Archived - Superannuation Data Transformation FAQs

APRA intends to clarify the definition and instruction for the service arrangement engagement type in SRS 332.0 to: 

• Political donations (Expense type) = ‘means payments made for the purpose of political donations’
   
• Donation to a political party (Service arrangement engagement type) – ‘means payments that are political donations’

This is to capture all payments which are classified as ‘Political donations’, including where the purpose for which the expense was given is classified as a different expense type such as marketing.

APRA intends to work with industry to develop the worked example for release in mid-2023. The worked example is intended to illustrate APRA’s expectations that RSE licensees would have in place appropriate methodology for calculating the amount of a connected related entities’ dividends and retained earnings which are attributable to expenses of the RSE. APRA also intends to clarify in SRS 332.0 that the reference for Table 4 is to include s.13(4D)(e) of the Financial Sector (Collection of Data) Act 2001 (FSCODA).

APRA intends to update SRS 332.0 Expenses to clarify that the minimum reporting threshold for the above-mentioned expense types is $5,000 AUD. This is as indicated in APRA’s response letter to industry dated 3 March 2023.

RSE licensees are required to classify and report all payments regardless of the materiality threshold. However, for payments of less than $5,000 AUD where the RSE licensee does not have the service provider details, the RSE licensee is not required to identify the service provider and can report the service provider identifier with the Service Provider Name Text as ‘multiple payees’.

Yes, APRA will extend the best endeavours approach that was in place up until the March 2023 quarter, for one additional quarter. RSE Licensees may apply the same approach for the June 2023 quarter. This is in recognition that the implementation date for the new SRS 550.0 does not come into effect until 30 September 2023.

APRA expects RSE licensees to report the inception date of an investment option as when the option was first made available to members (as per SRS 605.0). APRA intends to clarify the description for the Investment Performance Start date in SRS 605.0 as the date that the investment option received its first contribution or funding from a member, which is the date when the RSE licensee can begin to measure investment performance for a member. 

Yes, APRA intends to update the description in table 2 in SRS 606.1 to reflect that the description for these fields should be reported for the combination of product, menu, option and fee and costs arrangement.

APRA intends to amend the definition in SRS 101 to ‘the indirect cost that is separately disclosed by the external manager or product provider and is not disclosed by the RSE licensee'.

APRA intends to clarify in the reporting standards that the exclusions for SRS 550.0, SRS 705.0, SRS 705.1 and SRS 706.0 apply to:

• investment options that are classified as Investment Option Category Type of ‘Insurance Only’;
• superannuation products where the Product Category Type is 'Insurance Only’ or ‘Whole of life or endowment’; and
• investment options which solely underlie an ‘Insurance Only’ or ‘Whole of life or endowment' superannuation product category type.

APRA will clarify the instructions in SRF 550.0, SRF 605.0, SRF 705.0 and SRF 705.1 as per FAQ 1.24.

The revised definitions in the amended SRS 101.0 will commence when the instrument is registered and apply to reporting periods ending on or after 30 June 2023. However, APRA only expects entities to apply the amended definitions to new and amended reporting standards as they take effect. For consistency, entities reporting under current reporting standards (where the relevant amended reporting standard have not yet taken effect) should continue to use the definitions in the current SRS 101.0.   

APRA proposes to clarify in SRS 332.0 the expectations on RSE licensees when applying the definition of ‘connected entity’ and the look-through requirements outlined below. 

• Where a payment is made by the entity or on behalf of the entity to an industrial body, report the details of the industrial body as the service provider for that expense in Table 1 and report the service provider type as ‘Industrial Body’;
   
• Where the expense is incurred with a service provider or other payee who is not a connected entity, report the service provider or payee; and
   
• For all other expenses, if there is no connected entity, report the receiving entity. If expenses are with a connected entity, look through to identify if the provision of that service is by a further connected entity (the look-through chain) and report the last connected entity in the look-through chain.

Where the expense is in relation to money, consideration or any other benefit given to an entity (the receiving entity) by the RSE licensee or a connected entity (the paying entity), APRA expects RSE licensees to obtain information about the following: 

• Details of the receiving entity and the relationship between the receiving entity and the paying entity (Table 1); 
   
• The purpose for which the money, consideration or other benefit is given. Where the expense payment is for multiple purposes, obtain sufficient information to report the amount for each expense type for which the expense is incurred (Table 2 and 3); and
   
• For related connected entities, identify the way in which the money, consideration or other benefit is used by the receiving entity, and any entity with which that entity deals, including the extent to which the receiving entity’s profit is attributable to that money, consideration or other benefit (Table 4).

For the avoidance of doubt, the corporate overheads of a service provider that is a connected entity do not need to be reported, including corporate overheads with a further connected entity, e.g. if a connected service provider uses a bank which is a connected entity of the RSE licensee.

APRA also proposes to update the worked example, including illustrations of look-through reporting by RSE’s under the amended reporting standard, noting the principals outlined in the current worked example are still current.

APRA proposes to amend SRS 606.0 to extend the due date for SRF 606.1 for the 30 June 2023 and 30 September 2023 reporting periods to 3 November 2023.

APRA also proposes to amend SRF 606.1 to clarify that investment options with investment option category type  of ‘Direct Cash Account’, ‘Direct Term Deposit’, ‘Direct Fixed Income Instrument’, ‘Direct Shares’, ‘Direct Hybrid Security’, or ‘Annuity’ do not need to be reported in Table 2 ‘Member accounts (fee and cost arrangements)’ of SRF 606.1. 

APRA proposes to amend SRS 332.0 to clarify the reporting instructions for Table 4 ‘Related party reporting’ to exclude related connected entities where the employer sponsor is a related connected entity only due to a standard employer sponsor arrangement and the relationship with that entity does not result in a relevant duty or a relevant interest in accordance with Prudential Standard SPS 521 Conflicts of Interest.  
 

On 21 June 2022, APRA provided an extension to the due date for the period ending 30 June 2022 (and where relevant, associated historical data reporting) for SRF 550.0 under SRS 550.0, SRS 705.0, SRS 705.1 and SRS 706.0 from 28 July 2022 to 28 October 2022 for:

• investment options which solely underlie defined benefits; and
• investment options which are not investment options underlying a MySuper product or trustee-directed product and:
  • the Investment Option Type is ‘Direct’; or
  • the Investment Option Category Type is ‘Single sector’.

