Banking (prudential standard) determination No. 3 of 2024

This instrument revokes the earlier Banking (prudential standard) determination No. 1 of 2023 and replaces Prudential Standard APS 330 Public Disclosure with a new Prudential Standard APS 330, made under section 11AF of the Banking Act 1959 (the Act). The new standard commences 1 January 2025 (instrument header; Authority; Application, para 3). Its stated objective, in APRA’s own words, is to require certain authorised deposit-taking institutions (ADIs) to publicly disclose key prudential information to contribute to market transparency and enhance market discipline (Objectives and key requirements).

Mechanically, the Prudential Standard does the following:

Incorporates by reference the Basel Committee on Banking Supervision (BCBS) “Disclosure requirements” standard (the BCBS Standard) as it exists from time to time, and requires ADIs to make the prudential disclosures set out in that BCBS Standard, subject to express Australian modifications in Attachment A (General requirements, para 1; Attachment A, General modifications, para 1).
Limits its application to ADIs other than foreign ADIs, non-significant financial institutions (non-SFIs) and purchased payment facility providers, while allowing APRA to extend application in particular cases (Application, paras 1-1.1).
Requires ADIs to have a board‑approved disclosure policy and to maintain internal controls to achieve accuracy and appropriateness of disclosures; an Accountable Person must attest in writing that disclosures comply with the ADI’s disclosure policy (Disclosure policy; Verification of disclosures, paras 1-3).
Prescribes presentation, timing and format requirements, including a dedicated “Regulatory Disclosures” web section, publication concurrent with lodgement of financial reports under the Corporations Act, provision of quantitative data in CSV/Excel or APRA‑approved format, and a minimum 12‑month archive of prior disclosures (Presentation of disclosures; Frequency and timing of disclosures, paras 1-3).

meta-content-style-type: text/css meta-content-type: application/xhtml+xml; charset=utf-8 meta-keywords: "[SEC=OFFICIAL]"

Commonwealth Coat of Arms

Banking (prudential standard) determination No. 3 of 2024

Prudential Standard APS 330 Public Disclosure

Banking Act 1959

I, Clare Gibney, a delegate of APRA:

(a) under subsection 11AF(3) of the Banking Act 1959 (the Act), REVOKE Banking (prudential standard) determination No. 1 of 2023, including Prudential Standard APS 330 Public Disclosure made under that determination; and

(b) under subsection 11AF(1) of the Act, DETERMINE Prudential Standard APS 330 Public Disclosure in the form set out in the schedule, which applies to all ADIs and authorised NOHCs to the extent provided in paragraphs 2 to 4 of the prudential standard.

This instrument commences on 1 January 2025.

Dated: 27 August 2024

Clare Gibney

Executive Director

Policy & Advice Division

Interpretation

In this instrument:

APRA means the Australian Prudential Regulation Authority.

ADI, authorised NOHC and prudential standard have their respective meanings given in subsection 5(1) of the Act.

Schedule

Prudential Standard APS 330 Public Disclosure comprises the document commencing on the following page.

Commonwealth Coat of Arms

Prudential Standard APS 330

Public Disclosure

Objectives and key requirements of this Prudential Standard<br>This Prudential Standard requires certain authorised deposit-taking institutions (ADIs) to publicly disclose key prudential information, to contribute to the transparency of financial markets and to enhance market discipline. This Prudential Standard applies to ADIs that are locally-incorporated significant financial institutions.<br>The key requirements of this Prudential Standard are that an ADI must:<br>make clear, comprehensive, meaningful, consistent, and comparable public disclosures of prudential information;cover key prudential metrics and information relating to risk profile and financial resilience, as defined by the Basel Committee on Banking Supervision (BCBS) and adjusted by APRA for the Australian context; andhave a formal policy approved by the Board, with effective internal controls and procedures, to ensure its disclosures are appropriate and accurate.

Table of Contents

Authority

Application

Interpretation

Adjustments and exclusions

Previous exercise of discretion

Key principles

General requirements

Attachment A – Modifications to disclosure requirements in the BCBS Standard

Authority

This Prudential Standard is made under section 11AF of the Banking Act 1959 (the Banking Act).

Application

This Prudential Standard applies to all authorised deposit-taking institutions (ADIs) with the exception of:
foreign ADIs;
non-significant financial institutions (non-SFIs); and
purchased payment facility providers.

Additionally, APRA may determine in a particular case that this Prudential Standard applies to a foreign ADI or non-SFI.

A reference to an ADI in this Prudential Standard, unless otherwise indicated, is a reference to:
an ADI on a Level 1 basis; and
a group of which an ADI is a member on a Level 2 basis.
If an ADI is a member of a group on a Level 2 basis, the ADI is not required to comply with the requirements in this Prudential Standard on a Level 1 basis unless APRA determines otherwise. If an ADI to which this Prudential Standard applies is:
the holding company for a group, the ADI must ensure that the requirements in this Prudential Standard are met on a Level 2 basis, where applicable; or
a subsidiary of an authorised non-operating holding company (authorised NOHC), the authorised NOHC must ensure that the requirements in this Prudential Standard are met on a Level 2 basis, where applicable.
This Prudential Standard commences on 1 January 2025.

Interpretation

Terms that are defined in Prudential Standard CPS 001 Defined terms appear in bold the first time they are used in this Prudential Standard.
Where this Prudential Standard provides for APRA to exercise a power or discretion, this power or discretion will be exercised in writing.
In this Prudential Standard, unless the contrary intention appears, a reference to an Act, Regulations, Prudential Standard or Reporting Standard is a reference to the instrument as in force from time to time.

Adjustments and exclusions

APRA may adjust or exclude a specific prudential requirement in this Prudential Standard in relation to one or more ADIs or authorised NOHCs.[1]

Previous exercise of discretion

An ADI must contact APRA if it seeks to place reliance, for the purposes of complying with this Prudential Standard, on a previous exemption or other exercise of discretion by APRA under a previous version of this Prudential Standard.

Key principles

An ADI must make clear, comprehensive, meaningful, consistent, and comparable public disclosures of prudential information as required in this Prudential Standard, so as to contribute to the transparency of financial markets and to enhance market discipline.

Disclosures must be clear

Disclosures must be presented in a form that is understandable to key stakeholders, including investors, analysts, financial customers and others, and communicated through an accessible medium. Important messages must be highlighted and easy to find. Complex issues must be explained in a simple language with important terms defined. Related risk information must be presented together.

Disclosures must be comprehensive

Disclosures must describe an ADI’s main activities and all significant risks, supported by relevant underlying data and information. Significant changes in risk exposures between reporting periods must be described, together with the appropriate response by management.
Disclosures must provide sufficient information in both qualitative and quantitative terms on an ADI’s processes and procedures for identifying, measuring, and managing those risks. The level of detail of such disclosure must be proportionate to an ADI’s complexity.
Disclosures must be consistent with the manner in which the ADI assesses and manages risks and strategy, helping users to understand its risk tolerance and appetite. Where the minimum requirements for prudential disclosures set out in this Prudential Standard do not adequately capture this, the ADI must disclose additional information.

