The CPS 230 Visibility Gap

In reality, many organisations are discovering the same problem: you can’t manage what you can’t clearly see.

Without structured, connected visibility, even well-designed frameworks start to strain. Teams work harder, reporting becomes heavier, and decisions take longer - not because capability is lacking, but because the underlying view of the business is incomplete.

Where the visibility challenge
shows up 

Across firms, the same issues keep surfacing:

• Critical operations feel subjective
  Without a clear, end-to-end view, defining what is “critical” often relies on judgement rather than evidence.

• Dependencies are only partially understood
  Key suppliers are known, but beyond that, visibility quickly drops off, leaving fourth-party risk largely opaque.

• Data is fragmented and hard to use
  Risk, supplier, and incident data exist, but sit across different systems, making consistent, decision-ready reporting difficult.

• Ownership is unclear
  Operational risk spans multiple teams, and without shared visibility, responsibility becomes blurred.

• Boards lack meaningful insight
  Accountability has increased, but reporting often lacks the clarity and depth needed for confident oversight.

• Legacy systems reinforce silos
  Many organisations are working across infrastructure that was never designed to provide a connected, real-time view.

Individually, these are manageable challenges.
Together, they create a persistent gap between compliance on paper and confidence in practice.

What good visibility looks like

If the challenge is fragmented visibility, the goal is the right data: clear, accessible, and ready to use.

Firms that are moving forward are focusing on:

• Creating a single, consistent view of suppliers and services
  Reducing duplication and ensuring everyone is working from the same information.

• Standardising how data is collected and shared
  So risk, compliance, and procurement teams aren’t asking the same questions in different ways.

• Linking operations, suppliers, and risk clearly
  Making it easier to understand how disruption would actually impact the business.

• Improving accessibility of information
  So the right people, especially senior stakeholders, can get what they need, when they need it.

In short, visibility becomes something that is designed into the operating model, not stitched together afterwards.

From firm-level visibility to industry-wide clarity

Improving visibility within a single organisation is one step.

But many of the biggest challenges, particularly around third-party risk, don’t exist in isolation.

Suppliers serve multiple institutions.
Assurance is repeated across the market.
And visibility gaps are often shared, not unique.

This is where industry collaboration starts to matter.

What is a Hellios community? 

A Hellios community brings together financial institutions and their suppliers into a shared, standardised assurance model.

Instead of each firm independently collecting and managing supplier information, the community creates a common approach - reducing duplication and improving consistency across the market.

How does it work? 

• Suppliers complete standardised, region-specific questionnaires aligned to local regulatory and industry requirements

• Questionnaires are supported by local teams, ensuring relevance and clarity

• Each buying organisation benefits from dedicated Service Delivery Managers, providing ongoing support and oversight

• Information is centrally managed and maintained, rather than repeatedly requested

• Buying organisations access consistent, comparable data across their supplier base

This creates a model that combines standardisation with local relevance, rather than forcing a one-size-fits-all approach.

How does this support visibility? 

• A clearer, more consistent view of suppliers
  Standardisation improves comparability and reduces gaps in understanding

• Information when you need it
  Data is accessible, structured, and ready to support decision-making

• Reduced duplication and effort
  Less time chasing information means more time using it effectively

• Dedicated support throughout
  Both Buyers and suppliers are supported to ensure quality and completeness

• Localised, relevant questionnaires
  Aligning to regulatory expectations like CPS 230 while remaining practical

Start seeing clearer 

CPS 230 has made one thing clear: visibility is no longer optional.

The institutions that move beyond fragmented views and toward connected, usable insight will be better placed to manage risk, reduce effort, and demonstrate true resilience.