The impact on the due dates for the historical data and for the period ending 30 June 2022 is shown in the tables below.

Historical data

Accepted file submission formats are as noted on the APRA Connect technical specifications page on the APRA website.

Accepted submission formats for the Superannuation Data Transformation Phase 1 reporting standards are: Manual entry, XML, and Excel.

Generally, entities are able to make this choice based on their own organisation’s needs and technical capabilities; however if the data being uploaded exceeds the row limits allowed in Excel then entities should use XML.

Further APRA Connect information and support material is available on the APRA website at: APRA Connect support material.

On 7 October 2022, APRA provided an extension to the reporting due date in respect of some investment options:

1.    For the following Superannuation Reporting Standards:

• SRS 550.0 Asset Allocation (SRS 550.0); 
• SRS 705.0 Components of net return (SRS 705.0); and
• SRS 705.1 Investment Performance and Objectives (SRS 705.1).

APRA extended the reporting due date from 28 days after the quarter end to 35 days after the quarter end, in respect of all investment options for periods ending 30 September 2022, 31 December 2022, and 31 March 2023. 

2.    For the following Superannuation Reporting Standards:

• SRS 550.0 Asset Allocation; 
• SRS 705.0 Components of net return;
• SRS 705.1 Investment Performance and Objectives; and
• SRS 706.0 Fees and Costs (SRS 706.0)

APRA extended the reporting due date from 28 October 2022 to 28 July 2023 for investment options which have an Investment Option Category Type of:

• Direct Term deposit
• Direct Fixed Income Instrument
• Direct Shares
• Direct Hybrid Security
• Direct Listed Investment Company
• Direct Exchange Traded Product

APRA expects RSE licensees to have plans and processes in place to accurately report all investment option data prior to 30 June 2023. RSE licensees that are in a position to provide complete investment option reporting earlier are encouraged to do so.

For all investment options yet to be reported under the staged implementation, other than these six types of direct investment options:

• the due date for historical data required under SRS 550.0 and SRS 705.1, and for periods up to and including 30 June 2022 remains 28 October 2022. 
   
• as per item one above, the due date for the reporting period ending 30 September 2022 for these three reporting standards is 4 November 2022.

For reporting under SRF 550.1 Investments and Currency Exposure and SRF 550.2 Derivatives and Counterparties for the period ending 30 September 2022, the due date is 4 November 2022. 

The following table summarises the reporting periods and extended due dates under the Superannuation Data Transformation reporting standards:

Yes. APRA recognises there is a degree of overlap between data to be collected through the new reporting standards and data collected under existing reporting standards.  The existing reporting standards will continue for an initial parallel collection period, primarily to enable APRA to assess data quality for the new reporting standards. Once appropriate quality of reporting under the new framework is achieved, APRA intends to  provide exemptions from reporting obligations and/or revoke reporting standards which require the same data that is to be submitted under the new data collection.

APRA will undertake a separate consultation in late 2021 on proposals for publication of data reported under these reporting standards, including consulting on the confidentiality of the specific data items that APRA intends to publish.

 The SIS regulation which defines a trustee-directed product was made on 5 August 2021. APRA intends to update SRS 101.0 to include the definition for trustee-directed products as follows:

Trustee-directed product: Has the meaning given by subregulation 9AB.2(2) of Superannuation Industry (Supervision) Regulations 1994 (SIS).

Yes, RSE licensees that are in a position to provide full reporting earlier will be able to do so.

Validation rules for the new reporting standards can be viewed at the APRA Connect Taxonomy Artefacts page. APRA will post alerts via its subscriber list for updates to the Taxonomy Artefacts.

The draft artefacts include the data dictionary, validations, reporting taxonomy and XSD (to validate the structure of XML files). While every effort has been made to ensure accuracy, entities can expect further changes before APRA Connect goes live.

Updated versions of the artefacts will be available prior to the release of the external test environment in June.

APRA expects that all fees and costs will be reported gross of tax to ensure that there is consistency in reporting. For the avoidance of doubt, APRA intends to remove the line ‘consistent with the manner in which they are required to be disclosed in PDS’ in the ‘Reporting basis and unit of measure’ section of Reporting Standard 706.0 Fees and Costs.

Returns for each historical reporting period covered under the required timeframe will be available on APRA Connect for RSE Licensees to submit historical data.

APRA intends to consult on specific audit requirements for the new reporting standards as part of the review of the approved audit form under SPS 310 in the second half of 2021. For the 30 June 2021 annual reporting period there are no specific audit requirements beyond those detailed in Part 3 (B) Controls and Compliance in the approved audit form.

The SIS regulation which define a trustee-directed product was made on 5 August 2021. APRA will extend the due date for submission of 30 June 2021 data for trustee-directed products from 30 September 2021 to 28 October 2021 to allow sufficient time to implement reporting. RSE licensees that are in a position to provide the full coverage of reporting earlier are encouraged to do so.

In APRA’s response to consultation the staged implementation approach introduced temporary reduced coverage, with the first year of reporting on products, investment menus and investment options only including data on MySuper and trustee-directed products for the following four reporting forms:

• “SRF 705.0 Components of Net Return” (SRF 705.0)
• “SRF 705.1 Investment Performance and Objectives” (SRF 705.1)  
• “SRF 550.0 Asset Allocation” (SRF 550.0)
• “SRF 706.0 Fees and Costs Disclosed” (SRF 706.0)

RSE licensees must report 30 June 2021 data for MySuper products by 30 September 2021. 

APRA intends to allocate the returns for the historical data reporting periods in APRA Connect on 1 February 2022 after the 28 January 2022 submission due date for the superannuation December 2021 quarterly returns.

APRA also intends to allocate returns for the historical periods in the APRA Connect test environment from early December for entities to test these submissions.

APRA has published the SDT reporting standards with marked up changes here.

APRA has published a log of the changes to all versions of the APRA Connect artefacts issued at APRA Connect Taxonomy Artefacts. The latest version of the artefact file was released on 19 August 2021. 

