{"id":"F2018L00765","name":"Australian Prudential Regulation Authority (confidentiality) determination No.1 of 2018","slug":"australian-prudential-regulation-authority-confidentiality-determination-no-1-of-2018","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":97364,"registerId":"commonwealth-F2018L00765-current","compilationNumber":null,"startDate":"2026-04-02","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Australian Prudential Regulation Authority (confidentiality) determination No.1 of 2018","content":"![](image.001.png)\n\nAustralian Prudential Regulation Authority (confidentiality) determination No.1 of 2018\n\nInformation provided by general insurers and Lloyd’s underwriters for the purposes of the National Claims and Policies Database under Reporting Standard GRS 800.1, GRS 800.2, GRS 800.3, LOLRS 800.1, LOLRS\n\n800.2 and LOLRS 800.3\n\nAustralian Prudential Regulation Authority Act 1998\n\nI, Alison Bliss, a delegate of APRA, under section 57 of the Australian Prudential\n\nRegulation Authority Act 1998, DETERMINE that a reporting document specified in Part 1 of the Schedule does not contain confidential information, except for the items of information specified in Part 2 of the Schedule.\n\nThis determination commences on the date of registration on the Federal Register of Legislation under the Legislation Act 2003.\n\nNote: The effect of this determination is that the non-confidential information (other than personal information within the meaning of the Privacy Act 1988) may be published under subsection 56(5C) of the Australian Prudential Regulation Authority Act 1998.\n\nDated: 7 June 2018\n\n\\[Signed\\]\n\nAlison Bliss\n\nGeneral Manager, Data Analytics\n\n| InterpretationIn this determination: | |\n| ------------------------------------ | --- |\n\nAPRA means the Australian Prudential Regulation Authority.\n\ngeneral insurer has the meaning given in section 11 of the Insurance Act 1973.\n\nLloyd’s underwriters has the meaning given in section 3 of the Insurance Act 1973.\n\nreporting document means a reporting document within the meaning of section 13 of the Financial Sector (Collection of Data Act) 2001.\n\nSchedule\n\nPart 1 (reporting documents covered by this\n\ndetermination)\n\n1. The level 1 reports covered by this Determination are (the level 1 reports):\n\n| | Policy data reports- All States |\n| --- | --------------------------------------- |\n| b. | Claims Data Reports- National |\n| c. | Claims Data Reports- NSW |\n| d. | Claims Data Reports- Victoria |\n| e. | Claims Data Reports- Queensland |\n| f. | Claims Data Reports- Western Australia |\n| g. | Claims Data Reports- South Australia |\n| h. | Claims Data Reports- Tasmania |\n| i | Claims Data Reports- Northern Territory |\n| j. | Claims Data Reports- ACT |\n\n2. The level 1 reports include all data items extracted, for the purpose of preparing the\n\nlevel 1 reports, from reporting documents given to APRA on or before the date of this determination by general insurers and Lloyd’s Underwriters under the following\n\nreporting standards made under the Financial Sector (Collection of Data Act) 2001:\n\n```html\n
  1. General Insurers

Reporting Standard GRS 800.1 Policy Data: Public and Product Liability and Professional Indemnity Insurance

b.

Reporting Standard GRS 800.2 Claim Data: Public and Product Liability and Professional Indemnity Insurance

c.

Reporting Standard GRS 800.3 Facility Business Data: Public

and Product Liability and Professional Indemnity Insurance

B. Lloyd’s Underwriters

Reporting Standard LOLRS 800.1 Policy Data: Public and

Product Liability and Professional Indemnity Insurance

b.

Reporting Standard LOLRS 800.2 Claim Data: Public and Product Liability and Professional Indemnity Insurance

c.

Reporting Standard LOLRS 800.3 Facility Business Data: Public and Product Liability and Professional Indemnity Insurance

\n```\n\n3. The level 2 reports covered by this Determination are (the level 2 reports):\n\n```html\n
  1. Policy reports

Year by Product (filter by: COB, State, Occupation, LOI, EDA)

b.

Product by State (filter by: Year, COB, LOI, EDA)

c.

Product by LOI (filter by: Year, COB, State, Occupation)

d.

Product by EDA (filter by: Year, COB, State, Occupation)

e.

Year by State (filter by: COB, Product, LOI, EDA)

f.

LOI by State (filter by: Year, COB, Product)

g.

EDA by State (filter by: Year, COB, Product)

h.

Year by LOI (filter by: COB, State, Product, Occupation)

i.

Year by EDA (filter by: COB, State, Product, Occupation)

j.

Occupation by Year (filter by: COB, Product, LOI, EDA)

k.

Occupation by Product (filter by: Year, COB, LOI, EDA)

l.

