The Security of Critical Infrastructure (SOCI) Act 2018, which was significantly amended in 2021 and further refined in subsequent updates, is Australia’s framework for strengthening the resilience of critical infrastructure. If you work in energy, water, healthcare, telecommunications, transport, or financial services, you are in the government's spotlight. The goal is to ensure these essential services can withstand cyber threats, adapt to evolving risks, and maintain operational resilience—even in the face of a storm.

The Act is managed by the Department of Home Affairs and the Australian Signals Directorate (ASD), with strict enforcement measures to ensure compliance. It establishes requirements such as mandatory cyber security risk management programmes, incident reporting, and enhanced operational security measures for organisations classified as Systems of National Significance (SoNS). If you operate in this space, expect heightened scrutiny and additional security expectations. You can learn more at the Cyber and Infrastructure Security Centre website which includes links to the SOCI legislation.

Understanding the SOCI Act and its impact on operational technology (OT)

The SOCI Act requires organisations to step up their cyber security game. Companies managing critical infrastructure must develop risk management programmes (RMPs) to address cyber threats. The ASD has intervention powers, meaning that if a serious cyber event occurs, the government can step in and take control.

Cyber incidents affecting critical infrastructure assets must be reported within 12 hours for significant impacts and 72 hours for other breaches. Organisations classified as SoNS have even greater obligations, including real-time threat monitoring and intelligence sharing with the government.

Third-party responsibilities under the SOCI Act

Organisations rely on third-party vendors, service providers, and contractors to maintain operations. However, this also introduces additional risks. Third parties must follow robust cyber security practices to avoid becoming the weakest link in the supply chain. If a security breach affects a critical infrastructure entity, the third party is responsible for promptly notifying the organisation. The responsibility for reporting the incident to regulators within SOCI Act timeframes falls on the critical infrastructure entity.

Beyond reporting, vendors must implement robust security controls, such as restricted access, encryption of sensitive data, and network security measures to protect against external threats. Regular risk assessments and security audits are essential to identifying vulnerabilities before they become critical issues and are part of the requirements. Additionally, continuous monitoring and incident response planning should be standard practice to maintain resilience.

Risk appetite and security alignment

Every organisation has a different risk appetite—some aim to eliminate risk entirely, while others balance security with operational efficiency. The SOCI Act mandates that companies integrate their risk appetite into Critical Infrastructure Risk Management Programmes (CIRMPs). Whether you are on the extreme end of cybersecurity controls or lean towards a more flexible model, your security posture must align with regulatory expectations.

A well-structured security approach ensures compliance without disrupting operations. Cyber defences need to be adaptable to evolving threats while maintaining business continuity. The SOCI Act pushes companies to create dynamic risk assessment frameworks, ensuring that security measures evolve alongside emerging threats.

For SoNS entities, this extends even further, requiring real-time threat intelligence sharing and continuous security validation to keep pace with an ever-changing risk landscape.

Strengthening security posture

Cyber security is not just about ticking compliance boxes - it is about protecting critical infrastructure while maintaining efficiency. Organisations should have round-the-clock security operations in place to detect and respond to threats immediately. Security strategies must align with SOCI Act requirements but also be tailored to business operations.

OT security extends beyond industrial servers—it includes process control levels, where cyber threats can directly impact physical operations. Monitoring and securing programmable logic controllers (PLCs), remote terminal units (RTUs), and other OT components is just as critical as protecting IT environments. Having a security operations centre (SOC) that understands OT environments and can monitor, respond to, and mitigate threats across all infrastructure levels is essential for true resilience.

Just as physical storms can disrupt operations, cyber threats act as unseen storms, making real-time visibility and proactive response crucial to business continuity.

Ensuring third-party risk management is a priority, as supply chain vulnerabilities can introduce significant security gaps. Partnering with government and industry groups to share threat intelligence helps organisations stay ahead of emerging threats. Security frameworks should be tailored to your organisation’s unique environment, rather than adopting a one-size-fits-all approach.

Key challenges in compliance and cyber security

Meeting SOCI Act requirements is complex. Many organisations struggle to integrate IT security practices into OT environments, where systems often prioritise uptime over security. Budget constraints and cyber security skills shortages add another layer of difficulty, making it challenging to implement advanced security controls.

Additionally, cyber adversaries continue to evolve. A defensive approach alone is not enough—organisations must adopt proactive threat hunting, continuous monitoring, and rapid response capabilities to keep up with increasingly sophisticated cyber threats.

Effective strategies for compliance and security

To navigate these challenges, organisations need a comprehensive cyber security strategy that balances compliance with operational resilience. Key measures include:

  • Leveraging cyber security advisory services to develop a tailored security framework
  • Implementing 24/7 SOC monitoring to detect and respond to threats in real time across IT and OT environments
  • Strengthening supply chain security by enforcing third-party risk management practices
  • Conducting regular security audits and penetration testing to identify vulnerabilities before attackers do

The SOCI Act has fundamentally reshaped cyber security for OT environments in Australia. Compliance is critical, but the key is integrating security measures seamlessly into business and OT operations. By aligning cyber security strategies with an organisation’s risk appetite, businesses can ensure they are both secure and operationally efficient.

CGI in Australia is providing security operations centre (SOC) services to clients that are classified as SOCI. We have seen first-hand the challenges and opportunities this regulation brings. The key takeaway? Compliance should not be a checkbox exercise—it should be a framework for building true cyber resilience.

How is your organisation adapting to the SOCI Act? Get in touch to discuss your challenges.