Discussion paper - Superannuation Data Transformation Phase 2

Executive summary

This discussion paper sets out Australian Prudential Regulation Authority’s (APRA’s) proposals to enhance its superannuation data collection relating to Registrable Superannuation Entity (RSE) licensee profile; RSE profile; Investments (including indirect investment costs); and RSE licensee financial statements.

APRA is undertaking the Superannuation Data Transformation (SDT) project to collect accurate and comparable superannuation data from the superannuation industry to enable appropriate regulatory oversight and to increase transparency across the entire industry. In doing so, the SDT project will drive better industry practice and improve member outcomes by making it easier to scrutinise fund operations and product performance.

APRA is proposing amended reporting requirements to meet the needs of APRA and peer agencies including Australian Securities and Investments Commission (ASIC) and Australian Bureau of Statistics (ABS). APRA proposes to amend five existing reporting standards, introduce six new reporting standards and replace eight pre-SDT reporting standards. APRA is also proposing to discontinue (without replacing) one redundant reporting standard.

APRA’s consultation proposals build on the pre-SDT reporting framework, as well as the new reporting framework and data model introduced under Phase 1 of the SDT project. Importantly, the proposals capture data that should already be readily available to RSE licensees. APRA is undertaking consultation to refine the proposals and has outlined specific questions for consultation in areas where APRA is particularly interested in hearing the views of relevant stakeholders.

RSE licensee profile: APRA proposes to enhance current reporting on the business model and structure of the RSE licensee board and board committees to gain a comprehensive understanding of the governance practices and effectiveness of superannuation trustees.

RSE profile: APRA proposes to complete the data model for an RSE’s business operations, including connections back to superannuation products and fee arrangements. APRA also proposes to introduce reporting on specific product distribution arrangements between RSEs and intermediaries such as employer sponsors and promoters. This new reporting will enable the establishment of concepts to support future reporting (for example on defined benefit sub-funds). 

Investments: In line with APRA’s strengthened Prudential Standard SPS 530 Investment Governance (SPS530) and Prudential Practice Guide SPG 530 Investment Governance (SPG 530), APRA proposes to address a key gap in APRA’s current collections to inform assessments of the governance of and exposures to liquidity and valuation risk. APRA is also proposing to rationalise the two ABS reporting standards on investments to meet the needs of both APRA and ABS.

Indirect investment costs: APRA proposes to collect the total annual indirect investment costs associated with each investment manager which is required for compliance with the disclosure obligations of Regulatory Guide 97 Disclosing fees and costs in PDSs and periodic statements RG 97 (RG97). The collection of this data will be aligned with the investment option reporting established in Phase 1. This proposal will address a key gap in APRA’s data on investment expenses and give effect to recommendations from the Productivity Commission report Superannuation: Assessing Efficiency and Competitiveness.

RSE licensee financial statements: APRA proposes to collect the RSE licensee financial statements data to address a key gap in the current reporting framework. This data would help APRA to understand the flow of monies within superannuation trustees and the superannuation system, to improve transparency of dividend payments and expenditures from trustee capital and support the assessment of financial resilience. 

APRA has included draft reporting standards, as an attachment to this discussion paper (Attachment A).

APRA has also provided a summary of all reporting tables, together with a mapping of any equivalent data concepts currently reported to APRA (Attachment B).

Subject to consultation feedback, APRA proposes that the first reporting reference period is 30 June 2025 for annual reporting and 30 September 2025 for quarterly reporting with due dates in November 2025 and December 2025 respectively.

APRA will consult on proposals for the confidentiality and publication of data after the proposed reporting standards have been determined.

Formal written submissions for this consultation close on 31 March 2024. APRA intends to issue a response to consultation in the September 2024 quarter.

Chapter 1 - Background

Under Phase 1 ‘Breadth’ of the SDT project, APRA addressed the most urgent data gaps required to support APRA, the industry and other stakeholders in assessing member outcomes. Addressing these gaps has enabled APRA to gain greater insights into the choice sector, including how the sector is performing, insurance outcomes, and how RSE licensees are using members monies.

The SDT project aims to drive better industry practices and improve member outcomes by significantly enhancing the comparability and consistency of reported data. 

In Phase 2 ‘Depth’, APRA is proposing amendments to reporting requirements to meet the information needs of APRA and peer agencies. 