Occupation by LOI (filter by: Year, COB, Product, Occupation)

m.

Occupation by EDA (filter by: Year, COB, Product, Occupation)

B. Claim reports

Year by Development year (filter by: COB, State, Product, Occupation, LOI, EDA)

b.

Year by Product (filter by: COB, State, Occupation, LOI, EDA)

c.

Product by State (filter by: Year, COB, LOI, EDA)

d.

Product by LOI (filter by: Year, COB, State, Occupation)

e.

Product by EDA (filter by: Year, COB, State, Occupation)

f.

Year by State (filter by: COB, Product, LOI, EDA)

g.

LOI by State (filter by: Year, COB, Product)

h.

EDA by State (filter by: Year, COB, Product)

i.

Year by LOI (filter by: COB, State, Product, Occupation)

j.

Year by EDA (filter by: COB, State, Product, Occupation)

k.

Occupation by Year (filter by: COB, Product, LOI, EDA)

l.

Occupation by Product (filter by: Year, COB, LOI, EDA)

m.

Occupation by LOI (filter by: Year, COB, Product, Occupation)

n.

Occupation by EDA (filter by: Year, COB, Product, Occupation)

C. Facility reports

Reporting period (filter by: Occupation)

b.

Occupation (filter by: Reporting period)

D. Facility in run-off reports

Reporting period (filter by: Occupation)

b.

Occupation (filter by: Reporting period)

\n```\n\n4. The level 2 reports include data items extracted, for the purpose of preparing the level 2 reports, from reporting documents given to APRA on or before the date of this determination by general insurers and Lloyd’s Underwriters under the following reporting standards made under the Financial Sector (Collection of Data Act) 2001:\n\n| | Reporting Standard GRS 800.1 Policy Data: Public and Product Liability and Professional Indemnity Insurance |\n| --- | --------------------------------------------------------------------------------------------------------------------- |\n| b. | Reporting Standard GRS 800.2 Claims Data: Public and Product Liability and Professional Indemnity Insurance |\n| c. | Reporting Standard GRS 800.3 Facility Business Data: Publicand Product Liability and Professional Indemnity Insurance |\n\n5. The level 2 reports include the following data items:\n\n```html\n
  1. Data measures

Gross written premium, gross earned premium, number of risks written and average earned premium.

b.

Number of claims reported, number of claims finalised, gross claim payments and gross claims incurred, each of which is available on an underwriting year, accident year and calendar year basis.

c.

Premiums received, claims paid, and number of policies, number of claims and number of facilities.

B. Data dimensions

Year

b.

Development year

c.

Class of business

d.

State/Jurisdiction

e.

Product

f.

Industry/Occupation

g.

Limit of indemnity

h.

Excess/deductible

C. Dimension categories available in level 2 reports

Year

b.

Underwriting years

c.

Accident years

d.

Calendar years

e.

Six month reporting period (facility reports only)

D. Development year

ALL

b.

0 – 9

E. Class of business (COB)

PI

b.

PL

F.

State/Jurisdiction

a.

All States

b.

No detailed occupation information is available except on All States’

c.

NSW

d.

VIC

e.

QLD

f.

SA

g.

WA

h.

TAS

i.

NT

j.

ACT

k.

Unknown

G. Product

ALL

b.

D&O and employment practices liability

c.

Medical indemnity/Malpractice

d.

Other professional indemnity

e.

Construction liability

f.

Product liability

g.

Public liability

h.

Other product and public liability

H. Industry/Occupation

ALL

b.

No detailed state/jurisdiction information is available except on ‘ALL’

c.

2 digit ANZSIC code; or

d.

character occupation code

e.

A - Financial occupations

f.

B - General Consultants

g.

C - Medical & Paramedical occupations

h.

D - Legal & Para Legal occupations

i.

E - Real Estate occupations

j.

F - Agricultural, Horticultural occupations

k.

G - Schools, Colleges occupations

l.

H - Insurance occupations

m.

I - Local Government occupations

n.

J - Miscellaneous occupations

o.

K – Architects

p.

L - Engineering occupations

q.

M - Surveying occupations

r.

N – Defamation

I. Limit of indemnity (LOI)

ALL

b.

No detailed EDA information is available except on ‘ALL’

c.

0-5m

d.

5m-10m

e.

10m+

J. Excess/deductible (EDA)

ALL

b.

No detailed LOI information is available except on ‘ALL’

c.

0-$499

d.

$500-$999

e.