Disclosures must be meaningful to intended users

Disclosures must highlight an ADI’s most significant current and emerging risks and how those risks are managed, including information that is likely to receive market attention. Where meaningful, linkages must be provided to line items on the balance sheet or the income statement. Voluminous disclosures that do not add value to users’ understanding or do not communicate useful information must be avoided. Furthermore, information which is no longer meaningful or relevant to users must be removed.

Disclosures must be consistent over time

Disclosures must be consistent over time to enable key stakeholders to identify trends in an ADI’s risk profile across all significant aspects of its business. Additions, deletions and other important changes in disclosures from previous reports, including those arising from an ADI’s specific, regulatory or market developments, must be highlighted and explained.

Disclosures must be comparable across ADIs

The level of detail and the format of presentation of disclosures must be sufficient to enable key stakeholders to perform meaningful comparisons of business activities, prudential metrics, risks, and risk management between ADIs and across jurisdictions.

General requirements

An ADI must make the prudential disclosures as set out in the Standard made by the Basel Committee on Banking Supervision (BCBS Standard) titled “Disclosure requirements”, as the BCBS Standard exists from time to time, subject to the modifications specified in Attachment A of this Prudential Standard. The BCBS Standard, including disclosure templates and tables that an ADI must complete and disclose, is available on the Bank of International Settlements website.[2]
An ADI may make minor modifications to the content of its disclosures under the BCBS Standard where there are inconsistencies between the BCBS Standard and the applicable requirements in any Prudential Standards. The modified disclosures must include a description of the modifications and commentary to explain why the modification was made. The ADI must notify APRA regarding the modifications in advance of making the modified disclosures. The ADI is not required to notify APRA again if the same modifications are made for future disclosures.
The BCBS Standard covers key prudential metrics and information relating to an ADI’s risk profile and financial resilience, including risk management approach, regulatory capital, credit risk, counterparty credit risk, securitisation, market risk, operational risk, interest rate risk in the banking book (IRRBB), macroprudential indicators, leverage ratio and liquidity.
An ADI may make additional voluntary risk disclosure to present information relevant to their business model, to enable market participants to better understand and analyse the ADI’s risk profile and financial resilience. Such additional voluntary disclosure must meet the key principles outlined in this Prudential Standard.
If APRA is not satisfied that the adequacy or quality of an ADI’s prudential disclosures is consistent with the requirements set out in this Prudential Standard, APRA may require the ADI to rectify the disclosures or to disclose further information.
APRA may require an ADI to commission an independent audit of its prudential disclosures. This may include where APRA has reason to believe that the information being disclosed is incorrect or misleading.

Disclosure policy

An ADI must have a formal policy relating to its prudential disclosures approved by the Board. The key elements of the policy must be summarised in the ADI’s year-end public disclosure. The disclosure policy must set out:
the ADI’s approach to determining the content of its prudential disclosures; and
the ADI’s internal controls and procedures for disclosures, including the review process and verification process.
An ADI must maintain effective internal controls and procedures for public disclosures, so as to produce appropriate and accurate disclosures. The information provided by an ADI in prudential disclosures must be subject, at a minimum, to the same level of internal controls and procedures as for the ADI’s financial reporting.
In exceptional cases, disclosure of certain items of information may prejudice the position of an ADI or any other person, by making public information that is proprietary, confidential or personal in nature.[3] In such circumstances, an ADI may elect not to disclose this information and to instead disclose more general information about the subject matter of the requirement, together with commentary as to why the specific items of information have not been disclosed.

Verification of disclosures

An ADI must ensure that prudential disclosures are appropriately verified and must take steps necessary to ensure their reliability.
An ADI must ensure that its prudential disclosures are consistent with information that has been subject to review by an external auditor, is lodged or published elsewhere or has been already supplied to APRA.
An ADI must attest in writing that prudential disclosures have been prepared in accordance with the ADI’s disclosure policy. This attestation must be made by an Accountable Person of the ADI, and included in the disclosure.[4]

Frequency and timing of disclosures

An ADI must publish their disclosures as indicated in the relevant BCBS disclosure templates and tables. These vary between quarterly, semi-annual and annual depending on the specific disclosure requirement.
The prudential disclosures must be published concurrently with the lodgement of the ADI’s financial reports under the Corporations Act. If a disclosure is required to be published for a period when an ADI does not produce any financial report, the disclosure requirements must be published as soon as practicable.
Unless otherwise required by APRA, an ADI must complete and disclose the relevant disclosure templates in the BCBS Standard as it exists from time to time by the applicable implementation dates for each template as specified in the BCBS Standard.

Presentation of disclosures

An ADI must include a ‘Regulatory Disclosures’ section on its website that is easily identifiable to users. An ADI must publish all required prudential disclosures under this Prudential Standard in a standalone document in the Regulatory Disclosures section on the ADI’s website.
In addition, an ADI must also disclose all quantitative information in a Comma-separated values (CSV) file, Microsoft Excel file, or other format approved by APRA, to facilitate use of the data. This file must also be made available on an ADI’s ‘Regulatory Disclosures’ section on its website.
An ADI must make available an archive of prudential disclosures relating to prior reporting periods for at least the past 12 months period prior to the most recent publication. This archive must be included in the ‘Regulatory Disclosures’ section on the ADI’s website.
An ADI must include information on the composition of regulatory capital, main features of regulatory capital instruments, leverage ratio, liquidity, and links between financial statements and regulatory exposures, as required under the BCBS Standard, in:
an ADI’s financial report; or
an ADI’s directors’ report; or
other information accompanying an ADI’s financial report; or
the Regulatory Disclosures section on the ADI’s website, provided that the financial report, directors’ report or other information accompanying the financial report includes a link to these completed disclosures.
An ADI must present their disclosure requirements in the prescribed form; either template or table. Templates must be completed with quantitative data in accordance with the definitions provided. Tables generally relate to qualitative requirements, but quantitative information is also required in some instances. An ADI may choose the format they prefer when presenting the information requested in tables.
Information provided in templates and tables must be meaningful to users. Disclosure requirements in the BCBS Standard that necessitate an assessment from an ADI are specifically identified. When preparing these individual tables and templates, an ADI must consider how widely the disclosure requirement applies. If an ADI considers that the information requested in a template or table would not be meaningful to users, for example because the exposures and risk-weighted asset (RWA) amounts are immaterial, it may choose not to disclose part or all of the information requested. In such circumstances, however, the ADI must explain in a narrative commentary why it considers such information not to be meaningful to users. It must also describe the portfolios excluded from the disclosure requirement and the aggregate total RWA those portfolios represent.
For templates, the format is designed as either:
fixed – where the format of a template is described as fixed, an ADI must complete the fields in accordance with the instructions given. If a row or column is not considered to be relevant to an ADI’s activities or the required information would not be meaningful to users, the ADI may delete the specific row or column from the template, but the numbering of the subsequent rows and columns must not be altered. An ADI may add extra rows and extra columns to fixed format templates if it wishes to provide additional detail to a disclosure requirement by adding sub-rows or columns, but the numbering of the prescribed rows and columns in the template must not be altered; or
flexible – where the format of a template is described as flexible, an ADI may present the required information either in the format provided or in one that better suits the ADI. The format for the presentation of qualitative information in tables is not prescribed. However, if presentation restrictions are prescribed in a template, an ADI must comply with these restrictions. In addition, when a customised presentation of the information is used, an ADI must provide information comparable with that required in the disclosure requirement (at a similar level of granularity as if the template or table were completed as presented).
An ADI must supplement the quantitative information provided in both fixed and flexible templates with a narrative commentary to explain at least any significant changes between reporting periods and any other issues that the ADI considers to be of interest to market participants. The form taken by this additional narrative is at the ADI’s discretion.