The log includes:

• Schema: changes to elements, enumerations, etc;
• Validation rules: new or amended validation rules; and
• Rule restrictions: validation rules that have been restricted. 

A summary of taxonomy artefact changes can be found here:

The returns for the historical data collection will be allocated as individual returns for each reporting period (quarter or year) as relevant to that reporting standard.

APRA intends to release a discussion paper to consult with industry on the publication of data as well as confidential treatment of the data reported to APRA under the new reporting standards in February 2022.

APRA intends to begin consultation of Phase 2 of the SDT project in in quarter 1 of 2022.

In response to consultation feedback, APRA is revising the proposed timeframes for consultation. Timeframes will be outlined in the SDT Phase 2 Response Paper. APRA expects to release the SDT Phase 2 Response Paper in early August 2022.  

Where an RSE licensee offers Separately Managed Accounts or other MDAs, APRA expects RSE licensees to report each model portfolio offered as one investment option under SRS 605.0 with Investment Option Type ‘Direct’ and Investment Option Category Type ‘Other’. APRA does not expect RSE licensees to report each underlying investment as an investment option.

For each of these investment options, APRA expects the RSE licensee to report:

• the asset allocation targets of the model portfolio under SRS 550.0 Table 1 Strategic Asset Allocation
• the asset allocation of all investments held as at the end of the relevant quarter under SRS 550.0 Table 2 Actual Asset Allocation. 
• the investment return of the model portfolio under SRS 705.0 Components of Net Return.
• the investment objective of the model portfolio, and the investment return of the model portfolio under SRS 705.1 Investment Performance and Objectives. 

APRA intends to consult on the inclusion of an additional Investment Option Type classification under SRS 605.0 to allow RSE licensees to identify these types of investment options as MDAs.

APRA revoked Reporting Standard SRS 533.1 Asset Allocation and Member Benefit Flows (SRS 533.1); Reporting Standard SRS 703.0 Fees Disclosed (SRS 703.0); and Reporting Standard SRS 250.0 Acquired Insurance (SRS 250.0) in 2022.

APRA revoked Reporting Standard SRS 534.0 Derivative Financial Instruments (SRS 534.0) on 26 September 2023. RSE licensees no longer need to report under SRS 534.0 from 26 September 2023. 
APRA revoked Reporting Standard SRS 530.0 Investments (SRS 530.0) and Reporting Standard SRS 702.0 Investment Performance (SRS 702.0) on 1 December 2023.

For Reporting Standard SRS 533.0 Asset Allocation (SRS 533.0), from the period ending 30 September 2023, RSE licensees are exempted from reporting under SRS 533.0 in respect of MySuper products with a single diversified investment strategy.  The last reporting period required for SRF 533.0 in respect of MySuper products a standard investment strategy was for the period ending 30 September 2023.

APRA has not exempted RSE Licensees from reporting under SRS 533.0 in respect of MySuper products with a lifecycle investment strategy. RSE Licensees that offer MySuper products with a lifecycle investment strategy are required to continue to report under SRS 533.0 in respect of those products until further notice by APRA.

APRA intends to publish the March 2023 Quarterly Superannuation Industry Publication and the first Quarterly Product-level Superannuation Statistics in late June 2023.

APRA expects that data will be reported for transactions that occurred during the reporting period for each historical reporting period.

APRA expects RSE licensees to report in SRF 251.0 table 1 information about all insurance policies which:

1. were in force at any time during the reporting period ending 30 June 2021 or in the 5 years prior to the start of the reporting period; or
2. for which one or more of the following activities occurred during the reporting period ending 30 June 2021 or in the 5 years prior to the start of the reporting period:
   1. premiums were paid to the insurer; or 
   2. claims were received, processed or paid.
   3. RSE licensees will need to validate their own data to ensure the relevant historical data is reported for each insurance cluster. 
   4. APRA will verify the population post-submission and any inconsistencies will require a resubmission of the relevant form.
       

APRA has extended the due date for the submission of historical data for SRS 251.0 from 28 February 2022 to 30 May 2022.

RSE licensees are encouraged to submit this return earlier if they are able, noting that the reporting standard will be available in APRA Connect from early Februray 2022.

APRA expects that historical data will be reported under SRS 550.0 Asset Allocation and SRS 705.1 Investment Performance and Objectives for products, investment menus and investment options that have a start date prior to 30 June 2021 and do not have an end date at the due date of the historical data.

APRA does not expect historical data to be submitted for a product, menu or investment option that has been wound up prior to the historical data submission deadline.

If any investment options are transferred or continued in a new product, the historical data for these options still needs to be reported.

RSE licensees will need to validate their own data to ensure the relevant historical data is accurately reported for each product, menu, or investment option.

APRA will verify data post-submission and any inconsistencies will require a resubmission of the relevant form.

Where there has been a change in the MySuper product structure over the historical period, for example from single strategy to lifecycle strategy, APRA expects the RSE licensee to report historical data for the product for each period in line with the structure at that time.

In some cases, this may mean that RSE licensees are required to report additional investment options on SRF 605.0 with an end date prior to 30 June 2021.

Where a change occurred mid-quarter, APRA expects RSE licensees to report each investment option for the portion of the quarter the investment option was in use only.

APRA does not otherwise expect RSE licensees to report historical data for a product, menu or investment option that has been wound up prior to the historical data submission deadline.

APRA has allocated returns for each historical period and expects RSE licensees to submit data for each period in the relevant return.

APRA expects that if an investment option was reported as a trustee-directed product as at 30 June 2021 that historical data is reported by 28 February 2022, regardless of when the investment option was classified as a trustee-directed product

APRA expects that where an RSE licensee opts to report historical data in two stages that the RSE licensee will:

• first submit data for MySuper products and trustee-directed products by 28 February 2022; and  then complete a resubmission of each return for each period for the full reporting population (for all other products, menus and investment options in addition to the MySuper products and trustee-directed products) by 28 July 2022.
   
• The resubmissions need to include the MySuper and trustee-directed product data as well as the new data relating to all other products, menus and investment options.
   