$1,000+

\n```\n\n \n\nSchedule\n\nPart 2 (items of information from reporting documents that are to remain confidential)\n\n Data items in respect of the following data dimensions are not covered by this Determination:\n\n data on state/jurisdiction and also occupation; and\n data on the limit of indemnity and also the excess/deductible.","sortOrder":0}],"analysis":{"flash_summary_failed":{"failed":true,"reason":"A positive credit balance is required for all requests, including BYOK, so fallback providers remain available. Add credits at https://vercel.com/d?to=%2F%5Bteam%5D%2F%7E%2Fai%3Fmodal%3Dtop-up to continue.","source":"analysis-cron"},"flash_summary":{"complexity_score":5,"scope_assessment":{"changed":false,"description":"This determination is narrowly focused: it classifies which items drawn from specified insurer reporting standards may be treated as non‑confidential for publication from APRA's National Claims and Policies Database, while preserving confidentiality for two specific cross‑tabulations. It implements a publication decision consistent with the database's stated purpose rather than expanding APRA's remit. There is no substantial scope growth beyond enabling publication of aggregated outputs from the covered reporting standards."},"complexity_factors":["Cross‑references to multiple Acts and instruments (APRA Act s.57 and s.56(5C); Financial Sector (Collection of Data) Act reporting standards).","Two tiered reporting structure (level 1 and level 2) with many listed report names and state/national breakdowns (lengthy enumerated lists).","Level 2 contains numerous data measures, dimensions and categories (many discrete cells: Year, Development year, COB, State, Product, Occupation, LOI, EDA, etc.).","Detailed categorical lists (multiple product types, occupation codes, LOI and EDA ranges) increasing the permutations for publishing logic.","A small but important negative carve‑out (Part 2) that is conditional on combinations of dimensions (i.e. confidentiality triggered only where certain dimensions are combined).","Defined terms (APRA, general insurer, Lloyd's underwriters, reporting document) and reliance on external reporting standards (GRS/LOLRS) create further cross‑referencing.","Operational complexity for publication (need for suppression rules, small‑cell checks) implied but not specified in the determination."],"plain_english_summary":"**What this determination does, in plain English**\n\n- APRA (the Australian Prudential Regulation Authority) has formally decided which pieces of insurer reporting it considers non‑confidential and therefore may be published from APRA's National Claims and Policies Database. The decision is made under section 57 of the APRA Act. The practical effect is that APRA may publish the non‑confidential items (subject to the Privacy Act protection of personal information) under subsection 56(5C) of the APRA Act.\n\n**Which reports and data are in scope**\n\n- The determination covers specific reporting documents provided to APRA by general insurers and Lloyd's underwriters under a set of reporting standards (GRS 800.1, GRS 800.2, GRS 800.3 and the equivalent Lloyd’s standards LOLRS 800.1, 800.2, 800.3). (See Part 1 of the Schedule.)\n- It lists two groups of outputs that APRA prepares from those reports: \"level 1\" reports (policy and claims reports at national and state levels, and facility reports) and \"level 2\" reports (a range of aggregated tables such as \"Year by Product\", \"Product by State\", \"Year by Development year\", and many other cross‑tabulations and filters). The Schedule sets out the exact report names and the filters/dimensions available in level 2 reports.\n\n**What data elements will be published**\n\n- Level 2 reports include standard insurance aggregates (for example: gross written premium, gross earned premium, numbers of risks and policies, number of claims reported and finalised, claim payments and incurred claims) and a range of dimensions/filters (for example: Year, Development year, Class of business, State/jurisdiction, Product, Industry/Occupation, Limit of indemnity (LOI), Excess/deductible (EDA)). The Schedule lists the exact measures and dimensions.\n\n**What remains confidential**\n\n- The determination explicitly preserves confidentiality for two specific combinations of data dimensions. Data items combining: (a) state/jurisdiction together with occupation; and (b) limit of indemnity together with excess/deductible will remain confidential and are not cleared for publication under this determination (see Part 2 of the Schedule).\n\n**Who this affects**\n\n- Directly: general insurers and Lloyd's underwriters who supply the covered reporting documents to APRA (they are the data providers). APRA is affected as the publisher/processor of the data.\n- Indirectly: researchers, regulators, market analysts, insurers' competitors, and the public who may use the published aggregated outputs. Policyholders are affected to the extent their non‑personal information appears in aggregated outputs (personal information remains subject to the Privacy Act).\n\n**Why it matters (mechanics and trade‑offs)**\n\n- APRA's mechanical change is to classify most of the fields extracted for the listed level 1 and level 2 outputs as non‑confidential, enabling publication of aggregated insurance market statistics.\n- APRA claims the purpose is to allow the publication of those aggregated datasets from the National Claims and Policies Database. That objective creates trade‑offs:\n - Benefits: aggregated publication provides data for market monitoring, benchmarking, research and policy analysis. It lowers information frictions for third parties who rely on industry‑level statistics.