CYB-01 · Cyber security

Cybersecurity strategy — documented, board-approved, and aligned to business goals

A written cybersecurity strategy must define the organisation's risk appetite, key cyber threats, control objectives, and improvement roadmap. Must be board-approved and reviewed at least annually or following material changes.

Critical priority

Trigger

When this rule fires

No documented cybersecurity strategy, or strategy not approved at board level, or strategy last reviewed > 12 months ago

Applicability gate

Confirm the entity's role before treating this as a duty

This is a readiness rule mapped to JS2 themes. Its presence in the library does not establish that JS2 applies directly to the firm.

Insurance Broker: Most independent non-life Category I brokers are not directly in JS2's defined scope. A broker may be directly in scope if it separately meets a listed category, and may face contract or oversight requirements from an in-scope institution. Third-party provisions impose duties on the in-scope financial institution. They do not themselves make every supplier or intermediary directly subject to JS2.
Uma Binder Holder: UMA or binder-holder status is not itself listed in JS2's definition. Direct scope depends on another listed capacity; insurer contracts and oversight may create evidence requirements. JS2 paragraph 3.3 concerns juristic persons structured under an insurer or designated insurance group; it is not a blanket rule for every independent UMA or intermediary.
Insurer: An insurer as defined in the Insurance Act is directly in scope of JS2 from 1 June 2025. Apply proportionality and distinguish the insurer's own duty from requirements it places on third parties.

Citation

Mapped source

This control maps to the public instruments below. The mapping does not establish entity applicability.

Section

Joint Standard 2 of 2024 — paragraph 6.1.1 (strategy; annual review 6.1.2)

Legislation

Joint Standard 2 of 2024
FAIS Act risk management obligation

Remediation

How to close the gap

Engage a qualified cyber security practitioner to draft a strategy. Present to board for approval. Include: risk appetite statement, threat landscape assessment, control objectives, and a 12-month improvement roadmap.

Evidence required

Evidence to prepare if this control applies

Board-approved cybersecurity strategy document
Board resolution evidencing approval
Last review date on document
Improvement roadmap with owner and deadline per initiative

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