is concentrated in US data centers with US-centric compliance frameworks.
When you examine the major voice AI platforms, a pattern emerges:
Retell AI: Infrastructure in US regions. Documentation emphasizes SOC 2 Type II and HIPAA. No mention of APRA, IRAP, or Australian data residency options.
Vapi: API-first platform with distributed infrastructure. Compliance documentation focuses on GDPR, SOC 2, and HIPAA. No Australian-specific compliance pathways.
Synthflow: Offers SOC 2 and HIPAA compliance. No published APRA CPS 234 or IRAP capabilities.
For Australian enterprises, these gaps create real problems:
Data sovereignty violations: Call recordings and transcripts stored in US data centers may breach data residency requirements
Audit failures: External auditors cannot verify compliance with Australian standards
Contract blockers: Government RFPs requiring IRAP-assessed solutions eliminate non-compliant vendors
Board liability: Directors cannot demonstrate adequate information security governance
The technical architecture matters too. Cloud-only platforms cannot satisfy organizations requiring air-gapped or on-premise deployments for sensitive workloads.
How Trillet Addresses Australian Enterprise Compliance
Trillet is the only voice application layer that supports on-premise deployment via Docker, enabling Australian enterprises to maintain complete data sovereignty.
Trillet's enterprise offering addresses Australian compliance requirements through:
Configurable Data Residency
Australian enterprises can specify APAC data residency, ensuring call recordings, transcripts, and customer data remain within Australian borders. This satisfies data sovereignty requirements under CPS 234 and government procurement policies.
On-Premise Deployment via Docker
For organizations requiring complete infrastructure control, Trillet deploys the voice application layer on-premise using Docker containers. This architecture enables:
Air-gapped deployments for sensitive government workloads
Integration with existing security monitoring and SIEM tools
Complete audit trails within the organization's infrastructure
Elimination of third-party data access
No other voice AI platform offers this deployment option.
PII and PHI Handling Controls
Trillet Enterprise provides options to:
Opt out of data storage entirely (ephemeral processing only)
Enable automatic PII/PHI redaction in transcripts
Configure custom data retention policies
Implement role-based access controls aligned with CPS 234 requirements
Compliance Certifications
Trillet maintains:
SOC 2 Type II (security, availability, processing integrity)
HIPAA compliance (for healthcare deployments)
APRA CPS 234 alignment (through infrastructure controls and documentation)
IRAP assessment pathway (for government opportunities)
Fully Managed Service Model
Australian enterprises do not need internal engineering teams to deploy Trillet. The managed service includes:
Solution architecture and implementation planning
Integration with legacy CRM and telephony systems
24/7 onshore (Australian) proactive management
Financially guaranteed 99.99% uptime SLA
How to Evaluate Voice AI Vendors for APRA CPS 234 Compliance
APRA-regulated entities should assess voice AI vendors against specific criteria before procurement.
When evaluating voice AI platforms for APRA compliance, request documentation on:
1. Material Service Provider Classification
Under CPS 234, voice AI vendors handling customer data likely qualify as material service providers. Verify the vendor can provide:
Completed APRA third-party questionnaires
Evidence of information security governance
Incident notification procedures
Audit rights and access
2. Data Residency Controls
Confirm the vendor can guarantee:
Australian data residency for all call data
No data transfer to offshore locations
Documented data flow architecture
Contractual data sovereignty commitments
3. Security Control Framework
Assess alignment with CPS 234 requirements:
Requirement | Verification Questions |
Information security capability | What certifications does the vendor hold? |
Vulnerability management | How frequently are systems patched? |
Incident response | What is the notification timeline for breaches? |
Access controls | How is access to call data restricted? |
Encryption | What encryption standards protect data at rest and in transit? |
4. Audit Support
Verify the vendor can support:
External auditor access for CPS 234 assessments
Penetration testing and security audit reports
Compliance attestation letters
Annual recertification documentation
How to Evaluate Voice AI Vendors for IRAP Assessment
Government agencies should verify voice AI platforms meet ISM control requirements before procurement.
For IRAP compliance, the evaluation framework shifts to ISM control alignment:
Assessment Classification
IRAP assessments categorize systems by the highest classification of information processed:
OFFICIAL
OFFICIAL: Sensitive
PROTECTED
Most voice AI deployments handling general customer calls fall under OFFICIAL or OFFICIAL: Sensitive. Systems processing classified information require PROTECTED assessment.