Attachment A – Modifications to disclosure requirements in the BCBS Standard

General modifications

An ADI must convert all references in the BCBS Standard to Euros to Australian dollars by multiplying by a factor of 1.5.
An ADI should only complete templates and tables that are mandatory for global systemically important banks (G-SIBs) or that are voluntary to complete if required by APRA.
‘Multilateral development banks’ include entities listed in paragraph 3(c) in Attachment B of Prudential Standard APS 112 Capital Adequacy: Standardised Approach to Credit Risk (APS 112) instead of the definition provided under the BCBS Standard.
Where the BCBS Standard refers to threshold deductions for items of disclosure, an ADI is required to disclose such items as full deductions in line with the requirements of Prudential Standard APS 111 Capital Adequacy: Measurement of Capital (APS 111). The full amount of the deductions must be disclosed as ‘national specific regulatory adjustments’.
When disclosing credit risk exposures, an ADI must also disclose the credit exposures of its overseas banking subsidiary that is prudentially regulated by a prescribed New Zealand authority as a separate asset class.[5]

Capital adequacy and RWA

Where an ADI is required to disclose their RWA per risk type under the BCBS Standard, an ADI must also disclose its IRRBB RWA as a separate line item.
An ADI is not required to disclose metrics relating to prudential valuation adjustments.
An ADI is not required to disclose metrics relating to the expected credit loss (ECL) transitional arrangements.
An ADI is not required to complete disclosure requirements relating to:
equity positions under the simple risk weight approach and the international model method during the five-year linear phase-in period;
equity investments in funds – look-through approach;
equity investments in funds – mandate-based approach; and
equity investments in funds – fall-back approach.

Equity positions and equity investments in funds must be disclosed as ‘national specific regulatory adjustments’.

An ADI is not required to make disclosures relating to the securitisation internal ratings-based (IRB) approach.
An ADI is not required to disclose the capital charge for switching between the trading book and banking book when disclosing its overview of RWA under the BCBS Standard.
When making market risk disclosures as part of an ADI’s overview of RWA under the BCBS Standard, an ADI must disclose all components of its Traded Market Risk RWA (e.g. General Market Risk and Specific Market Risk), categorised under either the Standardised Approach or the Internal Model Approach.

Comparison of modelled and standardised RWA

When making disclosures relating to RWA calculated under the IRB and Standardised approaches, an ADI must use the relevant exposure classes set out in Reporting Standard ARS 112.0 Capital Adequacy: Standardised Approach to Credit Risk and the relevant asset classes set out in Prudential Standard APS 113 Capital Adequacy: Internal Ratings-based Approach to Credit Risk (APS 113). Where exposures are immaterial under an exposure class or asset class, an ADI may remove or consolidate asset classes in an approach consistent with paragraphs 20 and 39 of this Prudential Standard.

Remuneration

An ADI is not required to make remuneration disclosures under the BCBS Standard. An ADI must instead meet the remuneration disclosures as set out in Prudential Standard CPS 511 Remuneration.

Credit risk

An ADI must use the default rate consistent with that used to estimate probability of default under APS 113, rather than as defined under the BCBS Standard.
A reference to ‘specific provisions’ in the BCBS Standard means ‘provisions held against non-performing exposures, or performing exposures that represent identified losses’.
A reference to ‘general provisions’ in the BCBS Standard means ‘provisions held against performing exposures that represent a purely forward-looking amount for future losses that are presently unidentified’.
Provisions under the ECL accounting method referred to in the BCBS Standard must receive the following treatment for disclosures purposes:
12-month ECL Stage 1 provisions would be treated as general provisions;
ECL Stage 2 provisions would be treated as specific provisions where these provisions do not represent a purely forward-looking amount for future losses that are presently unidentified. If some Stage 2 loans do represent a purely forward-looking amount for future losses that are presently unidentified, they would be treated as general provisions; and
ECL Stage 3 provisions would be treated as specific provisions.
When completing templates and tables relating to credit risk, an ADI must use equivalent terminology relevant to other Prudential Standards, including:
‘non-performing exposures’ as defined in Prudential Standard APS 220 Credit Risk Management (APS 220) rather than ‘defaulted exposures’; and
‘restructured exposures’ as defined in APS 220 rather than ‘forborne exposures’.
An ADI must use the relevant asset class categories and definitions set out in APS 112 and APS 113 when disclosing credit RWA for each asset class. This includes not making disclosures for the asset class ‘high-volatility commercial real estate lending’.
An ADI must convert all references to ‘obligors’ in the BCBS Standard to ‘borrower’ or ‘counterparty’. A group of connected obligors would mean a group of connected counterparties that is connected by control or single-risk relationships. Where an ADI assesses that a borrower may form part of more than one group of connected borrowers, the ADI may primarily assign the borrower based on a control relationship rather than a single-risk relationship.
An ADI must publicly disclose information on losses in income-producing real estate as required under paragraph 6(d) of Attachment E to APS 113 as part of their public disclosures required under this Prudential Standard. This information must be disclosed on an annual basis.
An ADI must include its off-balance sheet exposures in its disclosure of changes in stock of defaulted loans and debt securities.

Counterparty credit risk

An ADI is not required to make counterparty credit risk disclosures relating to the Internal Model Method or value-at-risk for securities financing transactions.
When disclosing derivative exposures under the BCBS Standard, an ADI must disclose their derivative exposures under the APRA and Reserve Bank of New Zealand (RBNZ) methodologies separately.

Securitisation

A reference to ‘originator’ or ‘sponsor’ means an ‘originating ADI’ as defined in paragraph 12(o) of Prudential Standard APS 120 Securitisation (APS 120).
An ADI is not required to complete disclosure requirements related to the BCBS’s internal assessment approach, the ‘simple, transparent and comparable’ framework or the IRB securitisation framework.
An ADI is not required to complete securitisation disclosures relating to mixed asset pools. Where the underlying collateral is mixed, the securitisation exposure should be disclosed as a line item either under ‘retail’ or wholesale’.
An ADI must treat references to 1250 per cent risk weights as deductions from Common Equity Tier 1 Capital (CET1).
An ADI must treat references to the Standardised Approach (SEC-SA) as the Supervisory Formula Approach as set out in Attachment C to APS 120.
Securitisation exposures of an ADI’s overseas banking subsidiary that is prudentially regulated by a prescribed New Zealand authority must be disclosed as part of their New Zealand credit RWA.

Market risk

An ADI is not required to comply with the market risk disclosures requirements set out in the BCBS Standard. An ADI must instead disclose the items set out in Table 1 and Table 2 to the extent applicable on a semi-annual basis.