In this context, APRA has reviewed the pre-SDT superannuation reporting standards currently reported via Direct to APRA (D2A) and is proposing enhancements and redesign where relevant. APRA is also proposing to discontinue redundant data collections with a view to ceasing reporting to D2A for the superannuation industry. 

In implementing its data collection program, APRA is committed to reducing ad hoc data requests to identify or address vulnerabilities as they arise. This will enable RSE licensees to provide data through predictable collections, minimising the need for more costly one-off data requests and points of reconciliation. This will help to address reporting burden on RSE licensees and enables APRA to effectively supervise and respond to emerging risks or events.

APRA’s data roadmap

APRA is committed to its data collection program that aims to both streamline requirements for industry and enrich data and insights for APRA, Government, peer regulators, its regulated population, and other stakeholders.

On 31 July 2023, APRA published a letter outlining plans to commence the first annual review of its data directions roadmap and its intent to continue to work with the superannuation industry on data collections as part of Phase 2 of the SDT project. This consultation is consistent with APRA’s stated priority to commence formal consultation in November 2023 on proposed reporting standards for RSE licensee profile and RSE profile, investments including indirect investment costs, and RSE licensee financial statements.

Chapter 2 - Summary of consultation proposals

APRA’s consultation proposals include data on RSE licensee and RSE profile, investments, indirect investment costs and RSE licensee financial statements. These proposals build on the pre-SDT reporting framework and the new reporting framework and data model. APRA’s proposals link to the Phase 1 collections to complete the model of the RSE’s business operations and reuse established classification frameworks.

These linkages will facilitate a more comprehensive understanding of the business operations of RSE licensees and RSEs, and the broader superannuation industry. 

In developing the proposals, APRA has worked closely with peer agencies with the goal of ‘collect once and share’ where feasible. APRA is seeking feedback from industry to adjust materiality, granularity, look-through and frequency to address appropriate proportionality of the proposed collection. 

In addition, APRA will hold industry workshops to further refine the collection design prior to finalisation.

APRA intends to approach a sample of entities to undertake a pilot by reporting data in a number of the proposed tables. The pilot will be aligned to planned thematic work on liquidity and valuations. Feedback from the pilot submission process will inform the design of the final reporting standards. If any RSE licensees would like to participate in the pilot, please contact APRA to express your interest.

APRA takes a risk-based, forward-looking approach to supervision and proposes the collection of the data points to meet its intended objectives and use cases. To reduce regulatory burden on industry, APRA intends to utilise data that RSE licensees already hold. APRA is seeking feedback on alternative data points or approaches that could still meet APRA’s objectives that may further reduce regulatory burden. 

APRA encourages stakeholders to provide information that will assist APRA in better understanding any impediments to providing the proposed data and requests comments made in submissions are as specific as possible, identifying specific data item(s) or instruction(s) where possible.

Subject to consultation feedback, APRA proposes that the first reporting reference period would be in late-2025, allowing at least 12 months from the planned response to consultation and finalisation of the reporting standards in late 2024 with the first reporting periods being 30 June 2025 for annual reporting and 30 September 2025 for quarterly reporting with due dates in November 2025 and December 2025 respectively.

The proposed reporting requirements are summarised for each topic in Table 1 below. Details on the proposals for each topic are outlined in Chapter 3.

Table 1: Summary of proposed reporting standards

Chapter 3- Detailed proposals

RSE Licensee Profile

APRA proposes to enhance data currently reported on the RSE licensee ownership structure, directors and board committees.

APRA’s proposals include information about directors such as tenure, position on board committees, details of RSE licensee’s other directorships or employment with Australian Stock Exchange (ASX) listed, APRA regulated or connected entities and total director remuneration. These enhancements will enable APRA to gain insights into the RSE licensee’s implementation of SPS 510 Governance and SPS 521 Conflicts of Interest and assess indicators of Board effectiveness and prudent governance arrangements.

APRA seeks feedback on the availability of the proposed data such as information on other directorships and employment with ASX listed, APRA regulated or connected entities, as well as on APRA’s proposal to notify APRA of any changes to the reported other directorships and employment information within 28 days.