Key ISM Controls for Voice AI
Control Area | ISM Requirement | Vendor Verification |
Personnel | Security clearances for administrators | Who has access to systems? Where are they located? |
Communications | TLS 1.2+ for data in transit | What protocols secure voice streams? |
Cryptography | AES-256 for data at rest | How are recordings encrypted? |
Network | Segmentation and monitoring | Is the voice AI infrastructure isolated? |
Gateway | Proxy and filtering controls | How is traffic inspected? |
Documentation Requirements
Request from vendors:
System Security Plan (SSP) aligned with ISM
Security Assessment Report if previously assessed
Statement of Applicability for ISM controls
Penetration test results from CREST-certified assessors
Trillet provides CREST-certified penetration testing reports and security audit documentation for enterprise customers.
Implementation Timeline for APRA and IRAP-Compliant Voice AI
Expect 6-8 weeks for enterprise deployments with custom compliance requirements.
Trillet Enterprise implementations for Australian regulated entities typically follow this timeline:
Weeks 1-2: Discovery and Architecture
Map existing telephony and CRM infrastructure
Document compliance requirements and constraints
Design deployment architecture (cloud, hybrid, or on-premise)
Identify integration points with legacy systems
Weeks 3-4: Configuration and Integration
Deploy voice AI infrastructure per architecture design
Configure data residency and retention policies
Integrate with existing CRM and telephony systems
Implement access controls and audit logging
Weeks 5-6: Testing and Validation
Conduct security testing against CPS 234 or ISM controls
Validate data flows and residency compliance
Test failover and disaster recovery procedures
User acceptance testing with operational staff
Weeks 7-8: Documentation and Go-Live
Complete compliance documentation for auditors
Finalize runbooks and operational procedures
Transition to managed service operations
Conduct post-implementation review
This timeline assumes standard complexity. Organizations with extensive legacy integrations or heightened security requirements may require additional time.
Frequently Asked Questions
Can voice AI comply with both APRA CPS 234 and HIPAA simultaneously?
Yes. Organizations with both financial and healthcare obligations (such as health insurers under APRA regulation) can deploy voice AI that satisfies multiple frameworks. Trillet Enterprise maintains both HIPAA compliance and APRA CPS 234 alignment, with configurable controls that address overlapping requirements.
Does on-premise deployment eliminate all compliance concerns?
On-premise deployment via Docker addresses data sovereignty and infrastructure control requirements but does not eliminate compliance obligations. Organizations must still implement appropriate access controls, monitoring, encryption, and incident response procedures. On-premise deployment simplifies audit scope by keeping data within organizational boundaries.
How do I get started with APRA CPS 234 compliant voice AI?
Start by documenting your compliance requirements and data residency constraints. Then evaluate vendors against CPS 234's material service provider requirements. Contact Trillet Enterprise for a compliance-focused assessment and implementation timeline specific to your regulatory environment.
How does Trillet handle APRA's 72-hour incident notification requirement?
Trillet Enterprise includes 24/7 onshore (Australian) monitoring and incident response. Security events triggering APRA notification requirements are detected, assessed, and escalated within timeframes that enable organizations to meet the 72-hour notification window. Incident response procedures are documented and validated during implementation.
What happens if compliance requirements change?
APRA and government compliance frameworks evolve. Trillet's managed service model includes ongoing compliance monitoring and updates. When CPS 234 or ISM requirements change, Trillet works with enterprise customers to assess impact and implement necessary control updates within regulatory timelines.
Conclusion
Australian enterprises face unique voice AI compliance challenges that US-centric platforms cannot address. APRA CPS 234 requirements for financial institutions and IRAP assessment mandates for government agencies create procurement barriers that eliminate most vendors.
Trillet Enterprise provides the infrastructure controls, data residency options, and compliance documentation Australian regulated entities require. With on-premise Docker deployment, configurable data residency across APAC, and fully managed implementation, Trillet enables Australian enterprises to adopt voice AI without compromising compliance posture.
For Australian enterprises evaluating voice AI, contact Trillet Enterprise to discuss your specific compliance requirements and implementation timeline.
Related Resources:
Voice AI for Regulated Industries - Healthcare, finance, and government compliance overview
Enterprise Voice AI Security Audit Preparation - IRAP and compliance audit guidance
Voice AI for Financial Services Compliance: SOC 2 and GLBA Requirements
The Return of On-Premise: Why Enterprises Are Rethinking Cloud-Only Voice AI