Table 1: Market risk – disclosures for ADIs using the standard method

Qualitative disclosures	(a)	An ADI must describe its market risk management objectives and policies, including:<br>• strategies and processes;<br>• the structure and organisation of the relevant risk management function;<br>• the scope and nature of risk reporting and/or measurement systems;<br>• policies for hedging and/or mitigating risk and strategies and processes for monitoring the continuing effectiveness of hedges/mitigants; and<br>• portfolios covered by the standard method.
Quantitative disclosures	(b)	The capital requirements (in terms of risk-weighted assets) for:<br>• interest rate risk;<br>• equity position risk;<br>• foreign exchange risk; and<br>• commodity risk.

Table 2: Market risk – disclosures for ADIs using the internal models approach (IMA) for trading portfolios

Qualitative disclosures (a) An ADI must describe its market risk management objectives and policies, including:• strategies and processes;• the structure and organisation of the relevant risk management function;• the scope and nature of risk reporting and/or measurement systems;• policies for hedging and/or mitigating risk and strategies and processes for monitoring the continuing effectiveness of hedges/mitigants; and• portfolios covered by the IMA.In addition, a discussion of the extent of, and methodologies for, compliance with the prudential requirements for prudent valuation practices for positions held in the trading book contained in Attachment A of APS 111.
(b) The discussion must include an articulation of the soundness standards on which the ADI’s internal capital adequacy assessment is based. It must also include a description of the methodologies used to achieve a capital adequacy assessment that is consistent with the soundness standards.
(c) For each portfolio covered by the IMA:• the characteristics of the models used;• a description of stress testing applied to the portfolio; and• a description of the approach used for back-testing/validating the accuracy and consistency of the internal models and modelling processes.
(d) The scope of acceptance by APRA.
(e) For the incremental risk capital charge and the comprehensive risk capital charge the methodologies used and the risks measured through the use of internal models. The qualitative description must include:• the approach used by the ADI to determine liquidity horizons;• the methodologies used to achieve a capital assessment that is consistent with the required soundness standard; and• the approaches used in the validation of the models.
Quantitative disclosures (f) For trading portfolios under the IMA:• the high, mean and low value-at-risk (VaR) values over the reporting period and period end; • the high, mean and low stressed VaR values over the reporting period and period-end;• the high, mean and low incremental and comprehensive risk capital charges over the reporting period and period-end; and• a comparison of VaR estimates with actual gains/losses experienced by the ADI, with analysis of important ‘outliers’ identified in back-test results.

Credit valuation adjustment risk

An ADI must only complete the credit valuation adjustment (CVA) risk qualitative disclosure requirements set out in the BCBS Standard, and disclose its total CVA risk capital charge at quarter end.

Operational risk

An ADI must also disclose any additional capital requirements imposed by APRA under Prudential Standard APS 115 Capital Adequacy: Standardised Measurement Approach to Operational Risk when making disclosures relating to operational risk regulatory capital requirements. This must involve including an additional line-item titled ‘Other regulatory capital charges’ as part of an ADI’s minimum required operational risk capital disclosure template.

Interest rate risk in the banking book

An ADI must convert all references to ‘non-maturity deposits’ in the BCBS Standard to ‘core deposits’ within the meaning of Prudential Standard APS 117 Interest Rate Risk in the Banking Book.

Macroprudential supervisory measures

An ADI that is required by APRA to disclose templates relating to G-SIB indicators must do so annually using the ADI’s financial year-end data.[6]

Leverage ratio

An ADI is not required to disclose its leverage ratio buffers, unless specifically required by APRA.
A reference to the ‘Basel III leverage ratio’ in the BCBS standard means the leverage ratio as defined and calculated in Prudential Standard APS 110 Capital Adequacy (APS 110).
An ADI must disclose the amounts of adjusted gross securities financing transaction assets based on an average of daily values over the disclosure period. The average of daily values may be calculated as a best estimate, provided that this is undertaken on a consistent and prudent basis, with appropriate supporting governance and procedures.
An ADI is not required to disclose the BCBS template relating to the summary comparison of accounting assets vs leverage ratio exposure measure on a quarterly basis. An ADI is required to disclose this template on a semi-annual basis.

Liquidity

Under the Liquidity disclosure requirements, an ADI is required to disclose its total High Quality Liquid Assets and Alternative Liquid Assets. As part of this disclosure, an ADI must also disclose its total liquid assets that are RBNZ eligible securities, which are securities that the RBNZ will accept in its domestic market operations.
An ADI is not required to disclose its performing loans and securities with a risk weight of less than or equal to 35 per cent under the Basel II standardised approach for credit risk as part of their Net Stable Funding Ratio disclosure requirements as stated by the BCBS Standard. Instead, an ADI must disclose its standard residential property loans, as that term is defined in APS 112, to individuals with a loan-to-value ratio of 80 per cent or below, excluding encumbered loans and loans with a maturity less than one year.
When making disclosures relating to ‘small business customers’ under the BCBS Standard, an ADI should use the definition of ‘SME customer’ in Prudential Standard APS 210 Liquidity (APS 210).
ADIs that are Significant Financial Institutions that use the minimum liquidity holdings approach under APS 210 are not required to make disclosures relating to the liquidity coverage ratio or the net stable funding ratio under the BCBS Standard.

[1] Refer to subsection 11AF(2) of the Banking Act.

[2] https://www.bis.org/basel_framework/standard/DIS.htm.

[3] Proprietary information encompasses information that, if shared with competitors, would render an ADI’s investment in its products/systems less valuable by undermining its competitive position. Confidential information is that which an ADI possesses about customers or other persons that is confidential, being provided under the terms of a legal agreement or counterparty relationship. Personal information is as defined in the Privacy Act 1988.

[4] Accountable Person has the meaning given in subsection 37BA of the Banking Act.

[5] prescribed New Zealand authority has the meaning given in subsection 5(1) of the Banking Act.

[6] An ADI whose financial year ends on 30 June must make the disclosures using 31 December data (i.e. based on interim rather than financial year-end data).

meta-content-style-type: text/css meta-content-type: application/xhtml+xml; charset=utf-8 meta-keywords: "[SEC=OFFICIAL]"

Banking (prudential standard) determination No. 3 of 2024

Prudential Standard APS 330 Public Disclosure

Banking Act 1959

I, Clare Gibney, a delegate of APRA:

This instrument commences on 1 January 2025.

Dated: 27 August 2024

Clare Gibney

Executive Director

Policy & Advice Division

Interpretation

In this instrument:

APRA means the Australian Prudential Regulation Authority.

ADI, authorised NOHC and prudential standard have their respective meanings given in subsection 5(1) of the Act.

Schedule

Prudential Standard APS 330 Public Disclosure comprises the document commencing on the following page.

Prudential Standard APS 330

Public Disclosure

The Standard rests on a handful of organising concepts that determine what ADIs must disclose and how they must manage disclosure processes.