APRA notes that in addition to the data collected under SRS 600.0, limited information about RSE licensee board directors is also collected under SRS 520.0 Responsible Persons Information (SRS 520.0). Reporting under SRS 520 will continue as this collection supports timely notification to APRA of changes to Responsible Persons of an RSE Licensee in line with the requirements under Prudential Standard SPS 520 Fit and Proper. Reporting under SRS 520.0 may be revised in future following potential amendments to CPS 520 as part of APRA’s review of its governance prudential standards.¹ 

Finally, APRA proposes to collect enhanced details on RSE licensee ownership including details of all shareholders of the RSE licensee. APRA seeks feedback on the availability of the proposed data on shareholders, including whether the proposed collection will identify controlling shareholders. Together with other aspects of APRA’s collections, this will enable APRA to identify and monitor money flows to entities associated with shareholders.

APRA also proposes to extend the current reporting on remuneration and audit committees to cover all board committees. APRA seeks feedback on the completeness of the proposed committee list (or an equivalent label) to capture all board committees. 

RSE profile

APRA proposes enhancements to the data currently reported on the population of products, menus and options established in Phase 1 of the SDT project to collect details on promotor funds and sub-funds and employer sponsor sub-funds (in addition to defined benefit sub-funds currently reported) and their relationship to products. 

APRA seeks feedback on whether RSE licensees already use an existing Superannuation Product Identifier, Superannuation Menu identifier or Superannuation fees and costs arrangement identifier to identify sub-funds. Where possible, APRA requests examples of the sub-fund names and identifiers used.

APRA will continue to collect data on defined benefit funds and sub-funds, pooled superannuation trust investors and MySuper lifecycle products currently reported under pre-SDT reporting standards. With respect to the data collection on pooled superannuation trust investors, APRA requests feedback on the impact to industry of changing the reporting measurement from dollar value held by investors to units held by investors. 

However, APRA proposes to expand the data about factors that determine lifecycle strategy implementation from MySuper to any lifecycle product. APRA also proposes to collect data on the lifecycle investment strategy approach e.g. cohort or representative stage. APRA requests feedback on whether there any additional variables relevant for choice lifecycle products that should be captured in the proposed data collection.

APRA’s proposed reporting on the RSE profile is proportionate to the complexity of the business model. For example, a fund with an employer sponsor sub-fund and no defined benefit products, promotor arrangements or lifecycle products would only report five out of the proposed 10 tables.

Investments - Liquidity

Sound liquidity management promotes equity between members and ensures that members can redeem investments when requested in a range of market conditions. It is important that an RSE licensee has a deep understanding of the liquidity demands on the RSE, and each investment option, and how these demands might affect asset values and the RSE licensee’s ability to meet portability and payment obligations. 

APRA does not currently collect detailed data on liquidity from superannuation funds. APRA proposes to collect information on the key liquidity demand drivers; the key sources of liquidity including the reliability of these sources and the potential for these sources to deteriorate; and the potential effects of an adverse liquidity environment and liquidity stress factors on an RSE’s liquidity profile. APRA also proposes to collect information on liquidity management practices. 

The proposed data will enable APRA to identify RSEs or investment options experiencing or likely to experience liquidity management challenges and identify emerging liquidity risks across the industry, including potential systemic implications. 

APRA proposes to collect this data for the RSE as well as for investment options that are of particular interest from a liquidity risk perspective. To minimise the burden on industry, APRA proposes to limit investment options reporting for the liquidity tables to MySuper products and the following investment options: 

• With actual asset allocation of 20% or more to unlisted assets (where unlisted assets include Unlisted Property, Unlisted Infrastructure, Unlisted Equity, and Private Credit, and any other investments classified as Level 3 assets under the Australian Accounting Standards (AASB) fair value hierarchy);
   
• With 100% benchmark allocation to Investment Strategic Sector Type of 'Cash’ as reported in SRS 550.0 Table 1 for the same reporting period; or
   
• With a Liquidity Provider Type of ‘Liquidity Provider’ as reported in SRS 553.0 Table 3 for the same reporting period.

APRA seeks feedback on proposed criteria for reporting on investment options with material exposures to unlisted assets, as well as feedback on the expected volume of data under this proposed approach.

Liquidity demand

APRA proposes to capture information on specific cashflows which are of interest to liquidity demand at the fund level and for specified investment options. APRA is also proposing to capture further information on foreign currency derivative contracts outstanding by maturity given the potential for rapid and significant calls on liquidity. 

