Financial Sector (Collection of Data) (reporting standard) determination No. 15 of 2022
In ForceCTH
Jurisdiction
Commonwealth
Collection
legislative instrument
Plain English Summary
5/10 complexity
This Reporting Standard requires the parent entity of a Level 2 insurance group to submit Form GRF 114.3_G disclosing off‑balance‑sheet business to APRA for each reporting period (applicable to periods ending on or after 1 July 2022), submitted electronically and subject to Group Auditor review and limited assurance. APRA says the information is for prudential supervision and capital assessment. The rule allocates reporting and assurance costs to group parents, requires Board/senior management authorisation, and gives APRA discretion to vary frequency or content.
This Reporting Standard prescribes the data collection, quality-control and submission mechanics for off-balance sheet business information from Level 2 insurance groups to the Australian Prudential Regulation Authority (APRA). Paragraph 4 requires the parent entity of a Level 2 insurance group to provide APRA with the information set out in Form GRF 114.3_G for each reporting period. The Standard is made under the authority of section 13 of the Financial Sector (Collection of Data) Act 2001 (para 1).
In practical terms the instrument does the following (text references are to the numbered paragraphs in the source):
Defines its application: it applies to the parent entity of a Level 2 insurance group as defined in Prudential Standard GPS 001 (para 3).
Requires regular reporting: the default frequency is half-yearly (unaudited) and annual (audited) reporting aligned to the group financial year (para 6). APRA may change the reporting periods for a particular group by written notice (para 7).
Specifies submission method: electronic submission via APRA’s ‘Direct to APRA’ application is mandated, or an APRA-notified alternative where that application is unavailable (para 5).
Imposes quality-control and audit expectations: data must be produced from systems, processes and controls reviewed and tested by the Group Auditor, at least annually and as part of a limited assurance engagement consistent with AUASB professional standards and GPS 310 requirements (paras 10-11, note to para 6).
Prescribes authorisation, agent and record-retention duties: digital signature by an officer or agent using an APRA-acceptable digital certificate is required (para 12); where an agent submits, the parent entity must obtain and retain a copy of the completed form (para 13); submitters must be authorised by the Principal Executive Officer or Chief Financial Officer (para 14).
Current sections
Direct links to the current provisions in Financial Sector (Collection of Data) (reporting standard) determination No. 15 of 2022.
Off-balance Sheet Business (Level 2 Insurance Group)
Objective of this Reporting Standard
This Reporting Standard sets out the requirements for the provision of information to APRA relating to a Level 2 insurance group’s off-balance sheet business.
It includes Form GRF 114.3_G Off-balance Sheet Business (G) and associated specific instructions and must be read in conjunction with the general instruction guide.
Authority
This Reporting Standard is made under section 13 of the Financial Sector (Collection of Data) Act 2001.
Purpose
Information collected in Form GRF 114.3_G Off-balance Sheet Business (G) (GRF 114.3_G) is used by APRA for the purpose of prudential supervision, including assessing compliance with the capital standards.
Application and commencement
This Reporting Standard applies to a parent entity of a Level 2 insurance group as defined in Prudential Standard GPS 001 Definitions (GPS 001). This Reporting Standard applies for reporting periods ending on or after 1 July 2022. The parent entity of a Level 2 group is required to ensure that each requirement in this Reporting Standard is complied with.
Information required
The parent entity of a Level 2 insurance group must provide APRA with the information required by Form GRF 114.3_G in respect of the Level 2 insurance group for each reporting period.
Forms and method of submission
The information required by this Reporting Standard must be given to APRA in electronic format using the ‘Direct to APRA’ application or, where ‘Direct to APRA’ is not available, by a method notified by APRA prior to submission.
Note: The ‘Direct to APRA’ application software may be obtained from APRA.