\n - Costs and risks: publishing aggregated commercial data can reduce informational asymmetries but may expose commercially sensitive information about firms' books if very granular cross‑tabs are published. The determination narrows this risk by withholding two sensitive cross‑tabulations (state x occupation; LOI x EDA), but residual re‑identification or competitive sensitivity can remain where narrow filters or small cells exist.\n- Compliance and burden: the determination does not require new reporting from insurers (the data is already supplied under the Financial Sector (Collection of Data) Act). The decision changes how APRA may disclose the data, not the reporting obligations, so direct compliance cost to insurers is minimal. The main implementation burden is on APRA to ensure published outputs respect the confidentiality carve‑outs and to manage de‑identification and small‑cell risks.\n- Bureaucratic discretion and governance: the determination is made by an APRA delegate under statutory power (s.57). That gives APRA discretion over which reporting documents to clear for publication; future determinations could expand or contract what is non‑confidential.\n- Effects on private enterprise and competition: publicly available aggregated statistics may assist smaller insurers and new entrants by improving market information; conversely, they may erode some informational advantages held by incumbents if APRA publishes granular industry metrics. The specific confidentiality carve‑outs suggest APRA has preserved some protections for sensitive, high‑value cross‑tabs.\n\n**Implementation risks and mitigations**\n\n- The most concrete implementation risk is re‑identification: even where particular dimension combinations are withheld, other combinations and filters might permit inference about small groups. The determination mitigates this by explicitly retaining confidentiality for two high‑risk cross‑tabs and by preserving the Privacy Act protection for personal information, but APRA must still apply operational safeguards (aggregation thresholds, cell suppression) when publishing.\n\n**Bottom line (mechanical summary)**\n\n- APRA has authorised publication of a wide set of aggregated insurance statistics drawn from specific insurer reports, while reserving confidentiality for two sensitive cross‑tabulations (state with occupation; LOI with EDA). Insurers keep their existing reporting duties, but APRA can now release substantial non‑personal aggregated information from those reports.\n\n(References in this summary: the determination as a whole; Part 1 and Part 2 of the Schedule; section 57 and subsection 56(5C) of the Australian Prudential Regulation Authority Act 1998.)"},"kimi_summary":{"content_quality":"ok","complexity_score":4,"scope_assessment":{"changed":false,"description":"This determination appears tightly scoped to its original purpose: specifying confidentiality treatment for National Claims and Policies Database reporting standards. It does not expand beyond the specific reporting standards GRS 800.1-800.3 and LOLRS 800.1-800.3, and maintains the established framework of determining which data items are non-confidential for publication purposes under section 57 of the APRA Act."},"complexity_factors":["Extensive tabular data categorising 40+ specific report types across Level 1 and Level 2 reports","Cross-references to 6 separate reporting standards (GRS 800.1-800.3 and LOLRS 800.1-800.3) under the Financial Sector (Collection of Data) Act 2001","Nested definitional dependencies: terms like 'general insurer' and 'Lloyd's underwriters' are defined by reference to the Insurance Act 1973","Complex multi-dimensional data filtering logic with 10 data dimensions and numerous category values (e.g., 18 occupation categories, 8 product types, 11 state/jurisdiction categories)","Conditional confidentiality rule at the end: confidentiality applies to specific *combinations* of data dimensions rather than entire data fields, creating a logical AND condition","Technical insurance terminology throughout (e.g., 'development year', 'underwriting year', 'limit of indemnity', 'excess/deductible', 'facility business')","Dual-level reporting structure (Level 1 raw reports vs Level 2 aggregated/analytical reports) with different data item specifications for each"],"plain_english_summary":"This APRA determination rules which liability-insurance data in the National Claims and Policies Database can be published and which must remain confidential. It makes most aggregated policy and claims statistics public—helping researchers, regulators, insurers and consumers—while safeguarding privacy and commercial sensitivity.\n\nKey exceptions: any data combining state/jurisdiction with occupation, and any data combining limit of indemnity with excess/deductible, remain secret to prevent re-identification or disclosure of sensitive pricing information."}},"importantCases":[],"_links":{"self":"/api/acts/australian-prudential-regulation-authority-confidentiality-determination-no-1-of-2018","history":"/api/acts/australian-prudential-regulation-authority-confidentiality-determination-no-1-of-2018/history","analysis":"/api/acts/australian-prudential-regulation-authority-confidentiality-determination-no-1-of-2018/analysis","conflicts":"/api/acts/australian-prudential-regulation-authority-confidentiality-determination-no-1-of-2018/conflicts","importantCases":"/api/acts/australian-prudential-regulation-authority-confidentiality-determination-no-1-of-2018/important-cases","documents":"/api/acts/australian-prudential-regulation-authority-confidentiality-determination-no-1-of-2018/documents"}}