To further inform liquidity demand as well as monitor trends in member activity in relation to investment options, APRA also proposes to collect on a quarterly basis the member transaction inflows and member transaction outflows for all investment options which represent a significant proportion of the total investment option assets. APRA seeks feedback on the ease for RSE licensees to report this on a more frequent basis as requested and for other specified investment options as required.  

Sources of liquidity

APRA proposes to collect a summary of the expected timeframe to redeem assets at the fund level and for specified investment options. APRA seeks feedback on the suitability of the proposed redemption time periods. To inform APRA’s assessment of the reliability of sources of liquidity, APRA also proposes to collect further information on the type of assets classified as being available liquid assets (redeemable within 3 days). These proposals build on the framework of asset class and asset class characteristics established in phase 1 of SDT in the proposed collection. APRA seeks feedback on any challenges with reporting the value of Negotiable Certificates of Deposits (NCDs) on a look through basis.

APRA proposes to collect different cash flow types (such as member switching, derivative margining and capital calls/ funding commitments) and seeks feedback on the list of cash flow types to include. Please also provide feedback on the availability of data on liquidity for external product investment options.

Stress scenarios

APRA has also raised its expectations of liquidity stress testing, which forms an important part of an RSE licensee’s investment risk management process. It provides insights about the potential effects of different scenarios on outcomes for members as well as potential actions that are to be considered, including any rebalancing or liquidity risk mitigation strategies. APRA is therefore proposing that RSE licensees report the proposed measures of liquidity supply and demand for the RSE and specified investment options both in respect of the quarter as well as under the RSE licensee’s worst case liquidity stress scenario. Where no stress test has been conducted during the reporting period, an RSE licensee would report nil. APRA seeks feedback on the availability of the proposed data from the stress test results, as well as any other feedback on the feasibility of proposed approach.

Liquidity management practices

To support the assessment of whether RSE licensees’ liquidity management practice is commensurate with the nature, risk and complexity of investments and business operations and consistent with the requirements under SPS 530, APRA proposes to collect the metrics and indicators that RSE licensees have developed and are monitoring, as part of their liquidity management plan. 

This will support APRA’s increased focus on liquidity stress preparedness by RSE licensees across the industry. APRA seeks feedback on RSE licensees’ ability to report the proposed liquidity event data regarding trigger metrics or indicators, including whether the proposals align with RSE licensee’s approach and internal reporting. 

APRA proposes to collect data on liquidity more frequently during periods of liquidity stress to inform targeted supervisory responses. Specifically, APRA proposes to establish reporting on the estimated order of asset liquidation, which RSE licensees would only be required to report when instructed to by APRA, for example under an emerging liquidity stress. APRA seeks feedback on the ease in which RSE licensees could report other proposed liquidity data items on an ad-hoc basis within short response periods (such as a week) if required.

Investments - exposure concentrations and valuations

The collection of data on significant investment exposures across the superannuation industry enables APRA to identify exposure concentrations that could have material impact on portfolio risks and outcomes. To streamline the proposed collection, APRA proposes to collect data elements relating to valuations alongside investment exposures data for unlisted assets. 

APRA proposes to enhance the existing collection under SRS 532.0 Investment Exposure Concentrations (SRS 532.0) by building on the asset class and investment vehicle classifications which have been established in entities’ reporting systems through Phase 1 of the SDT project, as well as collecting the linkages to the established product, investment menu and investment option framework. 

APRA proposes to collect unique identifiers for individual assets and investment vehicles reported by leveraging data available in entities’ asset registry systems. This will enable enhanced use of the data with the ability to track exposures across time, and potentially across the industry. APRA seeks feedback on the availability of the proposed unique identifiers or alternatives.

APRA proposes to continue collecting exposure concentrations in underlying investment vehicles currently reported under SRS 532.0 Item 3 and seeks feedback on whether the existing reporting design can be improved.

Materiality threshold for exposures 

Consistent with SRS 532.0, APRA proposes to collect data for directly held and indirectly held investments of each RSE. To ensure that the materiality threshold for reporting is reflective of the increase in size of RSEs, APRA proposes to adjust the existing ‘large exposure’ threshold (at least one percent of the total investments of the RSE) by including an additional dollar-based threshold. APRA seeks feedback on this approach, the volume of investments that would be captured for $50 million, $100 million or $250 million, and suggestions on alternative measures.

