Increased transparency of general insurance and life insurance data
In 2020, APRA released a consultation proposing to determine general insurance (GI) class of business and life insurance (LI) product group data – that is submitted to APRA - to be non-confidential1. APRA also proposed to begin publishing explanations from individual insurers in relation to material revisions to, or large movements in, their data, including whether or not APRA requested the revision.
This letter outlines APRA’s decisions on these proposals including its response to the submissions received during the consultation2.
Proposal 1: Determine class of business and product group data to be non-confidential
APRA will implement the proposal to determine class of business and product group data to be non-confidential.
By publishing more of the data that APRA collects, APRA aims to promote greater transparency in the LI and GI industry in line with APRA’s prudential objectives3. In turn, this will support competition, contestability and efficiency in the financial system and facilitate innovative uses of data. Additional benefits include:
- Informing the public: publishing more of the data APRA collects will generate greater consumer understanding and more informed public discussion of insurance-related issues; and informed decision-making for all users of the GI and LI statistical publications4.
- Influencing by comparison: promote better practices through comparability and peer review, facilitating analysis and understanding of observed trends and maintaining confidence in the Australian financial system.
- Driving accountability: encourage insurers to act with discipline and encourage better, more efficient market behaviour.
Submissions were generally supportive of the intent of APRA’s initiative, albeit there were some concerns raised.
A number of respondents raised concerns about APRA publishing or otherwise disclosing class of business/ product group data for individual insurers. APRA will not be publishing insurer level data from reporting forms beyond that already published. Should APRA plan in the future to expand the publication of insurer level data to include class of business / product group data for specific entities, APRA will formally need to consult on any such proposals at that time with industry.
APRA’s determination will only impact APRA’s existing publications of aggregate industry data.5 In practice it will result in APRA reporting a very limited number of data items which were previously masked in these publications. All reporting items impacted are outlined in Appendix A of this letter.
APRA has strict procedures and processes in place when considering requests to release data and will continue to respect any potential commercial concerns relating to the data collected from insurers.
Proposal 2: Publishing explanations from individual insurers
Respondents were generally concerned that this may result in the release of commercially sensitive information at an insurer level. In response to these concerns, APRA has decided not to proceed with this proposal.
Additional feedback
APRA sought feedback on the question of how long data items should remain confidential to avoid market sensitive disclosures. Given limited feedback, APRA will not be making a determination on this point at this time, but may decide to consult again on this issue in the future.
Next steps
APRA will release the first of the impacted publications, the Quarterly General Insurance Performance Statistics and Quarterly Life Insurance Performance Statistics for the September 2021 reference period, on 25 November 2021.
Yours sincerely,
Alison Bliss
General Manager
Data Analytics and Insights
Appendix A – Impacted reporting forms
General Insurance – Level 1 Insurers
Reporting Form | Current data deemed non-confidential (1) | Determination of non-confidential data |
GRF_115_0: Outstanding Claims Liabilities - Insurance Risk Charge | Were actuarial services used to complete this return (Yes/No) | All data items, excluding 'Adjustments and exclusions to prudential requirements for the OCL Insurance Risk Charge' |
GRF_115_1: Premiums Liabilities - Insurance Risk Charge | Were actuarial services used to complete this return (Yes/No) | All data items, excluding 'Adjustments and exclusions to prudential requirements for the PL Insurance Risk Charge' |
GRF_310_1_L: Premium Revenue and Reinsurance Expense (L) | Section 3: | All data items |
GRF_310_2_L: Claims Expense and Reinsurance Recoveries (L) | Section 3: | All data items |
GRF_310_3_L: Details of Income and Expenses | 1. Investment income – All data items | All data items |
GRF_410_0_L: Movement in Outstanding Claims Liabilities | Section 3: | All data items |
GRF_420_0_L: Premium Revenue by State and Territory of Australia (L) | None | All data items |
GRF_430_0_L: Claims Expense by State and Territory of Australia (L) | None | All data items |
GRF_440_0_L: Claims Development Table (L) | Section 3: | All data items |
(1) Australian Prudential Regulation Authority (confidentiality) determination No. 11 of 2015.
General Insurance – Level 2 Groups
Reporting Form | Current data deemed non-confidential (1) | Determination of non-confidential data |
GRF_115_0A_G: Outstanding Claims Liabilities - Insurance Risk Charge - Australia by Class of Business (G) | Were actuarial services used to complete this return (Yes/No) | All data items, excluding 'Adjustments to OCL Insurance Risk Charge' |
GRF_115_1A_G: Premiums Liabilities - Insurance Risk Charge - Australia by Class of Business (G) | Were actuarial services used to complete this return (Yes/No) PART A: PREMIUMS LIABILITIES - GPS 320 BASIS PART B: PREMIUMS LIABILITIES - AASB BASIS
PART C: ADDITIONAL POLICIES RISK CHARGE PART D: TOTAL PREMIUMS LIABILITIES | All data items, excluding 'Adjustments to PL Insurance Risk Charge' |
(1) Australian Prudential Regulation Authority (confidentiality) determination No. 11 of 2015.
Life Insurance
Reporting Form | Current data deemed non-confidential (2) | Determination of non-confidential data |
|---|---|---|
LRF_200_0: Capital Adequacy Supplementary Information | Section 2: Insurance risk charge | All data items |
LRF_330_0: Summary of Revenue and Expenses | (i) Totals by class of business – all data items | All data items |
LRF_400_0: Statement of Policy Liabilities | (i) 2. Totals by class of business and basis – all data items | All data items |
LRF_420_0: Assets Backing Policy Liabilities | (i) 3.Totals by class of business – all data items | All data items |
LRF_430_0: Sources of Profit | (i) 2. Totals by class of business and profit allocation – all data items | All data items |
(2) Australian Prudential Regulation Authority (confidentiality) determination No. 12 of 2015.
Footnotes:
1. APRA commences consultation on increased transparency of general insurance and life insurance data.
2. APRA received 9 submissions from interested parties in response to the proposals in the discussion paper. Of these submissions, 3 are available at: Confidentiality of general insurance and life insurance data. The other 6 submissions were marked as confidential.
3. APRA's objectives.
4. This initiative also aligns with the Australian Government Public Data Policy Statement. See: https://pmc.gov.au/public-data/public-data-policy.
5. Specifically, Quarterly General Insurance Performance Statistics, Quarterly Life Insurance Performance Statistics, and General Insurance Claims Development Statistics. The proposals relate to current and historical data in these publications.