Reporting periods and due dates
Subject to paragraph 7, the parent entity of a Level 2 insurance group must provide the information required by this Reporting Standard:
(a) in respect of the first half year based on the financial year of the Level 2 insurance group on an unaudited basis; and
(b) in respect of each financial year of the Level 2 insurance group on an audited basis.
Note: The annual information required by paragraphs 4, 5 and 6(b), together with certain annual information required by other reporting standards, will form part of the Level 2 insurance group’s annual accounts within the meaning of GPS 001. Prudential Standard GPS 310 Audit and Related Matters (GPS 310) contains the relevant provisions governing audits.
If, having regard to the particular circumstances of a Level 2 insurance group, APRA considers it necessary or desirable to obtain information more or less frequently than as provided by subparagraph 6(a) or 6(b), APRA may, by notice in writing to the parent entity, change the reporting periods, or specify reporting periods, for the particular Level 2 insurance group.
The information required by this Reporting Standard in respect of a Level 2 insurance group must be provided to APRA:
(a) within the time stated in Reporting Standard GRS 001 Reporting Requirements (GRS 001); or
(b) in the case of information provided in accordance with paragraph 7, within the time specified by notice in writing.
Note: GPS 310 requires a Level 2 insurance group to ensure that its Group Auditor conducts a limited assurance review of the group’s annual accounts. Accordingly, the Group Auditor’s report(s) as required by GPS 310 (relating to the information required by paragraph 4) must be provided to APRA by the time specified in GRS 001 (unless an extension of time is granted under GRS 001).
On the written application of the parent entity of a Level 2 insurance group, APRA may by notice in writing to the parent entity exclude the requirement under subparagraph 6(a) to provide half yearly information.
Quality control
The information provided by the parent entity of a Level 2 insurance group under this Reporting Standard must be the product of systems, processes and controls that have been reviewed and tested by the Group Auditor of the Level 2 insurance group. This will require the Group Auditor to review and test the Level 2 insurance group’s systems, processes and controls designed to enable the group to report reliable financial information to APRA. This review and testing must be done on:
(a) an annual basis or more frequently if necessary to enable the Group Auditor to form an opinion on the reliability and accuracy of data; and
(b) at least a limited assurance engagement consistent with professional standards and guidance notes issued by the Auditing and Assurance Standards Board (AUASB) as may be amended from time to time, to the extent that they are not inconsistent with the requirements of GPS 310.
All information provided by the parent entity of a Level 2 insurance group under this Reporting Standard must be subject to systems, processes and controls developed by the Level 2 insurance group for the internal review and authorisation of that information. It is the responsibility of the Board and senior management of the parent entity of the Level 2 insurance group to ensure that an appropriate set of policies and procedures for the authorisation of data submitted to APRA is in place.
Authorisation
When an officer, or agent, of a parent entity of a Level 2 insurance group provides the information required by this Reporting Standard using the ‘Direct to APRA’ software it will be necessary for an officer, or agent, to digitally sign the relevant information using a digital certificate acceptable to APRA.
If a parent entity of a Level 2 insurance group provides the information required by this Reporting Standard through an agent who submits using the ‘Direct to APRA’ software, on the parent entity of the Level 2 insurance group’s behalf, the parent entity of the Level 2 insurance group must:
(a) obtain from the agent a copy of the completed form with the information provided to APRA; and
(b) retain the completed copy.
An officer, or agent, of a parent entity of a Level 2 insurance group who submits the information under this Reporting Standard for, or on behalf of, the parent entity of a Level 2 insurance group must be authorised by either:
(a) the Principal Executive Officer of the parent entity of the Level 2 insurance group; or
(b) the Chief Financial Officer of the parent entity of the Level 2 insurance group.
Variations
APRA may, by written notice to the parent entity of a Level 2 insurance group, vary the reporting requirements of Form GRF 114.3_G in relation to that Level 2 insurance group.