Unlisted asset exposures and valuations

Valuations determine the entitlements members receive from investing their superannuation money. Inappropriate valuation practices, especially in unlisted assets, can have a direct adverse impact on outcomes for members. With increasing allocation in unlisted assets by superannuation funds, increased market volatility experienced recently and during the pandemic, having robust valuation governance that supports prudent valuation practices, policies and processes is more critical than ever before for RSE licensees in delivering quality outcomes for its members. 

An RSE licensee’s valuation governance is critical in ensuring that assets are valued fairly and members are treated equitably, and valuations practices are an area of increased focus in APRA in protecting the financial interest of superannuation members.

APRA does not currently collect data on valuation governance and practices. To date, insights have been achieved mainly through thematic reviews and targeted prudential engagements. APRA is proposing to address this gap to enhance APRA’s capability and insight to support supervision and regulatory activities in relation to valuation practices. The valuation data that APRA proposes to collect is information APRA expects that RSE licensees use in discharging their valuation governance responsibility under SPS 530. 

With this increased focus on unlisted assets and valuations of those assets, APRA proposes to collect the exposures of all directly held investments in unlisted assets (with no materiality threshold) and their valuation information. APRA seeks feedback on the proposed definition of ‘unlisted investments’ in the instructions, the volume of investments that would be captured, the availability of valuation information, and whether the proposed reporting is aligned to the information used by RSE licensees in valuation policies and practices.

APRA proposes to collect information on material unlisted investments held through unlisted investment vehicles, including special purpose vehicles and wholly owned vehicles. APRA seeks feedback on the proportionality of the proposed materiality threshold to the complexity of RSE licensee’s investment arrangements and the availability of valuations data for these investments on a look through basis. 

APRA seeks feedback on any asset classes and/or investment structures that would be challenging to report on a look through basis, and any alternative information the RSE licensee uses to address this challenge. APRA is open to applying a different materiality threshold in respect of indirectly held unlisted assets if it is helpful to industry. At a minimum APRA proposes that information on the value or proportion of assets revalued in the quarter would be reported. If the proposed data on valuation methodology is not available, RSE licensees may report ‘not available’.  

Unit pricing 

APRA proposes to collect information on unit pricing practices for all investment options as asset values are directly linked to unit prices and member entitlements. APRA wants to understand how RSE licensees are monitoring potential member equity risks as it relates to the mismatch between the frequency at which members transact on the accounts and the frequency at which the RSEL is able to transact on the underlying investments in the options. APRA welcomes details of metrics used by RSE licensees. 

APRA is also proposing to collect an indicator as to whether the investment option is utilised as a liquidity provider for the RSE. APRA seeks feedback on the proposed concept and definition of a liquidity provider, and whether it aligns with RSE licensee practices.

Investments - Derivative transactions

The default of a derivative counterparty can lead to losses and potentially systemic risk and contagion effects. Collecting information that is consistent with the requirements under the risk mitigation standards for non-centrally cleared derivatives in Prudential Standard CPS 226 Margining and risk mitigation for non-centrally cleared derivatives (CPS 226.0) will enable APRA to monitor potential entity, industry and systemic risks. 

In consultation with ABS, APRA proposes to combine the reporting for ABS (Reporting Standard SRS 722.0 ABS Derivatives Schedule) and for APRA (Reporting Standard SRS 550.0 Asset Allocation) and to align classifications and definitions. ABS requires this data for the compilation of the Australian National Accounts and other publications, and some reporting requirements may differ from accounting standards. This will streamline the data collection, consistent with the principle to ‘collect once and share’. Given the overlap in data items, APRA proposes to replace SRF 550.2 Table 1 and Table 2 with the new derivative transaction tables (SRF 550.3 Table 1 and SRF 550.4 Table 1 and Table 2) and seeks feedback on this proposed change.

As part of the collection review APRA and ABS assessed the possibility of using information currently collected by ASIC under the ASIC Derivative Transactions Rules (Reporting) 2022. The data was found to be insufficient for APRA and ABS’ objectives. For example, data such as exchange traded derivatives are not in the ASIC reporting.

APRA seeks feedback on the availability of the proposed reporting, as well as the proposed use of Legal Entity Identifiers (LEIs) as unique identifiers for reporting counterparties (for derivative transactions) and intermediary (for securities lending). 

Investments - Repurchase and Resale, and Securities Lending and Borrowing

Securities lending and borrowing transactions, and repurchase agreements present counterparty risk and liquidity risk, along with potential systemic risk implications to the broader financial system. Collecting data on such activities will enable APRA to monitor potential entity, industry and systemic risks. 

