Cybersecurity Checklist for 2026

Assess your organisation’s cybersecurity posture for 2026

Access the full cybersecurity checklist and identify key priorities for Essential Eight, ISO/IEC standards, and AI governance.

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What Australian organisations should be prioritising now

As 2026 begins, Australian organisations are entering the year with cybersecurity positioned firmly as a governance and assurance priority. Regulatory expectations are increasing, artificial intelligence is becoming operational rather than experimental, and boards are seeking clear evidence that cyber and data risks are being managed effectively.

Early in the year is the most critical time to set direction. Decisions made now will determine whether cybersecurity programs remain reactive or mature into structured, defensible systems that can withstand regulatory scrutiny and evolving threats.

This cybersecurity checklist for 2026 outlines the areas Australian organisations should be reviewing at the start of the year to establish clarity, resilience, and confidence.

1. Confirm Board and Executive Ownership of Cyber and AI Risk

At the beginning of 2026, organisations should confirm that cybersecurity and AI risk ownership is clearly defined.

This includes ensuring that:

Cyber and AI risks are formally recognised within enterprise risk management
Board and executive accountability is documented and understood
Reporting focuses on risk exposure, control effectiveness, and assurance
Governance aligns with recognised management system standards

Frameworks such as ISO/IEC 27001 and ISO/IEC 42001 support structured leadership involvement by embedding accountability and continual improvement into organisational governance.

2. Revalidate Regulatory and Legislative Alignment

Regulatory expectations do not pause at year-end.

As 2026 begins, organisations should revalidate alignment with:

Privacy Act obligations and expected reforms
APRA CPS 234 and ASIC cyber resilience guidance, where applicable
Industry requirements such as PCI DSS v4.0
Government and public-sector expectations, including the APS AI Plan 2025

Early validation reduces the risk of compliance gaps emerging later in the year.

3. Review ISMS Scope and Effectiveness (ISO/IEC 27001)

The start of the year is an appropriate time to assess whether the Information Security Management System still reflects operational reality.

Organisations should consider:

Whether the ISMS scope remains accurate
If risk assessments reflect current business, cloud, and third-party exposure
Whether controls are operating as intended
If internal reviews and independent audits are planned and scheduled

Certification to ISO/IEC 27001 provides independent confirmation that the ISMS remains effective and aligned with business objectives.

4. Assess Privacy Governance and Data Protection (ISO/IEC 27701)

Privacy risk continues to attract heightened regulatory and public attention in Australia.

At the beginning of 2026, organisations handling personal data should ensure:

Privacy management is integrated into the ISMS
Data handling practices are documented and controlled
Privacy responsibilities are clearly assigned
Privacy risk is reviewed alongside security risk

ISO/IEC ISO/IEC 27701 supports structured privacy governance and provides assurance that privacy controls are managed systematically.

5. Set Essential Eight Maturity Targets for the Year Ahead

The Australian Signals Directorate’s Essential Eight remains a central benchmark for cyber resilience.

Early in 2026, organisations should:

Confirm current Essential Eight maturity levels
Set realistic maturity targets based on risk exposure
Define governance for exceptions and risk acceptance
Plan for periodic maturity reassessment

Treating Essential Eight as an ongoing program, rather than a static requirement, supports sustainable resilience.

6. Establish AI Governance and Risk Oversight (ISO/IEC 42001 & APS AI Plan 2025)

AI is no longer emerging—it is operational.

At the start of 2026, organisations should identify:

Where AI systems are in use or planned
How data is accessed, processed, and retained within AI systems
Who is accountable for AI outcomes and decisions
Alignment with principles outlined in the APS AI Plan 2025, particularly transparency and human oversight

ISO/IEC 42001 provides a structured framework for managing AI risks through governance, accountability, and continual improvement.

7. Confirm Payment Security Readiness (PCI DSS & PCI ASV)

For organisations involved in payment processing, early-year validation is essential.

Organisations should:

Confirm alignment with PCI DSS v4.0 requirements
Validate scope and segmentation of cardholder data environments
Schedule required assessments and vulnerability scanning with an approved PCI ASV
Review evidence and documentation from prior assessments

Early action reduces the risk of non-compliance later in the year.

8. Review Incident Response Preparedness

Incident response readiness should be confirmed before incidents occur.

At the start of 2026, organisations should:

Review incident response plans and escalation paths
Confirm roles and responsibilities
Validate communication procedures
Schedule response testing and scenario exercises

Preparedness is increasingly assessed by regulators following incidents.

9. Reassess Third-Party and Supply Chain Risk

Third-party exposure evolves continuously.

Organisations should begin the year by:

Reviewing critical suppliers and service providers
Confirming security expectations and contractual obligations
Updating third-party risk assessments where required
Ensuring incident notification requirements remain clear

Supply chain assurance remains a key focus area for regulators and customers.