• RSE licensees that have the full population of historical data available for SRF 550.0 and SRS 705.1 can report the full historical data in February 2022, and are encouraged to do so.

APRA does not expect RSE licensees to submit forms with incorrect or dummy data.

APRA expects that the entire reporting form will be submitted, however RSE licensees are only required to report the required historical reporting items.

RSE licensees are expected to manually validate “blank” tables, where a submission is not required. Please refer to the APRA Connect Guide, section 6.5 Forms with no data for more information on how to submit returns where only a subset of forms is required.

APRA expects reporting for all insurance policies that have had claim, payment or premium activity during the reporting period. APRA also expects reporting for any insurance policies that may have ceased during the reporting period and for any insurance policies that may have been impacted by merger activity during the reporting period.

For each year of historical reporting under SRF 251.2, APRA expects that claim, payment and premium activity would be reported for the year in which the activity occurred.

For example, a premium paid in 2019 for cover in the 2018 year would be reported in the 2019 historical submission.

APRA intends to update ‘SRS 251.0 Insurance Arrangements’ to allow RSE licensees up until 28 February 2022 for the submission of 5 years of historical data for SRF 251.2 Insurance Payments (years ending 30 June 2016 – 2020).   

It will not be necessary to complete SRF 251.0 for each historical reporting period. APRA intends to clarify the instruction in SRS 251.0 for Table 1 of SRF 251.0. For the 30 June 2021 submission period only, RSE licensees must report all insurance policies currently or previously held by the RSE licensee for which one or more of the following activities occurred during the five years prior to the start of the reporting period:

a) premiums were paid to the insurer; or
b) claims were received, processed or paid.

In addition to the requirement to report all insurance policies currently or previously held by the RSE licensee which:

1. were in force at any time during the reporting period or in the 5 years prior to the start of the reporting period; or 

2. for which one or more of the following activities occurred during the reporting period:

a) premiums were paid to the insurer; or
b) claims were received, processed or paid.

The RSE licensee should report the period the payment relates to in ‘Insurance Cover Year Date’ column (SRF 251.2, Table 1, Column 3).  APRA expects any payment which relates to multiple years of cover to be split into amounts for each year of cover that it applies.

RSE licensees are only required to report data for insurance policies which provide default cover to members as indicated on SRF 251.3 Table 2. RSE licensees should report policies which are closed to new members as well as policies which are open to new members.

APRA expects that where different premium rates apply to different occupation categories, these should be reported as separate rows with a different Insurance Table Identifier for table 1. The same approach should also be adopted for table 2. 

If premium rates are the same for multiple occupation categories, then these should be reported as a single row in table 1 of SRF 251.3 as per FAQ 251.0c.

SRS 332.0 provides that reporting periods for this reporting standard are for each year of income of the entity.

For example, an RSE that has a 31 December year end would report SRS 332.0 for the year ending 31 December, with its submission due on 31 March.

As per the reporting basis section, reporting under SRS 332.0 Expenses should reflect expenses accrued. APRA intends to update references to ‘payments’ and ‘expenses paid’ in the reporting instructions to ‘expenses’.

APRA expects RSE licensees to report a row in Table 1 with the name ‘Accounting concepts’ for the purpose of reporting accounting concepts such as depreciation. The total amount of depreciation should be reported in Table 2 with the expense group type ‘Corporate overheads’ and expense type ‘Amortisation And Depreciation’. 

APRA expects other accruals adjustments relating to the provision of goods or services to be reported with the ‘Accruals adjustment’ service provider identifier against the relevant expense group type and expense type.

Where a supplier does not have an ABN, this field can be left blank. APRA intends to make the ABN a non-mandatory field. This will be reflected in the next release of APRA Connect and the associated taxonomy artefacts.

Expenses relating to the preparation of APRA returns should be included in the expense group ‘Corporate Overheads’ and expense type ‘Other’. The ‘Service Arrangement Inclusions Exclusions Text’ should be used where there is not a relevant category.

Expenses relating to the wages for corporate overheads such as human resources should be included in the expense group ‘Corporate Overheads’ and expense type ‘Other’ with the RSE licensee as the service provider. A description may be provided in ‘Service Arrangement Inclusions Exclusions Text’ if additional context is required. 

Wages for internal teams which provide a service which has an expense type listed should be reported under that category. For example, internal call centre staff wages should be reported as expense group type ‘administration’, expense type ‘call centre’, with the RSE licensee as the service provider.

APRA intends to update SRS 332.0 to permit RSE licensees to report on SRF 332.0 on a best endeavours basis for periods ending before 30 June 2022, except for expenses used for the purpose of the following expense types: 

• Marketing related expenses (including: Advertising or Marketing, Existing Member Campaigns, Member Acquisition Campaigns, and all expense types under Marketing And Distribution (expense group)); 
• Sponsorship;
• Payments Or Donations To Industry Bodies;
• Payments Or Donations To Political Parties;
• Payments Or Donations To Trade Bodies.

APRA expects RSE licensees to report the total expenses of the RSE, and to report a Service Arrangement Cost Amount for each expense type for which a service is provided to the RSE.

APRA expects RSE licensees to have plans and processes in place to improve reporting prior to the submission of the 30 June 2022 reporting.

SRS 332.0 is designed to capture information related to the flow of member money as well as the purpose for the deduction. Data on Director remuneration is reported to APRA under SRS 600.0 ‘Profile and Structure’ (RSE Licensee).    

Where Director fees are paid to an entity rather than to the Director themselves, the entity  should be reported in table 1 ‘Service providers'. Reporting should include the total amount paid to the entity in table 2 against the Service provider Identifier for that entity.

If the receiving entity is captured under one of the other expense type categories such as ‘Payments to trade bodies’, entities should report the amount under that category, with the description in the inclusions/exclusions text being ‘payments in lieu of director fees’. Otherwise, entities should report under the group expense type ‘Trustee office’ and the expense type ‘Directors fees’.

APRA intends to update the definition for ‘Payments or Donations to Industry Bodies’ to mean the expense incurred for the provision of payment or donations to industry associations.