Borrowed content plus national modification. The BCBS Standard is incorporated as the primary content source (General requirements, para 1). Attachment A sets out targeted modifications to adapt BCBS templates and definitions to APRA/Australian supervisory practice (Attachment A, General modifications and subsequent headings). The standard therefore creates a hybrid framework: BCBS templates supply detail, APRA’s Attachment A imposes Australian rule variations.
Materiality, clarity and comparability. The Standard sets five key disclosure principles: clarity, comprehensiveness, meaningfulness, consistency over time, and comparability across ADIs (Key principles and its subsections). These principles shape both the substance of disclosures and presentation choices, for example by requiring important messages to be highlighted and related risk information presented together (Disclosures must be clear, para 1).
Governance and accountability. The Standard requires a Board‑approved disclosure policy, internal controls aligned at least to the level of financial reporting controls, and an attestation by an Accountable Person that disclosures were prepared in accordance with the policy (Disclosure policy, paras 1-3; Verification of disclosures, para 3). APRA can require an independent audit of disclosures where it believes information is incorrect or misleading (General requirements, para 6).
Template discipline and permitted tailoring. Templates in the BCBS Standard are designated as fixed or flexible; ADIs must complete fixed templates per instructions but may delete non‑relevant rows/columns without altering prescribed numbering, and may customise flexible templates provided comparability is retained (Presentation of disclosures, para 7). ADIs may make minor modifications where BCBS wording conflicts with Australian Prudential Standards, but must notify APRA in advance and explain modifications in commentary (General requirements, para 2).
Data and machine‑readable publication. The Standard mandates the provision of all quantitative disclosures in CSV, Excel or APRA‑approved format to facilitate reuse, and requires a dedicated “Regulatory Disclosures” website section with archival access for at least the prior 12 months (Presentation of disclosures, paras 1-3).
Limited exceptions for confidentiality. The Standard recognises narrow circumstances where disclosure of proprietary, confidential or personal information may prejudice an ADI, permitting an ADI to omit such items and instead provide more general information and an explanation for nondisclosure (Disclosure policy, para 3; footnote [3]).
APRA discretion and supervisory remedies. APRA may adjust or exclude specific requirements in relation to one or more ADIs or authorised NOHCs (Adjustments and exclusions, para 1; footnote [1]), and may require rectification, further information or an independent audit if not satisfied with adequacy or quality (General requirements, paras 5-6).
Australian reporting and terminology alignments. Attachment A contains a series of definitional and reporting adjustments (for example, mapping ‘obligor’ to ‘borrower/counterparty’, converting Euro references to Australian dollars by multiplying by 1.5, disclosing IRRBB RWA as a separate line item, and treating certain BCBS templates as not required) that change the substance of BCBS disclosures in material ways for Australian ADIs (Attachment A, multiple paragraphs).

These concepts combine to make disclosure both a data and governance exercise. The Standard prescribes what to disclose (BCBS content as modified), how to present it (web section, CSV/Excel, templates and narrative), who must own it internally (Board and Accountable Person) and how APRA will supervise its adequacy (rectification, independent audit, adjustments/exclusions).

The text sets out a narrow, specified universe of affected entities. The Standard applies to all authorised deposit‑taking institutions (ADIs) except foreign ADIs, non‑significant financial institutions (non‑SFIs) and purchased payment facility providers (Application, para 1). The Objectives language clarifies that the Standard is intended to apply to “ADIs that are locally‑incorporated significant financial institutions.” APRA retains power to determine that the Standard applies in a particular case to a foreign ADI or a non‑SFI (Application, para 1).

Application is expressed on levels:

A reference to an ADI, unless otherwise indicated, refers to an ADI on a Level 1 basis and to a group of which an ADI is a member on a Level 2 basis (Application, para 1.1).
If an ADI is a member of a group on a Level 2 basis, the ADI need not comply on a Level 1 basis unless APRA determines otherwise; conversely, a holding company must ensure Level 2 compliance where applicable, and an authorised non‑operating holding company (authorised NOHC) must ensure the requirements are met on a Level 2 basis where applicable (Application, paras 1.2-1.2.2).

Who pays. The compliance costs and publication burden fall primarily on those ADIs captured by the Standard: locally‑incorporated significant ADIs and Level 2 groups where applicable. An authorised NOHC is explicitly required to ensure Level 2 compliance for its subsidiaries (Application, para 1.2.2.2).

Who decides. APRA is the decision‑maker for supervisory judgments and discretionary relief. APRA may (in writing) adjust or exclude specific prudential requirements for one or more ADIs or authorised NOHCs (Adjustments and exclusions, para 1; footnote [1]). APRA must be notified where ADIs intend to make alterations to BCBS templates inconsistent with Prudential Standards; APRA may require rectification, further information, or an independent audit (General requirements, paras 2, 5-6). APRA will exercise any power or discretion in writing (Interpretation, para 2).

Intermediary actors. External auditors are implicated: disclosures must be consistent with information subject to external auditor review and ADIs must attest that disclosures accord with their disclosure policy (Verification of disclosures, paras 2-3). Where APRA has reason to believe disclosures are incorrect or misleading, APRA may mandate an independent audit (General requirements, para 6), which imposes additional costs on the ADI.

Geographical scope and cross‑border items. The Standard explicitly requires disclosure of credit exposures of an ADI’s overseas banking subsidiary prudentially regulated by a prescribed New Zealand authority as a separate asset class (Attachment A, para 3). It also requires disclosure of overseas securitisation exposures of such New Zealand subsidiaries as part of New Zealand credit RWA (Attachment A, securitisation para 6). The Reserve Bank of New Zealand methodologies are used separately for derivative exposures (Attachment A, Counterparty credit risk para 2).

In short, the Standard targets Australian significant ADIs and their Level 2 groups; APRA is the supervisor with written discretion to extend, modify or exclude specific requirements; external auditors and Board/Accountable Persons are engaged in verification and attestation; and certain overseas subsidiaries (notably New Zealand prudentially regulated subsidiaries) are required to be disclosed discretely.

Duties

Adoption of BCBS templates (subject to Attachment A). An ADI must make the prudential disclosures set out in the BCBS Standard as it exists from time to time, with the Australian modifications in Attachment A (General requirements, para 1; Attachment A).
Board‑approved disclosure policy. An ADI must have a formal disclosure policy approved by its Board. The policy must set out the ADI’s approach to determining disclosure content and the internal controls and procedures for disclosures, including review and verification processes (Disclosure policy, para 1).
Internal controls parity with financial reporting. Disclosures must be subject at minimum to the same level of internal controls and procedures as the ADI’s financial reporting (Disclosure policy, para 2).
Attestation by an Accountable Person. An Accountable Person must attest in writing that prudential disclosures were prepared in accordance with the ADI’s disclosure policy; that attestation must be included in the disclosure document (Verification of disclosures, para 3; footnote [4]).
Publication, timing and format obligations. An ADI must: publish disclosures as indicated by the BCBS templates (which may be quarterly, semi‑annual or annual); publish concurrently with lodgement of financial reports under the Corporations Act; include a “Regulatory Disclosures” section on its website with all required disclosures in a standalone document; and provide quantitative data in CSV, Excel or APRA‑approved format (Frequency and timing of disclosures, paras 1-2; Presentation of disclosures, paras 1-3).
Narrative commentary and comparability. Templates must be supplemented with narrative commentary explaining significant changes between reporting periods and other issues of market interest. If an ADI omits information because it is immaterial, it must explain why and describe excluded portfolios and aggregate RWA for those portfolios (Presentation of disclosures, paras 6, 8).
Verification and consistency. Disclosures must be appropriately verified and consistent with auditor‑reviewed information, previously lodged material or material supplied to APRA (Verification of disclosures, paras 1-2).
Specific reporting items. Attachment A prescribes particular disclosure items to be included or excluded, e.g. separate IRRBB RWA line item, separate disclosure of New Zealand subsidiary credit exposures, disclosure of total RBNZ eligible securities as part of High Quality Liquid Assets, treatment of equity positions as national specific regulatory adjustments, and several other mapping rules (Attachment A, multiple paras).