Transition
A parent entity of a Level 2 insurance group must report under the old reporting standard in respect of a transitional reporting period. For these purposes:
old reporting standard means the reporting standard revoked in the determination making this Reporting Standard (being the reporting standard which this Reporting Standard replaces); and
transitional reporting period means a reporting period under the old reporting standard:
(a) which ended before the date of revocation of the old reporting standard; and
(b) in relation to which the parent entity of the Level 2 insurance group was required, under the old reporting standard, to report by a date on or after the date of revocation of the old reporting standard.
Note: For the avoidance of doubt, if a parent entity of a Level 2 insurance group was required to report under an old reporting standard, and the reporting documents were due before the date of revocation of the old reporting standard, the parent entity of a Level 2 insurance group is still required to provide any overdue reporting documents in accordance with the old reporting standard.
Interpretation
In this Reporting Standard (including the attachments):
(a) unless the contrary intention appears, words and expressions have the meanings given to them in GPS 001; and
(b) APRA-authorised reinsurer means an insurer carrying on reinsurance business. For the purposes of this definition, a Lloyd’s underwriter as defined under the Insurance Act is an APRA-authorised reinsurer if it carries on reinsurance business. The Australian Reinsurance Pool Corporation is also an APRA-authorised reinsurer for the purposes of this definition;
capital standards means the prudential standards which relate to capital adequacy as defined in GPS 001;
Chief Financial Officer means the chief financial officer of the parent entity of the Level 2 insurance group, by whatever name called;
financial year means the financial year (within the meaning of the Corporations Act 2001) of the parent entity of the Level 2 insurance group;
foreign insurer means a foreign general insurer within the meaning of the Insurance Act;
Note: A reference to a ‘branch’ or ‘branch operation’ is a reference to the Australian operations of a foreign insurer.
general instruction guide refers to the general Instruction guide set out in Attachment A of GRS 001;
Group Auditor has the meaning given in GPS 310;
Insurance Act means the Insurance Act 1973;
insurer means a general insurer within the meaning of section 11 of the Insurance Act;
Note: In the forms and instructions, a reference to an ‘authorised insurer’, ‘authorised insurance entity’ or ‘licensed insurer’ is a reference to an insurer, and a reference to an ‘authorised reinsurance entity’ is a reference to an insurer whose business consists only of undertaking liability by way of reinsurance.
non-APRA authorised reinsurer means any reinsurer that is not an APRA-authorised reinsurer;
Principal Executive Officer means the current principal executive officer of the entity, regardless of title, and whether or not he or she is a member of the governing board of the entity; and
reporting period means a period mentioned in subparagraph 6(a) or 6(b) or, if applicable, paragraph 7.
Off-balance Sheet Business (Level 2 Insu
Off-balance Sheet Business (Level 2 Insurance Group)
Off-balance Sheet Business (Level 2 Insurance Group)
Objective of this Reporting Standard
This Reporting Standard sets out the requirements for the provision of information to APRA relating to a Level 2 insurance group’s off-balance sheet business.
It includes Form GRF 114.3_G Off-balance Sheet Business (G) and associated specific instructions and must be read in conjunction with the general instruction guide.
Authority
This Reporting Standard is made under section 13 of the Financial Sector (Collection of Data) Act 2001.
Purpose
Information collected in Form GRF 114.3_G Off-balance Sheet Business (G) (GRF 114.3_G) is used by APRA for the purpose of prudential supervision, including assessing compliance with the capital standards.
Application and commencement
This Reporting Standard applies to a parent entity of a Level 2 insurance group as defined in Prudential Standard GPS 001 Definitions (GPS 001). This Reporting Standard applies for reporting periods ending on or after 1 July 2022. The parent entity of a Level 2 group is required to ensure that each requirement in this Reporting Standard is complied with.
Information required
The parent entity of a Level 2 insurance group must provide APRA with the information required by Form GRF 114.3_G in respect of the Level 2 insurance group for each reporting period.