APRA intends to update the definition for ‘Payments or Donations to Trade Bodies’ to mean the expense incurred for the provision of payments or donations as defined in 2.10 (1)(g) of the Superannuation Industry (Supervision) Regulations 1994.

APRA intends to define related party for SRS 332.0 to mean, in relation to an entity (the principal entity) or the RSE licensee of the principal entity, the entities described in regulation 2.10(1)(h)(i) – (vi) of the Superannuation Industry (Supervision) Regulations 1994. 

APRA intends to update SRS 332.0 to clarify that entities are expected to report the extent to which the receiving entity’s profit is attributable to that expense amount, only where the receiving entity is the RSE licensee or a connected entity, which is also a related party. Connected entity means a person connected with an RSE licensee under subsection 13(4F) of the Financial Sector (Collection of Data) Act 2001. Related party means, in relation to an entity (the principal entity) or the RSE licensee of the principal entity, the entities described in regulation 2.10(1)(h)(i) – (vi) of the Superannuation Industry (Supervision) Regulations 1994.

APRA intends to clarify the definition of ‘profit payments’ in SRS 101.0 to:  expenses incurred for any profit.

APRA intends to update SRS 332.0 to clarify how amounts are to be reported on an APRA look-through basis for connected entities:

Where the expense is in relation to money, consideration or any other benefit given to an entity (the receiving entity) by the RSE licensee or a connected entity (the paying entity), APRA expects RSE licensees to obtain information about the following for reporting in table 1 of SRF 332.0:

• details of the receiving entity; and
• the relationship between the receiving entity and the RSE licensee.

APRA expects RSE licensees to obtain information about the following, in order to classify relevant amounts under the relevant expense group type and expense type categories for reporting in tables 2 and 3 of SRF 332.0:

• the purpose for which the money, consideration or other benefit is given; and
• the way in which the money, consideration or other benefit is used by the receiving entity, and any entity with which that entity deals. This includes, for a related party, the extent to which the receiving entity’s profit is attributable to that money, consideration or other benefit in order to classify relevant amounts under the expense type ‘profit’.

APRA has defined a ‘related connected entity’ as an entity that is both a related party and a connected entity, where:

Connected entity means a person connected with an RSE licensee under subsection 13(4F) of the Financial Sector (Collection of Data) Act 2001. 
Related party means, in relation to an entity (the principal entity) or the RSE licensee of the principal entity, the entities described in regulation 2.10(1)(h)(i) – (vi) of the Superannuation Industry (Supervision) Regulations 1994.
Report all service provider expenses paid over the reporting period in table 1 of SRF 332.0  on a look-through basis. If there is no ‘related connected entity’, report the receiving entity. If expenses are with a ‘related connected entity’, report the last ‘related connected entity’ in the look-through chain.

Report all expenses for the reporting periods in tables 2 and 3 of SRF 332.0 on a look-through basis. If there is no ‘related connected entity’, report the total expenses with the receiving entity. If expenses are with a ‘related connected entity’, report the total cost amount from the last related connected entity in the look-through chain to the first entity that is not a  related connected entity. For each entity in the look-through chain, report any expense not on- paid to a further ‘related connected entity’. Classify the amount for each relevant expense group type and expense type for which the entity provides a service to the RSE, including the extent to which, for each ‘related connected entity’ in the look-though chain, that entity’s profit is attributable to that expense amount.

APRA intend to update SRS 332.0 to clarify the instructions in ‘Responsible Person Service Provider Relationship Indicator’ (SRS 332.0, table 1, column 7) and ‘Responsible Person Service Provider Relationship Text’ (SRS 332.0, table 1, column 8)  with the following: 

If responsible persons have a relationship with the service provider which may result in a relevant duty or a relevant interest in accordance with Superannuation Prudential Standard SPS 521 Conflicts of Interest, report details of the relationship with the service provider.

Under the staged implementation approach, APRA will permit RSE licensees to report certain information on a best endeavours basis for a defined period of time. The scope of data that may be submitted on a best endeavours basis has been removed from the reporting standard and provided as guidance. Despite this change, there will be no difference in how APRA will administer compliance with reporting of information that can be submitted on a best endeavours basis.

APRA will permit RSE licensees to complete SRF 332.0 on a best endeavours basis for each reporting period ending on or after 30 June 2021 but before 30 June 2023, except for expenses used for the purpose of the following expense types:

• Marketing related expenses (including: Advertising or Marketing, Existing Member Campaigns, Member Acquisition Campaigns, and all expense types under Marketing And Distribution (expense group));
• Sponsorship;
• Payments Or Donations To Industry Bodies;
• Payments Or Donations To Political Parties; or
• Payments Or Donations To Trade Bodies.

RSE licensees must report the total expenses for the RSE and report a service arrangement cost amount for each expense type for which a service is provided to the RSE.

APRA expects RSE licensees to have measures and processes in place to accurately report prior to the submission of data for reporting periods ending on or after 30 June 2023.

Note: In May 2022, APRA extended reporting on a best endeavours basis to periods ending on or before 30 June 2023.

APRA expects that investment expenses are those expenses classified as investment related expenses in the fund’s financial statements, and which are passed on to members through investment fees.

Therefore, to the extent that the salaries of the internal investment team are an investment expense, APRA would expect these salaries to be reported as an investment management ‘Investment’ expense under SRF 332.0 table 3 investment management expenses with the RSE licensee as the service provider. 

If these expenses are administration or operating expenses, APRA would expect these salaries to be reported as ‘Investment Consulting’, ‘Research’ or other appropriate classifications with the RSE licensee as the service provider. 

Under the staged approach, for asset characteristics to be reported on a best endeavours’ basis, where the classification cannot be determined, RSE licensees should report ‘Not Applicable’.

APRA notes and accepts this feedback and will correct the definition for  ‘Investment Grade’ and ‘Non-Investment Grade’ for Asset Characteristic 1 for Fixed Income in Reporting Standard SRS 550.0 Asset allocation as follows:

Investment Grade: Means a debt security with counterparty rating of Grade 1 to Grade 4.

Non-Investment Grade: Means a debt security with counterparty rating of Grade 5 and below.