Rights and supervisory discretion

Exception for confidential/proprietary/personal information. An ADI may elect not to disclose certain items where disclosure would prejudice the ADI or another person by revealing proprietary, confidential or personal information. In such cases, the ADI must disclose more general information and explain why specific items were not disclosed (Disclosure policy, para 3; footnote [3]).
APRA discretion to adjust or exclude requirements. APRA may adjust or exclude specific prudential requirements in relation to particular ADIs or authorised NOHCs (Adjustments and exclusions, para 1; footnote [1]).
APRA’s supervisory remedies. APRA may require an ADI to rectify disclosures or disclose further information where adequacy or quality is unsatisfactory, and may require an independent audit of disclosures where it has reason to believe the information is incorrect or misleading (General requirements, paras 5-6).

Procedural duties

Prior notification to APRA is required for any minor modifications to BCBS templates where there are inconsistencies with Prudential Standards; ADIs must notify APRA before making the modified disclosures (General requirements, para 2).
ADIs must contact APRA if they intend to rely on a previous exemption or exercise of discretion by APRA under the prior version (Previous exercise of discretion, para 1).

Sanctions and formal enforcement mechanisms are not expressly set out in this Prudential Standard text beyond APRA’s powers to require rectification, disclosure of further information, and independent audit. The instrument also confirms that APRA will exercise powers and discretions in writing (Interpretation, para 2), which creates a traceable supervisory record of decisions and directions.

The Prudential Standard sets out supervisory powers and enforcement-related procedural obligations rather than prescriptive monetary or criminal penalties within the text itself. The document specifies APRA’s regulatory levers in respect of prudential disclosure enforcement as follows:

Rectification and further disclosure. If APRA is not satisfied that the adequacy or quality of an ADI’s prudential disclosures is consistent with this Standard, APRA may require the ADI to rectify the disclosures or to disclose further information (General requirements, para 5). This is a form of corrective supervisory direction.
Independent audit requirement. APRA may require an ADI to commission an independent audit of its prudential disclosures. The Standard explicitly contemplates using this measure where APRA has reason to believe that the information being disclosed is incorrect or misleading (General requirements, para 6).
Discretionary adjustments and exclusions. APRA may adjust or exclude specific prudential requirements in relation to one or more ADIs or authorised NOHCs under the statutory power referenced in subsection 11AF(2) of the Banking Act (Adjustments and exclusions, para 1; footnote [1]). Those adjustments or exclusions are supervisory tools that change compliance obligations for particular ADIs.
Formality of APRA decisions. The Standard mandates that where APRA is to exercise a power or discretion it will do so in writing (Interpretation, para 2). That procedural requirement supports enforceability and transparency of supervisory actions.
Notification and prior consultation obligations. ADIs must notify APRA in advance of any minor modifications to BCBS template content where inconsistencies exist with Prudential Standards (General requirements, para 2). ADIs also must contact APRA if they intend to rely on a previous exercise of discretion by APRA under the prior Standard (Previous exercise of discretion, para 1). Failure to observe these obligations can trigger supervisory follow‑up.

What the Standard does not itself specify. The instrument does not set out explicit civil or criminal penalties within its text. It does not identify administrative pecuniary penalties, licence revocations or criminal sanctions specific to breaches of APS 330; those consequential enforcement powers, if available, sit in the Banking Act and general APRA enforcement framework rather than in this text. The Standard does, however, create enforceable duties by specifying compliance obligations and by providing APRA with corrective powers including written directions to rectify and to obtain an independent audit. Entities should therefore understand the Standard as enabling supervisory enforcement mechanisms rather than specifying the full suite of statutory penalties that APRA may have under the Banking Act.

Finally, APRA’s ability to adjust or exclude requirements (Adjustments and exclusions, para 1) creates a mechanism to tailor enforcement expectations to particular institutions, which is itself an enforcement and supervisory instrument because it determines the applicable obligations case by case.

The Prudential Standard expressly cross‑references and aligns with a number of other statutory instruments and prudential standards. These interactions determine definitions, reporting categories, and timing obligations.

Primary statutory authority. APS 330 is made under section 11AF of the Banking Act 1959 (Authority). Footnote [1] explicitly refers to subsection 11AF(2) as the statutory basis for APRA’s ability to adjust or exclude specific prudential requirements (Adjustments and exclusions, para 1; footnote [1]).

Definitions and defined terms. The Standard uses defined terms from Prudential Standard CPS 001 Defined terms; those terms appear in bold on first use as required (Interpretation, para 1). The Accountable Person attestation requirement invokes the definition of Accountable Person in subsection 37BA of the Banking Act (Verification of disclosures, para 3; footnote [4]).

Corporations Act reporting link. The Standard requires publication of prudential disclosures concurrently with lodgement of the ADI’s financial reports under the Corporations Act (Frequency and timing of disclosures, para 2). This ties timing and potential content reconciliation obligations to Corporations Act financial statements and their audit and lodgement regimes.

Interaction with other APRA prudential standards. Attachment A contains numerous direct references to other APS instruments that determine how BCBS content must be adapted:

APS 111 Capital Adequacy: Measurement of Capital is referenced for national specific regulatory adjustments and for treatment of certain deductions (Attachment A, para 2).
APS 112 Capital Adequacy: Standardised Approach to Credit Risk and APS 113 Internal Ratings-based Approach to Credit Risk are referenced for exposure class definitions and RWA calculations and to require ADIs to use those classes when disclosing RWA (Attachment A, several paras, including Capital adequacy and RWA; Comparison of modelled and standardised RWA; Credit risk).
APS 120 Securitisation supplies definitions for ‘originating ADI’ and the Supervisory Formula Approach (Attachment A, Securitisation paras 1, 5).
APS 115 Capital Adequacy: Standardised Measurement Approach to Operational Risk is referenced to require disclosure of any additional operational risk capital charges imposed by APRA as an “Other regulatory capital charges” line item (Attachment A, Operational risk para 1).
APS 117 Interest Rate Risk in the Banking Book is used to map BCBS references to non‑maturity deposits into “core deposits” (Attachment A, Interest rate risk para 1).
APS 210 Liquidity is referenced for the definition of SME customer and for exemptions relating to ADIs that use the minimum liquidity holdings approach (Attachment A, Liquidity paras 3-4).
APS 110 Capital Adequacy is referenced for the meaning of the Basel III leverage ratio (Attachment A, Leverage ratio para 2).
CPS 511 Remuneration is expressly referred to as the relevant standard for remuneration disclosures; ADIs are not required to use the BCBS remuneration template (Attachment A, Remuneration para 1).