As with derivative transaction reporting, APRA proposes to combine the reporting for ABS (Reporting Standard SRS 721.0 ABS Securities Subject to Repurchase and Resale and Stock Lending and Borrowing) and APRA (Reporting Standard SRS 535.0 Securities Lending) to streamline data collection. APRA also proposes to align the reporting for repurchase agreements and securities lending with the System of National Accounts framework. 

APRA seeks feedback on the availability of data based on the proposed level of granularity to be reported for counterparties, collateral and financial instruments. APRA also seeks feedback on availability of details of securities (including market value) by the collateral posted or collected, where multiple collateral is posted or received for a security purchased under agreement to resell and securities lending/borrowing.

Indirect Investment Costs

APRA proposes to enhance the superannuation data collection to collect the annual indirect investment costs with each investment manager. This proposal addresses a key gap in APRA’s data on investment expenses and addresses recommendations from the productivity commission. The annual indirect investment costs (in combination with investment expenses data) will enable consistent and comparable measurement of cost efficiency of RSEs and the superannuation industry, to improve the transparency of costs that impact member outcomes and ensure transparency of investment management costs.

This proposal builds on the data RSE licensees already obtain from investment managers on indirect investment costs to meet disclosure obligations under RG97) and report the total indirect investment costs for each investment option to APRA under SRS 705.0.

Under Phase 1 reporting, APRA collects details of service providers and investments expenses data on SRS 332.0 Expenses (SRS 332.0). APRA anticipates that most service providers for which indirect investment costs will be reported will be identified under SRF 332.0 Table 1 Payees and Service Providers. APRA seeks feedback from industry on amending the instructions for Table 1 to report all payees or service providers with either an expense or indirect investment cost during the reporting period.

RSE Licensee financial statements

APRA currently collects data on RSE financials but not RSE licensee financials.² APRA proposes to address this key gap in APRA’s collections by introducing reporting on the statement of financial position; statement of comprehensive income; changes in trustee reserves/capital and related party payments.

APRA has also worked closely with ASIC in developing the proposals. APRA proposes to collect data aligned to the RSE licensee’s financial statements on an annual basis for the RSE licensee’s financial year in a standard format to allow analysis and comparison across entities. Proposed submission timeframes are consistent with current audit of the financials.  The proposed data mirrors (at a minimum) the financial reporting required of RSE Licensees to ASIC and will be shared with ASIC.

This data would help APRA to understand the flow of monies within superannuation trustees and the superannuation system, including dividend payments and expenditures from trustee capital, to support APRA’s assessment of financial resilience. It will also be shared with ASIC in conjunction with other data sets, providing important context to support ASIC in its role as conduct regulator.

The reporting standards released with this consultation include reporting instructions for accounting terms. Where relevant in these instructions, APRA has specified that entities should report data in accordance with Australian Accounting Standards. As part of APRA’s ongoing commitment to co-design data collections with industry and to ensure that reporting instructions are as clear and consistent as possible, APRA seeks feedback from industry on whether the current accounting standard instructions in the proposed reporting standard are sufficient or whether more detailed specific AASB references would be beneficial. This will help ensure that APRA’s taxonomy, driven by these instructions, meets both industry and agency needs.

Chapter 4 - Consultation feedback

Request for submissions

Formal written submissions for this consultation close on 31 March 2024. Subject to the feedback received, APRA intends to issue a response to consultation in the September 2024 quarter.

APRA invites written submissions from RSE licensees which are requested to be submitted through APRA Connect. Written submissions from other industry stakeholders should be emailed to superdatatransformation@apra.gov.au  and addressed to: General Manager, Macro and Industry Insights. 

Important disclosure requirements – publication of submissions 

All information in submissions will be made available to the public on the APRA website unless a respondent expressly requests that all or part of the submission is to remain in confidence.

Automatically generated confidentiality statements in emails do not suffice for this purpose.

Respondents who would like part of their submission to remain in confidence should provide this information marked as confidential in a separate attachment.

Submissions may be the subject of a request for access made under the Freedom of Information Act 1982 (FOIA). APRA will consider and determine such requests, if any, in accordance with the provisions of the FOIA.

