Getting Unit Pricing Oversight right: Why it matters more than ever under CPS 230

In the world of investment operations, unit pricing is one of those essential processes that’s rarely in the spotlight – until something goes wrong. When it does, the impact can be serious: the value of member balances is at stake, reputational risk spikes and remediation efforts can consume valuable time, money and resources. 

That’s why unit pricing oversight deserves fresh attention, especially now, with APRA’s CPS 230 Prudential Standard on Operational Risk Management coming into effect in just a few months. It raises the bar on accountability, control effectiveness, and incident response across core processes, including investment operations. Unit pricing is squarely in scope. 

The complexity behind the numbers 

Unit pricing sounds simple on paper, calculate the value of assets and divide by the number of units on issue. But in practice, it’s a high-stakes, multi-step process involving multiple systems, data sources, and stakeholders. 

You’ve got daily asset valuations, corporate actions, unlisted asset revaluations, tax adjustments, cash reconciliations, fee accruals – the list goes on. All of it needs to be timely, accurate, and backed by a robust audit trail. 

Errors often arise from inconsistent data, manual hand-offs, unclear responsibilities, or delays in exception handling. Even a single missed valuation or duplicated entry can ripple through the entire process. 

CPS 230 is raising the stakes 

APRA's Prudential Standard CPS 230 is important because it embeds operational risk management on the board agenda. It is driving a fundamental shift in how operational risks, including those embedded in unit pricing, are managed, monitored, and mitigated.  

Its core objective is to ensure that organisations are resilient to operational risks and disruptions, with a particular emphasis on critical operations such as unit pricing. Under CPS 230, boards and senior management are explicitly accountable for operational risk management. This means that every step of the unit pricing process, from data acquisition and calculation to reconciliation and publication, needs to be governed by rigorous controls, real-time monitoring, and continuous improvement. 

By tackling these risks head-on, CPS 230 will help reduce the likelihood of financial harm to members and reinforce confidence in the fairness and resilience of unit pricing processes. 

The power of reconciliation and sign-off 

One of the most effective ways to manage this risk is a strong reconciliation and sign-off process. It serves as both a compliance step and a foundational control that ensures inputs are accurate, exceptions are addressed, and changes are justified. 

A solid process typically includes: 

• Pre-pricing checks and reconciliations (e.g. cash, asset holdings)
• Exception reporting with clear escalation paths
• A documented daily sign-off workflow, including second-line oversight where required
• Logging of overrides and adjustments for transparency and auditability 

These practices not only prevent errors – they build trust. Regular, independent reviews by internal audit, risk, or compliance functions ensure calculations are accurate and controls are working as intended.

Why automation matters

Manual oversight may have worked in the past, but it’s no longer viable at scale, especially when data is coming from multiple custodians, administrators, and internal systems. 

Automation and smart workflow design are rapidly becoming the gold standard. The benefits are immediate and wide-reaching: fewer manual steps, faster exception handling, and improved visibility across the pricing lifecycle. 

By automating key parts of the oversight process like data ingestion, exception checks, and daily sign-off, investment operations teams can reduce risk, improve efficiency, and react more confidently to emerging issues. 

Platforms like AlphaCert are designed for this kind of oversight. They bring together data from different sources, apply logic and validation checks, and support structured workflows for approvals and exception management. Every approval, override, or exception is logged and traceable, supporting both internal controls and external audits. This transparency is critical for meeting CPS 230’s requirements for robust operational risk management. 

A good time to reassess 

With CPS 230 on the horizon, now is a good time for investment operations leaders to reassess their unit pricing oversight framework. Where are the manual steps? Where do errors creep in? How long does exception handling take? And are you confident in your ability to explain and evidence your controls? 

The case for automating unit pricing oversight is clear. It delivers the accuracy, efficiency, and resilience demanded by today’s regulatory and operational environment. For superannuation funds and investment managers, investing in automation is no longer a luxury but a strategic imperative for compliance, competitiveness, and member trust. 

See how AlphaCert can strengthen your unit pricing oversight and help meet CPS 230 requirements. Explore how to streamline controls, reduce manual effort, and gain real-time visibility across your pricing processes. Contact us or request a demo today.