Other statutory instruments and external regulators. The Standard references the Privacy Act 1988 in relation to the definition of personal information in its confidentiality exception (footnote [3]). It also requires separate disclosure of derivative exposures under APRA and Reserve Bank of New Zealand (RBNZ) methodologies (Attachment A, Counterparty credit risk para 2), and requires separate treatment of exposures of overseas banking subsidiaries prudentially regulated by a prescribed New Zealand authority as a separate asset class (Attachment A, Credit risk para 3; securitisation para 6; footnote [5]).

External standards and evolving content. The BCBS Standard incorporated by reference is hosted on the BIS website and is explicitly incorporated “as it exists from time to time” (General requirements, para 1; footnote [2]). This creates a dynamic interaction whereby changes to BCBS disclosure requirements can alter an ADI’s obligations without a separate domestic legislative amendment, subject to the Attachment A modifications and APRA’s adjustment powers.

Operational interplay. The requirement that disclosures be consistent with auditor‑reviewed information (Verification of disclosures, para 2) and that quantitative items be available in machine‑readable format creates a practical interface with financial reporting, audit processes, data governance regimes and Corporations Act obligations.

In summary, APS 330 is not a freestanding code; it is designed to operate within APRA’s broader prudential architecture and Corporations Act reporting regime, to reference particular APS instruments for definitions and treatment of specific items, and to incorporate BCBS templates with local alterations. This network of references channels content, timing and verification obligations across a set of Australian and international regulatory instruments.

The instrument itself contains a succinct amendment record: it revokes Banking (prudential standard) determination No. 1 of 2023 and the Prudential Standard APS 330 made under that determination (instrument header). The new Standard is dated 27 August 2024 and commences 1 January 2025 (instrument header; Application, para 3).

Beyond that direct replacement, the Standard embeds mechanisms that yield a living‑document behaviour:

The BCBS Standard is incorporated “as it exists from time to time” (General requirements, para 1). That phrasing makes APRA’s disclosure requirements responsive to future BCBS changes absent discrete domestic amendments, although Attachment A sets out modifications that continue to apply. Practically, this means ADIs must monitor BCBS updates and apply them subject to Attachment A and any APRA‑issued directions.
APRA’s power to adjust or exclude specific prudential requirements for particular ADIs or authorised NOHCs (Adjustments and exclusions, para 1; footnote [1]) creates a statutory channel for bespoke amendments to obligations on a case‑by‑case basis, exercised in writing (Interpretation, para 2).
The Standard allows ADIs to make minor modifications to BCBS template content where inconsistencies exist with Australian Prudential Standards, but requires ADIs to notify APRA in advance and to describe and justify modifications in the disclosure (General requirements, para 2). That procedural route allows for limited operational variation without formal amendment to the Standard itself.

The document does not provide a history of prior amendments beyond revocation of the 2023 determination. The absence of an extended amendment log in the text means that for historical tracing a reader must compare this instrument against the revoked 2023 determination and any APRA communications or subsequent determinations that exercise 11AF powers. APRA’s written exercise of discretion (Interpretation, para 2) will create a record of applied amendments or exclusions for particular ADIs.

Finally, because several other APS instruments are referenced for definitional and calculation rules (APS 110, 111, 112, 113, 115, 117, 120, 210, CPS 001 and CPS 511), amendments to those standards will cascade into reporting and disclosure practice. The Standard’s reliance on external materials (BCBS content and other APRA standards) therefore creates an architecture in which change can occur through:

changes to BCBS requirements that are incorporated by reference;
amendments to referenced APS/CPS instruments; and
APRA’s case‑by‑case adjustments or exclusions exercised in writing under s11AF(2) of the Banking Act.

If analytic or compliance work requires tracking changes over time, practitioners should monitor BCBS releases, APRA’s prudential standard updates, and APRA written decisions under the adjustment/exclusion power.

The text of Prudential Standard APS 330 contains no references to litigation, judicial decisions, or case law (the instrument revokes the 2023 determination but does not cite any judicial determinations). There is no litigation history recorded within this instrument itself.

What the absence of litigation references in the instrument signifies practically is limited: the Standard is a forward‑looking regulatory instrument setting disclosure obligations and supervisory powers. Potential disputes arising from APRA’s exercise of its powers (for example, an APRA requirement to rectify disclosures, an APRA demand for an independent audit, or an APRA‑granted exclusion or adjustment) would be administrative decisions made under the Banking Act and the Standard’s procedural rules (Adjustments and exclusions, para 1; General requirements, paras 5-6; Interpretation, para 2). The instrument does not map out appeal routes or judicial review processes; such remedies, if pursued, would engage the administrative law framework applicable to APRA decisions and the Banking Act more broadly, but the Standard does not articulate those pathways.

For practitioners advising ADIs, the immediate practical consequence is that supervision and enforcement will be effected primarily through APRA’s written exercises of discretion and supervisory directions made under the standard and the Banking Act. Any litigation or judicial review that may arise in future will depend on the specific facts of an APRA action and would need to be identified from case law and tribunal records external to this instrument.

Because the instrument replaces a 2023 determination, a history of disputes arising under the earlier standard (if any) would not be recorded here; practitioners seeking precedent or litigation history should search for administrative or judicial decisions referencing APRA’s prior APS 330 obligations, or for cases involving APRA’s use of section 11AF powers, outside this document.

This Standard embeds a number of specific requirements and drafting choices that create practical pitfalls for ADIs and authorised NOHCs. The following items are concrete, source‑grounded issues that are easily overlooked:

Dynamic incorporation of BCBS content. The BCBS Standard is incorporated “as it exists from time to time” (General requirements, para 1). ADIs must monitor BCBS updates because those updates can change disclosure templates and frequencies absent a separate domestic amendment. Attachment A modifies BCBS content for Australia, but that does not remove the need to track BCBS changes.
Euro to AUD conversion by fixed factor. Attachment A requires conversion of all BCBS references to Euros into Australian dollars by multiplying by a factor of 1.5 (Attachment A, General modifications para 1). This is a prescriptive, non‑market exchange rate and will affect threshold calculations and template values; ADIs must implement this conversion consistently.
Template numbering discipline. For fixed templates, ADIs may delete irrelevant rows or columns but must not alter numbering of subsequent rows and columns; extra rows/columns may be added only as sub‑rows/columns without renumbering prescribed fields (Presentation of disclosures, para 7.1). Failure to preserve numbering can make disclosures non‑compliant with BCBS template expectations and APRA guidance.
Limited archive requirement. The Standard requires an archive only for the prior 12‑month period prior to the most recent publication (Presentation of disclosures, para 3). If an ADI assumes a longer archival duty as best practice, the Standard does not compel it; conversely, ADIs must ensure at least the 12‑month archive is readily accessible.
Attestation by Accountable Person. The requirement that an Accountable Person attest in writing that disclosures have been prepared in accordance with the ADI’s disclosure policy is specific and must be included in the disclosure document (Verification of disclosures, para 3; footnote [4]). This ties prudential disclosure to the Banking Act’s accountability framework and requires sign‑off procedures.
Consistency with audited information. Disclosures must be consistent with information that has been subject to review by an external auditor, lodged elsewhere, or supplied to APRA (Verification of disclosures, para 2). ADIs cannot disclose figures that are materially inconsistent with audited financial statements without reconciliation or explanation.
Notification before modification. ADIs may make minor modifications to BCBS template content where BCBS conflicts with other Prudential Standards, but must notify APRA in advance (General requirements, para 2). Retrospective notification is not sufficient.
Narrow confidentiality carve‑outs. The exception permitting nondisclosure of proprietary, confidential or personal information is conditional: an ADI must disclose more general information and explain why specific items are omitted (Disclosure policy, para 3; footnote [3]). Blanket nondisclosure is not authorised.
Differential treatment of BCBS items. Attachment A removes or changes a number of BCBS disclosure items (e.g. remuneration disclosures are not required under BCBS but must be reported under CPS 511; certain securitisation, market risk and CVA disclosures are narrowed or replaced) (Attachment A, multiple paras). ADIs relying on the BCBS language alone may miss these Australian adjustments.
New Zealand subsidiary disclosures. The Standard requires separate disclosure of credit exposures and securitisation exposures of an ADI’s overseas banking subsidiary prudentially regulated by a prescribed New Zealand authority (Attachment A, Credit risk para 3; securitisation para 6; footnote [5]). ADIs with New Zealand subsidiaries must ensure separate line items and proper mapping to domestic asset classes.
CSV/Excel and machine‑readable obligations. Quantitative data must be provided in CSV, Excel or APRA‑approved formats (Presentation of disclosures, para 2). Data governance and IT systems must be prepared to output consolidated, validated machine‑readable disclosures aligned with BCBS template structures.
Timing linked to Corporations Act lodgements. Disclosures must be published concurrently with lodgement of financial reports under the Corporations Act (Frequency and timing of disclosures, para 2). Coordination across finance, legal and compliance functions is necessary to meet simultaneous publication.
APRA’s power to require an independent audit. APRA may require an independent audit where it suspects information is incorrect or misleading (General requirements, para 6). This is a material compliance risk and cost driver.

Each of these items is explicitly provided for in the text; failing to plan for them will produce operational compliance shortfalls and may trigger supervisory follow‑up.

To operationalise APS 330, ADIs and authorised NOHCs should follow a structured compliance programme that maps the Standard’s prescriptions into governance, process, data and publication steps. The following is a checklist, grounded in the Standard’s text, for practical implementation.

Confirm scope and level of application

Determine whether the ADI is within scope: the Standard excludes foreign ADIs, non‑SFIs and purchased payment facility providers unless APRA determines otherwise (Application, para 1). If the ADI is part of a Level 2 group, determine whether compliance is required at Level 1 or Level 2; holding companies and authorised NOHCs have Level 2 obligations (Application, paras 1.1-1.2.2).

Map BCBS templates to Australian modifications

Obtain the current BCBS “Disclosure requirements” templates (General requirements, para 1; footnote [2]) and map each template against Attachment A to identify which templates or fields are modified, excluded or treated differently.
Apply the prescribed Austalian conversions and mappings (for example, multiply Euro amounts by 1.5, use APS 112/113 asset class categories, include IRRBB RWA line item, treat certain items as national specific regulatory adjustments) (Attachment A, multiple paras).

Establish Board‑approved disclosure policy and internal controls

Draft a disclosure policy for Board approval that sets out: approach to content determination, internal controls and procedures for disclosures, review and verification processes (Disclosure policy, para 1).
Ensure internal controls for disclosures match at minimum the level applied to financial reporting (Disclosure policy, para 2).
Document roles, responsibilities and escalation paths; include procedures for CSV/Excel output generation, template completion, narrative commentary drafting and sign‑offs.

Data governance and IT implementation

Build or configure systems to produce the required templates and machine‑readable outputs (CSV/Excel or APRA‑approved formats) and record the conversion factor (Attachment A, General modifications para 1; Presentation of disclosures, para 2).
Ensure reconciliations between disclosures and audited financial statements, and maintain traceability of calculations for RWA, IRRBB and other adjusted items.
Establish archive facilities to retain prior prudential disclosures for at least the previous 12 months (Presentation of disclosures, para 3).

Audit and assurance planning

Coordinate with external auditors to align reviewed figures and to ensure consistency between disclosures and audited financial statements (Verification of disclosures, para 2).
Prepare for the possibility APRA may require an independent audit (General requirements, para 6); document the process and select audit providers in advance.

Accountable Person attestation

Identify the Accountable Person under subsection 37BA of the Banking Act, and build an internal attestation process to produce the required written attestation that disclosures comply with the ADI’s disclosure policy. Include the attestation in the disclosures (Verification of disclosures, para 3; footnote [4]).

Presentation, narrative and comparability

Create a standalone “Regulatory Disclosures” web section that is easy to find and contains all required disclosures (Presentation of disclosures, para 1).
Complete fixed and flexible templates per the Standard’s rules; supplement quantitative templates with narrative commentary explaining significant movements and why any items are omitted as immaterial, including the RWA aggregate for excluded portfolios (Presentation of disclosures, paras 6-7).
If making minor modifications to BCBS templates due to inconsistencies with other Prudential Standards, prepare notified justification and seek APRA notification in advance (General requirements, para 2).

Confidentiality carve‑outs and explanations

For items that are proprietary, confidential or personal where disclosure would cause prejudice, prepare a documented decision and provide an alternative general disclosure and commentary explaining the omission (Disclosure policy, para 3; footnote [3]).

Timing and coordination with Corporations Act lodgements

Synchronise disclosure publication with the lodgement of the ADI’s financial report under the Corporations Act (Frequency and timing of disclosures, para 2). If an ADI has a period where it does not produce a financial report, publish the required disclosures as soon as practicable (Frequency and timing of disclosures, para 2).

Interaction with other prudential standards and offshore entities

Coordinate with capital and risk teams to ensure RWA, capital, securitisation and liquidity items are prepared using the APS110/111/112/113/120/210 definitions and approaches as required by Attachment A (Attachment A, multiple paras).
Ensure separate disclosure of credit exposures for overseas New Zealand prudentially regulated banking subsidiaries and disclose securitisation exposures for such subsidiaries as New Zealand credit RWA (Attachment A, Credit risk para 3; securitisation para 6; footnote [5]).

Prepare for APRA engagement

Maintain records required for potential APRA requests for rectification or independent audit (General requirements, paras 5-6).
If relying on a previous APRA exemption or discretion granted under the prior Standard, contact APRA to confirm reliance and any continued validity (Previous exercise of discretion, para 1).

Ongoing monitoring and controls testing

Test internal controls over disclosure preparation on a periodic basis, ensure the control environment is at least as strong as that for financial reporting, and update the Board on material changes to disclosure content, methodology or the APRA/BCBS landscape (Disclosure policy, para 2; Key principles).

This checklist follows the Standard’s structure and language. Implementation requires cross‑functional coordination across risk, finance, legal, compliance and IT, and will likely require re‑design of reporting templates, audit liaison and Board reporting processes to accommodate the attestation and board policy requirements.

Deep Dive

What it does

Current sections