10. Plan Independent Assessment and Assurance Activities

Finally, organisations should plan assurance activities early in the year.

This includes:

Scheduling independent audits and assessments
Planning certification or surveillance activities
Reviewing prior assessment findings
Defining improvement actions and timelines

Independent assurance provides structure and credibility to cybersecurity programs.

An Australian Starting Point with a Global Outlook

While this checklist reflects Australian expectations, the direction is global. Organisations worldwide are moving toward:

Management-system-based cybersecurity and AI governance
Continuous compliance and assurance
Stronger accountability at board and executive level

Organisations that establish clarity and structure early in 2026 will be better positioned to meet both domestic and international expectations.

Setting the Foundation for 2026

The beginning of the year is the most effective time to strengthen cybersecurity governance and assurance. By reviewing controls, setting maturity targets, and planning independent validation early, organisations can approach 2026 with confidence.

Risk Associates is a leading provider of independent certification, assessment, and assurance services for organisations across Australia and internationally, focused on clarity, resilience, and trust from the outset of the year.

FAQs – Frequently Asked Questions

What is the most important cybersecurity priority for Australian organisations in 2026?

The most important priority in 2026 is demonstrating governance, control effectiveness, and independent assurance. Australian organisations are expected to show that cybersecurity risks are managed through recognised frameworks such as ISO/IEC 27001, aligned with Essential Eight maturity, and supported by evidence—not just policies or tools.

How does the Essential Eight fit into a broader cybersecurity program?

The Essential Eight provides a baseline for cyber resilience in Australia, but it should not operate in isolation. In 2026, organisations are expected to integrate Essential Eight maturity into a broader information security management framework, such as ISO/IEC 27001, supported by governance, risk assessment, and continual improvement.

Is ISO/IEC 27001 still relevant in 2026?

Yes. ISO/IEC 27001 remains a foundational standard for managing information security risk in 2026. It provides a structured, risk-based management system that supports governance, regulatory alignment, and independent assurance. Many Australian regulators and customers continue to recognise ISO/IEC 27001 certification as a strong indicator of security maturity.

What is ISO/IEC 42001 and why does it matter in 2026?

ISO/IEC 42001 is the international standard for AI management systems. It helps organisations govern AI risks related to data usage, decision-making, accountability, and transparency. In 2026, as AI becomes operational across many organisations, ISO/IEC 42001 supports responsible, auditable, and compliant AI use—particularly when aligned with the APS AI Plan 2025.

How does ISO/IEC 27701 support privacy compliance in Australia?

ISO/IEC 27701 extends ISO/IEC 27001 to address privacy information management. It helps organisations structure how personal data is handled, protected, and governed. In Australia, it supports alignment with Privacy Act obligations by embedding privacy risk management into existing information security frameworks.

Who needs to comply with PCI DSS in 2026?

Any organisation that stores, processes, or transmits payment card data must comply with PCI DSS. This includes merchants, service providers, and organisations using outsourced payment environments. In 2026, PCI DSS v4.0 places greater emphasis on ongoing control validation and risk-based security management.

What is the role of a PCI ASV?

A PCI Approved Scanning Vendor (ASV) performs required external vulnerability scanning for PCI DSS compliance. Regular ASV scanning helps organisations identify and address vulnerabilities affecting payment card environments and provides evidence of compliance with specific PCI DSS requirements.

How does the APS AI Plan 2025 affect non-government organisations?

While the APS AI Plan 2025 is primarily focused on Australian government entities, its principles increasingly influence expectations for organisations supplying or interacting with the public sector. These principles, such as transparency, accountability, and safe AI use, are also becoming relevant benchmarks for private organisations adopting AI technologies.

Why is independent assessment important for cybersecurity in 2026?

Independent assessment provides objective assurance that security controls are effective and aligned with recognised standards. In 2026, regulators, customers, and partners increasingly expect independent validation, through audits, certification, or formal assessments—to support trust and compliance claims.

How often should cybersecurity assessments be performed?

Cybersecurity assessments should be performed regularly and aligned with risk exposure, regulatory requirements, and organisational change. Many organisations conduct annual independent assessments, supported by ongoing internal reviews and continuous monitoring throughout the year.

How can organisations prepare for cybersecurity assessments at the start of the year?

Early preparation includes reviewing governance structures, confirming scope and risk assessments, validating documentation, and planning assurance activities. Addressing gaps early in the year reduces the risk of non-compliance and supports smoother audits and certifications later in 2026.

How does this checklist support global cybersecurity expectations?

While written from an Australian perspective, this checklist aligns with global trends toward management-system-based security, AI governance, privacy integration, and continuous assurance. Organisations adopting these practices are better positioned to operate across jurisdictions and meet international stakeholder expectations.