Information in the submission about the affairs of any financial sector entity (including an APRA-regulated entity) that is not in the public domain and that is identified as confidential will be protected by section 56 of the Australian Prudential Regulation Authority Act 1998 and will therefore, subject to limited exemptions, be exempt from production under the FOIA.

Timing

APRA will hold round-table discussions in February 2024 with RSE licensees and non-RSE licensee stakeholders. To register for these roundtables please email superdatatransformation@apra.gov.au.

A summary of the consultation schedule is below:

Confidentiality 

APRA’s objective across all regulated industries is to maximise the amount of data that is determined as non-confidential and released publicly to enable improved industry transparency and drive better outcomes for members. Determining the new superannuation data to be non-confidential will increase industry transparency, enabling meaningful insights and comparisons as well as fostering confidence in the industry and its performance in delivering to its members. However, APRA recognises that there may be situations where further consideration is required with regards to the confidentiality of a number of the data items being collected.

APRA encourages stakeholders to provide information that will assist APRA in better understanding any impediments to providing the proposed data and requests comments made in submissions are as specific as possible, identifying specific data item(s) or instruction(s) where possible.

Data Security

As the data collecting agency, APRA regards maintaining the security of entity data as the highest priority.

APRA is governed by the Protective Security Policy Framework, which outlines required governance, protective, detective and response security capabilities. A security risk management practice is in place to assess cyber security risks, covering the availability, confidentiality and integrity of data and systems.

APRA applies the Australian Cyber Security Centre Information Security Manual (ACSC ISM), which includes the Essential Eight mitigation strategies. The ACSC ISM provides guidance for cyber security roles and incidents, procurement and outsourcing, security documentation, physical security, personnel security, communications infrastructure, communications systems, enterprise mobility, evaluated products, ICT equipment, media, system hardening, system management, system monitoring, software development, database systems, email, networking, cryptography, gateways and data transfers.

Data privacy

Additionally, APRA is bound by the Privacy Act 1988 (Privacy Act) and the Australian Government Agencies Privacy Code 2018 (Privacy Code). This includes a Privacy Impact Assessment (PIA) process that is used by APRA to assess initiatives undertaken in terms of the potential impacts these initiatives may have on the privacy of individuals involved. As part of this PIA process, a compliance assessment is conducted against the 11 Australian Privacy Principles (APPs) to which APRA is bound which are as follows:

• Open and transparent management of personal information (APP 1);
• Anonymity and pseudonymity (APP 2);
• Collection of solicited personal information (APP 3); 
• Dealing with unsolicited personal information (APP 4);
• Notification of the collection of personal information (APP 5);
• Use or disclosure of personal information (APP 6);
• Cross-border disclosure of personal information (APP 8);
• Quality of personal information (APP 10);
• Security of personal information (APP 11); 
• Access to personal information (APP 12); and 
• Correction of personal information (APP 13). 

APRA will undertake a PIA for the data points outlined in this paper. 

The Privacy Act imposes obligations on APRA regarding the collection, use, storage and disclosure of personal information. APRA will continue to comply with its obligations under the Privacy Act.

Attachment A: List of draft reporting standards

• Draft Reporting Standard SRS 101.0 Definitions for Superannuation Data Collections
• Draft Reporting Standard SRS 251.0 Insurance
• Draft Reporting Standard SRS 332.0 Expenses and Indirect Investment Costs
• Draft Reporting Standard SRS 340.0 RSE Licensee Financial Statements
• Draft Reporting Standard SRS 550.0 Asset Allocation
• Draft Reporting Standard SRS 551.0 Liquidity
• Draft Reporting Standard SRS 552.0 Securities Subject to Repurchases and Resale and Securities Lending and Borrowing
• Draft Reporting Standard SRS 553.0 Investment Exposure Concentration and Valuations
• Draft Reporting Standard SRS 604.0 RSE Licensee Profile
• Draft Reporting Standard SRS 605.0 RSE Structure
• Draft Reporting Standard SRS 606.0 RSE Profile
• Draft Reporting Standard SRS 607.0 RSE Business Model 

The draft reporting standards released today for consultation can be found here.

Attachment B: Consultation proposals reporting table mapping to current collections

The consultation proposals mapping can be found here.

Footnotes

¹ See APRA’s 2023 Corporate Plan APRA Corporate Plan 2023-24.

² The broader topic of financial reporting, including review of all RSE financial data currently reported to APRA is not in scope for this consultation.