APRA intends to update SRS 550.0 to expand the subset of characteristics in SRF 550.0 table 2 for which RSE licensees will be permitted to report on a best endeavours basis for periods ending on or after 30 June 2021 but before 30 June 2022. The intended update to SRS 550.0 will mean that following subset of characteristics are to be reported as follows:

• Where the asset class sector type is Fixed Income, an RSE licensee must report asset class characteristic 2.
• Where the asset class sector type is Fixed Income, an RSE licensee will be permitted to report asset class characteristic 1, asset class characteristic 3 and Investment Modified Duration Number on a best endeavours basis.
• Where the asset class sector type is Alternatives, an RSE licensee must report asset class characteristic 2.
• Where the asset class sector type is Cash, Property, Equity or Infrastructure, an RSE licensee will be permitted to report asset class characteristic 1, asset class characteristic 2 and asset class characteristic 3 on a best endeavours basis.

APRA expects RSE licensees to have plans and processes in place to improve reporting classifications prior to the submission of the 30 June 2022 reporting.

APRA expects RSE licensees to apply an asset weighted duration using the effective exposure.

APRA intends to clarify the instructions in the SRS 550.0 to instruct RSE licensees to report: 

• commodities using the Investment Asset Class Sector Type ‘Alternatives’ with Investment Asset Class Characteristic 2 as ‘Alternatives Commodities’; 
• alternative strategy funds using the Investment Asset Class Sector Type ‘Alternatives’ with the Investment Asset Class Characteristic 2 which best represents the primary investment strategy of the fund; and
• other alternative assets using the Investment Asset Class Sector Type ‘Alternatives’ with Investment Asset Class Characteristic 2 as ‘Alternatives Other’.

Where ‘Alternative strategy funds’ are defined as:

Means a collective investment that displays a combination of the following characteristics: 

(a) borrowing and leverage restrictions, which are typically included in collective investment-schemes related regulation, are not applied, may use high levels of leverage;
(b) significant performance fees (often in the form of a percentage of profits) are paid to the manager in addition to an annual management fee;
(c) investors are typically permitted to redeem their interests periodically (e.g. quarterly, semi-annually or annually); 
(d) significant ‘own’ funds are often invested by the managers; 
(e) derivatives are used, often for speculative purposes, and there is an ability to short sell securities; and 
(f)  more diverse risks or complex underlying products are involved.

APRA expects such arrangements to be classified as ‘Government’. APRA will consider implementing a category to capture these arrangements in the future.

Under the staged implementation approach, APRA will permit RSE licensees to report certain information on a best endeavours basis for a defined period of time. To improve clarity of drafting, the scope of data that may be submitted on a best endeavours basis has been removed from the reporting standard and provided as guidance. Despite this change, there will be no difference in how APRA will administer compliance with reporting of information which can be submitted on a best endeavours basis during the defined period. 

APRA will permit RSE licensees to complete SRF 550.0 table 2 and SRF 550.1 table 1 on a best endeavours basis for certain asset class characteristics for periods ending on or after 30 June 2021 but before 30 June 2023. 

APRA expects RSE licensees to have plans and processes in place to improve reporting classifications.

SRF 550.0 Asset Allocation

The matters which are permitted to be reported on a best endeavours basis for different reporting periods on SRF 550.0 are as follows:

An RSE licensee must report the information required under each table of SRF 550.0. 

For each reporting period ending on or before 31 March 2023, a reduced list of asset class characteristic 1, asset class characteristic 2 and asset class characteristic 3 applies for Table 2 in SRF 550.0: 

• Where the asset class sector type is Cash, Property, Equity or Infrastructure, APRA will permit the reporting of asset class characteristic 1, asset class characteristic 2 and asset class characteristic 3 on a best endeavours basis;  
• Where the asset class sector type is Fixed Income or Alternatives, an RSE licensee must report asset class characteristic 2. APRA will permit the reporting of asset class characteristic 1, asset class characteristic 3 and Modified Duration on a best endeavours basis. 

Note: In May 2022, APRA extended reporting on a best endeavours basis to periods ending on or before 31 March 2023.    

Refer to Appendix A in SRS 550.0: Asset class hierarchy for the asset class characteristics which apply to each asset class sector type.

For each reporting period ending on or after 30 June 2023, an RSE licensee must report the information required under SRF 550.0. For each of these reporting periods, all asset class characteristics apply.

SRF 550.1 Investments and Currency Exposure

The characteristics which are permitted to be reported on a best endeavours basis for different reporting periods on SRF 550.1 are as follows:

For each reporting period ending on or before 31 March 2023, an RSE licensee must report the information required under each table of SRF 550.1. For this period, a reduced list of asset class characteristic 1, asset class characteristic 2 and asset class characteristic 3 applies for Table 1: 

• Where the asset class sector type is Cash, Property, Equity or Infrastructure, APRA will permit the reporting of asset class characteristic 1, asset class characteristic 2 and asset class characteristic 3 on a best endeavours basis. 
• Where the asset class sector type is Fixed Income or Alternatives, an RSE licensee must report asset class characteristic 2. APRA will permit the reporting of asset class characteristic 1, asset class characteristic 3 and Modified Duration on a best endeavours basis. 

Note: In May 2022, APRA extended reporting on a best endeavours basis to periods ending on or before 31 March 2023.    

Refer to Appendix A: Asset class hierarchy in SRS 550.0 for the asset class characteristics which apply to each asset class sector type.

For each reporting period ending on or after 30 June 2023, an RSE licensee must report the information required under SRF 550.1. For each of these reporting periods, all asset class characteristics apply.
 

APRA expects RSE licensees to report the currency hedging ratio percent for strategic sector allocations where the domicile is ‘Not Specified’ in Table 1 of SRF 550.0 as the target currency hedging proportion for any internationally domiciled assets within that allocation. For example, for an allocation to the strategic sector of Equity, with the listing type of Listed and domicile of ‘Not Specified’, a currency hedging ratio of 50 percent would be interpreted as a target currency hedging ratio of 50 percent of those international domicile assets within the listed equity allocation.

APRA expects RSE licensees to report information relating to investment options underlying a MySuper product or trustee-directed product, for the reporting periods ending on or after 30 September 2021 but before 30 June 2022, within 28 days after the end of the relevant reporting period in accordance with paragraph 12 of SRS 550.0.

