← Joint Standard 2 Governance

CYB-05 · Cyber security

Controls assurance — annual independent testing of cybersecurity controls

Cybersecurity controls must be independently tested at least annually. This includes vulnerability assessments, penetration testing of client-facing systems, and/or scenario-based tabletop exercises. Findings must be tracked to closure.

High priority

Trigger

When this rule fires

No independent cyber controls test in the last 12 months, or findings from last assessment not tracked or remediated

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 — paragraphs 7.7.1 (control effectiveness) and 7.7.2–7.7.3 (vulnerability assessment and penetration testing)
Legislation
  • Joint Standard 2 of 2024

Remediation

How to close the gap

Commission an annual vulnerability assessment and penetration test (VAPT) by a qualified tester. Implement a findings tracker. Conduct a tabletop incident exercise with the leadership team.

Evidence required

Evidence to prepare if this control applies

  • VAPT report (last 12 months)
  • Tester independence and qualification confirmation
  • Findings remediation tracker with closure evidence
  • Tabletop exercise records (scenario, attendees, outcomes)