Project governance and timeline: establish a dedicated project team responsible for SRS 332.0 and SRF 332.1 compliance, drawing members from finance, investments, legal, compliance, operations and IT. Set a project plan aligned to the first reporting cycles: prepare SRF 332.0 for the financial year ending on or after 30 June 2025 and SRF 332.1 for the 12 months ending 30 June 2025, with SRF 332.1 due by 15 December following the reporting period and SRF 332.0 tables due within three months after the end of the relevant reporting period. Build milestones for data mapping, audit engagement, digital certificate provisioning and board/senior management sign‑off.
Data mapping and master registers: create or update master registers of RSEs, PSTs, defined benefit RSEs, and service providers. For each service provider, collect and store a Service Provider Identifier (no more than 20 alphanumeric characters), Service Provider Name, ABN (11 digits), Service Provider Type, relationship classification, shareholding percentages, and Responsible Person relationship indicators and descriptive text. Ensure the Service Provider Identifier used in SRF 332.1 exactly matches the one in SRF 332.0 Table 1.
Contract and organisational mapping for look‑through: implement a process to map connected entities and ownership/control chains so that look‑through reporting can be performed. For each expense and investment management arrangement, identify whether the counterparty is a connected entity and, if so, trace the chain to the last connected entity before a non‑connected entity. Document the look‑through methodology and hold evidence (contracts, ownership records, ABNs).
Chart of accounts alignment and apportionment rules: align the fund’s chart of accounts to APRA’s expense group type and expense type taxonomy. Define apportionment rules where a single payment covers multiple expense groups or expense types, ensuring the total service arrangement cost amounts reconcile to the financial statements on an accruals basis. Record rules for capital expenditure, IT services, travel and training where these may be related to other expense types, as the instructions require specific treatment for these categories.
Investment manager data collection: for SRF 332.1, obtain fee and cost data from each investment manager, broken down into base investment fees, performance‑linked fees and transaction fees, with the market value of investments to which the fees relate, asset class sector type, listing type and domicile type. For each contract with an investment manager select one Asset Class Sector Type that best represents the contract per the instructions. Document the mapping methodology for multi‑sector mandates.
Audit engagement and assurance plan: engage the RSE auditor early to plan the limited assurance engagement required by the Standard. Ensure the auditor’s scope and testing approach is consistent with Auditing and Assurance Standards Board guidance and compatible with Prudential Standard SPS 310 to the extent not inconsistent. Provide auditors with the systems, processes and internal control documentation they will need to test, and schedule interim testing if necessary to meet timelines.
Internal controls and board authorisation: draft and adopt internal policies and procedures for preparation, review and authorisation of APRA returns that assign responsibilities, specify controls over data extraction and transformation, and require CEO or CFO authorisation for submissions. Implement a formal sign‑off workflow tied to digital certificate usage and maintain evidence of board oversight as required by the Standard.
Digital certificate and submission testing: obtain a digital certificate acceptable to APRA for the authorised submitter(s) and test electronic submission processes on APRA’s systems well ahead of deadlines. If using an agent to submit forms, ensure contracts require the agent to provide the completed form back to the licensee and to follow the licensee’s authorisation and data quality controls.
Materiality and classification policy: adopt an explicit policy for applying SPS 515 materiality indicators to individual payments and service arrangements. Standardise rules for classifying expense group type and expense type, and for when to aggregate multiple payees under the “multiple payees” allowance, ensuring the four conditions for aggregation are strictly met.
Reconciliation and validation processes: implement reconciliations between SRF 332.0 totals and the RSE financial statements, and between SRF 332.1 totals and the fees and costs disclosed to members under ASIC RG 97. Reconcile SRF 332.1 to SRS 705.0 where applicable. Build data validation checks for percentage format (unconverted decimals to two decimal places), ABN validity, service provider identifier uniqueness and uniqueness of table primary key combinations.
Contractual and data sharing reviews: review outsourcing and investment management contracts to ensure the RSE licensee has the right to obtain the data required for look‑through reporting and manager‑level fee breakdowns. Amend contracts where necessary to secure timely delivery of data, and consider adding reporting templates or SLAs to ensure consistency. For third parties reluctant to provide granular data, document the legal basis for seeking the data and prepare fallback positions and remedial contract amendments.
Record retention and agent oversight: where agents submit on behalf of the RSE licensee, ensure documented arrangements require the agent to provide and retain copies of submitted forms, and permit APRA audit access to relevant workpapers. Maintain records of each submission, the authorised signatory, and the digital certificate used.
Training and governance: train finance, investment, compliance and operations teams on the data taxonomy, look‑through rules and format requirements. Provide trustees and responsible persons with briefings on new disclosure fields, particularly those concerning related parties and responsible person relationships with service providers under SPS 521.
Prepare for APRA variations and notices: because APRA may issue written notices changing reporting frequency or grant extensions, maintain a process for monitoring APRA communications and for quickly adjusting reporting timetables. Ensure a point person is responsible for receiving APRA notices and coordinating any compliance changes.
Testing and dry runs: conduct at least one dry run of the full submission cycle with auditors and any agents before the first live reporting deadline. Use trial submissions to identify data gaps, reconciliation issues and system constraints.
Board and senior management oversight: ensure the Board and senior management review and approve high‑level reconciliation results, audit planning and the policies governing classification and materiality. Ensure that responsibility for the reliability of submitted information is formally assigned and documented.
By implementing the above steps, an RSE licensee can convert the Reporting Standard’s prescriptive fields and technical rules into operational processes, generate the required auditor assurance evidence, and meet APRA’s electronic submission, authorisation and retention requirements.