APRA intends to revise footnote 6 when the reporting standard is next determined to read:

^{6 For the quarter ending 30 June 2021: due by the date in paragraphs 10, 11 or 18, as applicable. For the quarters ending 30 September 2021, 31 December 2021 and 31 March 2022: due by the date in paragraphs 12 or 18, as applicable.} 

In such cases, APRA expects RSE licensees to take the same approach as it would for reporting physical holdings of foreign currency, and to report foreign exchange derivatives held for the purpose of gaining exposure to the underlying asset in Table 2 of SRF 550.0 with Asset Class Sector Type as Cash and Investment Domicile Type as International Domicile.

The sum of the physical exposure and the synthetic exposure (reported in Table 2, column 14) should equal the value of investments (reported in Table 2, column 13).

APRA expects RSE licensees to report either a benchmark allocation to currency exposure or currency hedging ratios in SRF 550.0 table 1, with the approach determined by reference to the RSE licensee’s investment strategy.

Where an RSE licensee sets currency exposure targets at the investment option level, report the benchmark allocation to currency exposure in column 10 using Currency Exposure as the ‘Strategic Sector’ in column 2. 

Where an RSE licensee sets currency exposure targets or hedging ratios at the asset class level, it should report a currency hedging ratio (%) in column 13 for each relevant internationally domiciled asset class. 

The table below summarises the reporting approach for different scenarios: 

Where investment option level currency exposure is not reported in SRF 550.0 table 1 column 10, and the RSE licensee targets a fully hedged international exposure, the RSE licensee must report 100 per cent in SRF 550.0 table 1 column 13.

APRA expects that modified duration information should be attainable for each combination of fixed income characteristics reported where the investments are directly held (meaning investments made by the RSE in its own name, including investments held by a custodian as per the definition in SRS 101.0).

APRA expects RSE licensees to know the risks in its fixed income portfolios, including interest rate risk (proxied by modified duration). APRA expects that RSE licensees monitor modified duration at least at the portfolio level. 

APRA intends to revise the instructions for reporting modified duration to read as per the table below effective from the 30 June 2022 reporting period. 

This FAQ should be considered in conjunction with FAQ 550.0j, which extends the best endeavours reporting of modified duration to periods ending on or before 31 March 2023. 

While RSE licensees must report modified duration for the ‘Fixed Income’ asset class sector exposures within the ‘Fixed Income’, ‘Fixed Income Excluding Credit’ and ‘Credit’ strategic sector allocations, they should also report modified duration for other investment exposures where relevant.

If a derivative is held for the purpose of either gaining or reducing exposure to an underlying asset class: 

• report the synthetic exposure in column 14 against the underlying asset class sector type; 
• report the effective exposure in column 13 which comprises the physical securities, synthetic exposures and the market value of the derivatives; and
• report the corresponding cash offset value (i.e., inverse of the notional principal value of the derivative) in columns 13 and 14 of the relevant strategic sector type under the ‘Cash’ asset class sector type.

If a derivative is held for the purposes of hedging currency risk:

• report the market value of the foreign currency (FX) derivative against the asset class sector type the FX derivative is related to in column 13; 
• where the market value of the FX derivative is not allocated to a particular asset class sector type report against the ‘Cash’ asset class sector type in column 13; 
• report the actual currency hedging level against the investment exposure hedged as a percentage in column 15; and
• The notional principal value of the FX derivative does not need to be reported in SRF 550.0 table 2. 

If a derivative is held for the purposes of adjusting interest rate risk:

• For each investment exposure whose modified duration is altered using derivatives, report in column 17 the modified duration for that investment exposure after the derivative adjustment; and
• Report the market value of the derivative apportioned on an asset weighted basis against each reported combination of investment exposures whose modified duration is altered by the derivative. The notional principal value of the derivative does not need to be reported in SRF 550 table 2.

If a derivative is held for the purpose of either gaining or reducing exposure to an underlying asset class: 

• report the synthetic exposure in column 13 against the underlying asset class;
• report the effective exposure in column 12 which comprises the physical securities, synthetic exposures, and the market value of the derivatives; and
• report the corresponding cash offset value (i.e., inverse of the notional principal value of the derivative) in columns 12 and 13 of the relevant strategic asset sector type under the ‘Cash’ asset class sector. 

If a derivative is held for the purposes of hedging currency risk: 

• report the market value of the foreign currency (FX) derivative against the asset class sector type the FX derivative is related to in column 12;
• where the market value of the FX derivative is not allocated to a particular asset class sector type report against the ‘Cash’ asset class in column 12;
• report the actual currency hedging level against the investment exposure hedged as a percentage in column 14; and
• The notional principal value of the FX derivative does not need to be reported in SRF 550.1 table 1.

If a derivative is held for the purposes of adjusting interest rate risk:

• report the market value of the derivative apportioned on an asset weighted basis against each reported combination of investment exposures whose modified duration is altered by the derivative. The notional principal value of the derivative does not need to be reported in SRF 550.1 table 1.

If an RSE licensee has reported a benchmark allocation to ‘Currency Exposure’ strategic sector in SRF 550.0 table 1 column 10 (e.g., where an RSE licensee sets currency exposure targets at the investment option level), it should also report an allocation to ‘Currency Exposure’ strategic sector in table 2, with the value of the currency exposure reported in column 13 ‘Investment Option Value Amount’. 

The currency exposure amount reported in column 13 ‘Investment Option Value Amount’ should be the total currency exposure before hedging, with any hedging to be reflected in the hedged percentage in column 15 ‘Investment Currency Hedged Percent’.

For all international domicile allocations, RSE licensees should report the currency hedged ratio in column 15 ‘Investment Currency Hedged Percent’. This applies whether an RSE licensee reports either a benchmark allocation to currency exposure strategic sector or currency hedging ratios in in SRF 550.0 table 1. Any blanks will be interpreted as being fully unhedged.

APRA intends to revise the instructions when SRS 550.0 is re-determined, to read: 

Current instruction: Report table 1 on an APRA-look through basis, reporting the strategic asset allocation regardless of how investments are made.

