01. Australian State Cyber Testing Matrix
State government security assurance programs are increasingly audited by respective State Auditors-General. The table below compares the specific penetration testing mandates and vulnerability management requirements across the five major states.
| State | Governing Policy | Explicit Penetration Testing Mandate |
|---|---|---|
| Victoria | VPDSS V2.0 (OVIC) | Explicitly required under element E11.040 for risk-prioritised vulnerability management across departments and contracted suppliers. |
| New South Wales | NSW CSP 2026–2027 | Mandates continuous vulnerability triage (1.11) and pre-change assessment (1.12); pentest results serve as primary audit evidence for annual Oct 31 attestations. |
| Queensland | QGEA Policy IS18 | Guideline requires regular penetration testing of systems storing medium or high business impact data, and pre-deployment scans of public-facing apps. |
| Western Australia | WA Gov CSP 2024 | Requires vulnerability management governance (1.7); WA Auditor-General explicitly recommends routine penetration testing across all public entities. |
| South Australia | SACSF Standard 4.16 | Strictly mandatory: independent penetration testing before deployment, after major architectural changes, and at least annually for all public web services. |
02. Victoria: VPDSS V2.0 & Health Sector Mandates
Administered by the Office of the Victorian Information Commissioner (OVIC) under the Privacy and Data Protection Act 2014 (Vic), the Victorian Protective Data Security Standards (VPDSS) V2.0 establish 12 mandatory standards for public bodies.
ICT Security: Risk-Prioritised Vulnerability Management
Element E11.040 explicitly identifies penetration testing, patch management, and continuous technical monitoring as mandatory activities. Departments must document their testing programs in their biennial Protective Data Security Plan (PDSP) submitted to OVIC.
Victoria Health Sector Requirements (VMIA & VAGO)
Following the Victorian Auditor-General's Office (VAGO) audit into hospital patient data security, the Department of Health and VMIA established an ongoing health assurance program. Every public health service and registered community health organization is required to maintain a structured penetration testing program covering clinical web portals and telehealth APIs.
03. New South Wales: NSW Cyber Security Policy (2026–2027)
The NSW Cyber Security Policy 2026–2027 applies to all NSW Government departments, executive agencies, and statutory state-owned corporations.
Vulnerability Management & Triage
Agencies must establish and maintain continuous processes to identify, triage, and remediate technical vulnerabilities across digital services and APIs.
Security Impact Assessment in Change Management
Prior to deploying major updates or new web applications, agencies must evaluate the cyber security impacts and verify that changes introduce no exploitable flaws.
Every agency must submit an annual attestation signed by the Department Secretary or Agency Head to Cyber Security NSW by 31 October, detailing technical assurance results.
04. Queensland: QGEA Policy IS18 & Vulnerability Guidelines
Queensland's Information and Cyber Security Policy (IS18) mandates an Information Security Management System (ISMS) aligned with ISO/IEC 27001.
QGEA Vulnerability Management Guideline
The Queensland Government Enterprise Architecture guideline explicitly states that agencies should regularly test systems processing confidential or high-impact citizen data. Furthermore, all new or modified internet-facing web portals must undergo vulnerability assessments and penetration tests prior to public release, coordinated with the Queensland Government Cyber Defence Centre (QGCD).
05. Western Australia & South Australia (SACSF)
2024 WA Gov Policy (Office of Digital Govt)
Requires entities to implement vulnerability management governance (1.7), vulnerability disclosure programs (1.8), and Essential Eight ML1. The WA Auditor General's 2025 report urges routine penetration testing to eliminate systemic security deficits across state databases.
SACSF Standard 4.16: Secure Web Services
The most prescriptive state standard in Australia. Standard 4.16 mandates:
- Penetration testing before deployment and after major changes.
- Annual independent penetration testing of all public-facing services.
- Formal remediation tracking with retesting of all high-severity findings.
06. What This Means for SaaS & ICT Suppliers
Software vendors, cloud service providers, and contractors selling into state governments cannot treat compliance as an agency-only burden. State procurement panels systematically enforce security flow-down clauses:
Contractual Mandate in Victoria
Under the PDP Act, contracted service providers (CSPs) that handle public sector information are legally bound to uphold VPDSS standards, including Element E11.040 vulnerability testing.
Annual Vendor Assurance in South Australia
SACSF requires South Australian agencies to verify supplier assurance annually via recent third-party penetration testing reports or SOC 2 Type II attestations.
Rapid Delta Retest Evidence
When vulnerabilities are identified during procurement audits, vendors must supply verified delta retest proof confirming remediation within contractually specified SLAs.
07. How Infiltra Supports State Government Assurance
Infiltra provides autonomous AI-augmented penetration testing designed for Australian state agencies and enterprise suppliers requiring sovereign data handling and rapid turnaround:
100% AWS Sydney Data Residency
All attack orchestration, reasoning models, and vulnerability reports remain confined to the AWS Sydney (ap-southeast-2) region, satisfying state privacy and data sovereignty laws.
Pre-Deployment & Annual Retesting
Fulfill South Australia SACSF Standard 4.16 and NSW CSP 1.12 with on-demand tests before feature releases, followed by 1-click delta retests once developers commit patches.
Auditor-Ready Technical Dossiers
Generate formal executive summaries and technical vulnerability breakdowns mapped directly to ASD ISM controls and state procurement checklists.
Eliminate False Positives
Every vulnerability identified by Infiltra includes verifiable proof of exploitability, ensuring public sector engineering teams never waste time investigating scanner hallucinations.
08. Frequently Asked Questions
Key answers on Australian state government penetration testing mandates and supplier obligations.
State Policies
Do Australian State Governments Require Penetration Testing?
Do Australian State Governments Require Penetration Testing?
Yes. South Australia's SACSF Standard 4.16 mandates penetration tests for public-facing web services annually and before major releases. Victoria's VPDSS explicitly specifies penetration testing as a mandatory vulnerability management activity, and Queensland, NSW, and WA mandate technical assurance programs across public sector systems.
Third-Party Risk
Do These Rules Apply to Third-Party Suppliers and SaaS Vendors?
Do These Rules Apply to Third-Party Suppliers and SaaS Vendors?
Yes. In Victoria, the VPDSS applies directly to contracted service providers managing public sector information. South Australia requires agencies to obtain independent security attestation (such as current pentest reports or SOC 2 audits) from SaaS and ICT vendors annually.
Federal Alignment
How Do State Frameworks Relate to Federal ASD Requirements?
How Do State Frameworks Relate to Federal ASD Requirements?
State frameworks heavily incorporate the ASD Information Security Manual and the Essential Eight as their foundational technical standards. In particular, control ISM-2118's six-monthly penetration testing cycle is widely regarded by state auditors as the standard of good industry practice.