The Hidden Cost Of CPS 230 Compliance

But beneath the surface, a different challenge is emerging: the cost of running CPS 230 is higher than expected. 

Not because the regulation is inherently expensive, but because many firms are operating it through manual, fragmented, and duplicated processes. 

Where the cost starts to build 

Across large institutions, the same pressure points are appearing:

• Manual third-party assurance at scale
  Supplier oversight is often still driven by bespoke questionnaires, email follow-ups, and manual evidence reviews, effort that grows linearly with the supplier base.

• Duplication across teams
  Risk, procurement, compliance, and business units frequently request similar information independently, creating internal inefficiency.

• Over-assurance without clear risk differentiation
  In the absence of considered, adaptable approaches, firms default to treating many suppliers the same, creating unnecessary effort.

• High cost of maintaining data
  Information quickly becomes outdated, requiring repeated outreach, validation, and reconciliation.

• Tactical solutions becoming permanent
  Quick fixes implemented to meet deadlines are now embedded in day-to-day operations, driving ongoing cost.

Individually, these may seem manageable.
Together, they create an operating model that complies - but doesn’t scale efficiently.

What an efficient operating model looks like

If the challenge is rising cost, the goal is not fewer controls, it’s delivering assurance in a more efficient, scalable way.

Firms that are moving forward are focusing on:

• Reducing duplication of effort
  Ensuring supplier information is collected once and reused across teams.

• Standardising assurance approaches
  Moving away from bespoke questionnaires toward consistent, repeatable models.

• Improving reusability of data
  So information doesn’t need to be repeatedly requested and validated.

• Aligning effort to risk
  Applying deeper assurance where it matters most, rather than uniformly across all suppliers.

• Shifting from manual to coordinated processes
  Reducing reliance on email-driven, resource-intensive workflows.

In short, efficiency comes from rethinking how assurance is delivered, not weakening it.

From firm-level efficiency to industry-wide scale

Many of these cost challenges don’t originate within a single organisation.

They are systemic across the market:

• Multiple firms assessing the same suppliers

• Suppliers responding to repeated, similar requests

• Assurance being recreated rather than reused

This creates a model where cost is magnified and multiplied across the entire ecosystem. 

When the scale of the challenge is this large and systemic - it requires a coordinated approach.

What is a Hellios community? 

Hellios is the organisation that designs and operates industry communities. Bringing institutions and their suppliers together into a shared, structured assurance model.

For financial services, this is FSQS.

Built to be regionally relevant, FSQS aligns to local regulatory expectations such as CPS 230, while maintaining a consistent underlying approach.

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.

Why local teams matter?

A standardised model only works if the data behind it is complete, accurate, and maintained over time - this is where local support becomes critical.

• Driving supplier engagement
  Local teams actively support suppliers through the process, helping ensure questionnaires are completed fully and on time.

• Improving quality and consistency
  Guidance and clarification reduce incomplete or inconsistent responses, improving the reliability of the data.

• Ensuring local relevance
  Questionnaires are shaped and supported by teams who understand regional regulatory expectations - so the information gathered is not just complete, but genuinely useful and aligned to frameworks like CPS 230.

• Reducing delays and follow-ups
  With hands-on support, firms spend less time chasing responses or validating submissions.

• Ensuring long-term sustainability
  Unlike models that rely solely on self-service, ongoing local support helps maintain engagement and data quality over time.

Without this layer, even well-designed frameworks can struggle - particularly at scale, where low completion rates and inconsistent data quickly undermine value.

How does this reduce cost? 

• Less duplication across teams and firms
  Information is collected once and reused across the FSQS community

• Reduced supplier fatigue
  Suppliers respond to a single, structured set of requests—rather than multiple variations

• More efficient assurance processes
  Standardisation, combined with local support, improves both speed and quality

• Better alignment to regulatory expectations
  Regional questionnaires ensure relevance to frameworks like CPS 230

• Ongoing support through dedicated Service Delivery Managers
  Helping organisations get the most value from the data, not just collect it

The real challenge of CPS 230 isn’t compliance.

The real challenge is running compliance efficiently at scale. By reducing duplication and improving how data is shared and used, firms can lower cost while strengthening their response to multiple regulatory demands.