Proposed revised instruction: Report the RSE Licensee’s strategic asset allocation regardless of how investments are implemented.

No, under the instructions in SRS 550, RSE licensees an RSE licensee must report the information required under Table 2 of SRF 550.0 in respect of investment options underlying a MySuper product or trustee-directed product. For any other investment options, RSE licensee must report the information required under each Table of SRF 550.0 for each reporting period ending on or after 30 June 2022. Please refer to the ‘Information required’ section of SRS 550.0. 

Reporting under SRS 605.0 is to reflect the structure as at 30 June each year. If there are structural changes that take effect on or before 30 June, APRA expects that reporting will reflect the new structure.

Direct investment options that can be reported on an aggregated basis are direct shares, fixed income instruments or term deposits which have a common fee structure, investment option category and description in related disclosure material.

For example where there is an option for members to directly invest in individual shares on the ASX 300, this may be reported as one investment option with ‘Investment option name’ as ‘ASX 300 – individual shares’ for example, together with the number of shares either currently available to members or invested in by members previously under this option as ‘number of investment options’. Direct fixed income instruments and term deposits may also be reported collectively by duration and provider, for example ‘Bank X, 90 day’.

Yes, for comparability purposes, APRA requests the use of existing identifiers where possible. 

Identifiers for select investment options, MySuper lifecycle stages and defined benefit sub-funds are currently reported under SRS 001.0. APRA requests that RSE licensees use the same identifier when reporting corresponding products, investment menus or investment options under SRS 605.0 where possible.

In the case of a single strategy MySuper products, APRA expects that the ‘MySuper Identifier’ reported in SRF 001.0 (Part D item 6(2)), would be reported as the; 

• ‘Superannuation Product Identifier’ (SRF 605.0 (Table 1, column 2); and
   
• ‘Investment Menu Identifier’ (SRF 605.0 (Table 2, column 2).

In the case of MySuper products with a LifeCycle strategy, APRA expects that the ‘MySuper Identifier’ reported in SRF 001.0 (Part D item 6(2)), would be reported as the:  

• ‘Superannuation Product Identifier’ (SRF 605.0 (Table 1, column 2) and;
   
• ‘Investment Menu Identifier’ (SRF 605.0 (Table 2, column 2).

APRA expects that the ‘LifeCycle Stage Identifier’ reported in SRF 001.0 (Part D item 6(2)) for each lifecycle stage would be used for each corresponding ‘Investment Option Identifier’ (SRF 605.0 (Table 3, column 2).

In the case of select investment options, APRA expects each ‘Select Investment Option Identifier’ reported in SRF 001.0 (Part E item 7(2)) would be used where possible for each corresponding ‘Investment Option Identifier’ (SRF 605.0 (Table 3, column 2)).

Where a Product Disclosure Statement is not available to members, this field may be left blank.

APRA expects RSE licensees to report all investment options on table 3 of SRF 605.0 as at 30 June 2021. RSE licensees should report ‘Yes’ or ‘No’ in column 5 to indicate whether the investment option is a trustee-directed product. Submission of the 30 June 2021 period data for SRF 605.0 is due by 30 September 2021. If an RSE licensee reclassifies an investment option after the submission date, the RSE licensee should resubmit SRF 605.0 for the 30 June 2021 period with the corrected data in column 5. 

APRA notes that there is a difference between the reporting standard which specifies that numbers should be reported as percentages to 2 decimal places and APRA Connect which allows percentage up to 4 decimal places (6 decimal places in total). 

RSE licensees should report data for these columns to 4 decimal places (for percentages this will mean 6 numbers after the decimal point). APRA intends to update this requirement the next time the reporting standard is determined.

For the periods prior to the introduction of the Stronger Super reforms on 30 June 2014, if data is not available to recalculate the net investment return as per the definition in SRS 705.1, RSE licensees should report the available net investment return which most closely represents the net investment return definition on SRS 705.1.

For the calculation of volatility which includes periods ending on or before 30 June 2014, RSE licensees may take the same approach as for the net investment returns noting their input into calculating the ‘Volatility of comparison return (5 years)’ and ‘Volatility of comparison return (10 years)’ in SRS 705.1.

APRA intends to update the definitions for ‘Volatility of comparison return (5 years)’ and ‘Volatility of comparison return (10 years)’ in SRS 705.1 to allow RSE licensees to calculate the annualised standard deviation of daily returns for historical data. 

As described in FAQ 705.1b, for the calculation of volatility which includes periods ending on or before 30 June 2014, if data is not available to recalculate the net investment return as per the definition on SRS 705.1, RSE licensees may use the return which most closely represents the net investment return definition on SRS 705.1 as an input to the volatility calculation.

Therefore where an RSE licensee has an existing measure of 5 year and 10 year volatility, for example calculated as the standard deviation of daily investment return net of investment costs but inclusive of tax, RSE licensees may report this as the volatility measure for historical reporting (reporting periods ending before 30 June 2021). For ongoing reporting (periods ending on or after 30 June 2021), the volatility must be calculated as prescribed under SRS 101.0 Definitions for Superannuation data collections.

APRA  acknowledges this issue. The CPI release date will generally be prior to the due date. To allow industry sufficient time to prepare returns, APRA will update SRS 705.1 to allow up to 35 calendar days for the first year of reporting. 

APRA is considering potential structural solutions which may be implemented in a later phase of the SDT project to address this issue.

The 30 June 2022 submission of SRF 705.1 is due by 28 July 2022. Where an RSE licensee is unable to source investment objective performance by the due date, please submit using the best available information, and subsequently resubmit within 14 days if required. 

APRA intends to consult on an update to SRS 705.1 to enable a longer timeframe for submission of investment objective performance (to later in 2022).

APRA expects that all fees and costs reported under SRS 706.0 be reported ‘gross of tax obligations’ where ‘gross of tax obligations’ refers to gross of income tax, GST and stamp duty.  APRA intends to update SRS 706.0 to remove this reference: ‘consistent with the manner in which they are required to be disclosed in Product Disclosure Statements, where applicable’ when describing the requirement to report fees and costs gross of tax.