Forms and method of submission
The information required by this Reporting Standard must be given to APRA in electronic format using the ‘Direct to APRA’ application or, where ‘Direct to APRA’ is not available, by a method notified by APRA prior to submission.
Note: The ‘Direct to APRA’ application software may be obtained from APRA.
Reporting periods and due dates
Subject to paragraph 7, the parent entity of a Level 2 insurance group must provide the information required by this Reporting Standard:
(a) in respect of the first half year based on the financial year of the Level 2 insurance group on an unaudited basis; and
(b) in respect of each financial year of the Level 2 insurance group on an audited basis.
Note: The annual information required by paragraphs 4, 5 and 6(b), together with certain annual information required by other reporting standards, will form part of the Level 2 insurance group’s annual accounts within the meaning of GPS 001. Prudential Standard GPS 310 Audit and Related Matters (GPS 310) contains the relevant provisions governing audits.
If, having regard to the particular circumstances of a Level 2 insurance group, APRA considers it necessary or desirable to obtain information more or less frequently than as provided by subparagraph 6(a) or 6(b), APRA may, by notice in writing to the parent entity, change the reporting periods, or specify reporting periods, for the particular Level 2 insurance group.
The information required by this Reporting Standard in respect of a Level 2 insurance group must be provided to APRA:
(a) within the time stated in Reporting Standard GRS 001 Reporting Requirements (GRS 001); or
(b) in the case of information provided in accordance with paragraph 7, within the time specified by notice in writing.
Note: GPS 310 requires a Level 2 insurance group to ensure that its Group Auditor conducts a limited assurance review of the group’s annual accounts. Accordingly, the Group Auditor’s report(s) as required by GPS 310 (relating to the information required by paragraph 4) must be provided to APRA by the time specified in GRS 001 (unless an extension of time is granted under GRS 001).
On the written application of the parent entity of a Level 2 insurance group, APRA may by notice in writing to the parent entity exclude the requirement under subparagraph 6(a) to provide half yearly information.
Quality control
The information provided by the parent entity of a Level 2 insurance group under this Reporting Standard must be the product of systems, processes and controls that have been reviewed and tested by the Group Auditor of the Level 2 insurance group. This will require the Group Auditor to review and test the Level 2 insurance group’s systems, processes and controls designed to enable the group to report reliable financial information to APRA. This review and testing must be done on:
(a) an annual basis or more frequently if necessary to enable the Group Auditor to form an opinion on the reliability and accuracy of data; and
(b) at least a limited assurance engagement consistent with professional standards and guidance notes issued by the Auditing and Assurance Standards Board (AUASB) as may be amended from time to time, to the extent that they are not inconsistent with the requirements of GPS 310.
All information provided by the parent entity of a Level 2 insurance group under this Reporting Standard must be subject to systems, processes and controls developed by the Level 2 insurance group for the internal review and authorisation of that information. It is the responsibility of the Board and senior management of the parent entity of the Level 2 insurance group to ensure that an appropriate set of policies and procedures for the authorisation of data submitted to APRA is in place.
Authorisation
When an officer, or agent, of a parent entity of a Level 2 insurance group provides the information required by this Reporting Standard using the ‘Direct to APRA’ software it will be necessary for an officer, or agent, to digitally sign the relevant information using a digital certificate acceptable to APRA.
If a parent entity of a Level 2 insurance group provides the information required by this Reporting Standard through an agent who submits using the ‘Direct to APRA’ software, on the parent entity of the Level 2 insurance group’s behalf, the parent entity of the Level 2 insurance group must:
(a) obtain from the agent a copy of the completed form with the information provided to APRA; and
(b) retain the completed copy.
An officer, or agent, of a parent entity of a Level 2 insurance group who submits the information under this Reporting Standard for, or on behalf of, the parent entity of a Level 2 insurance group must be authorised by either:
(a) the Principal Executive Officer of the parent entity of the Level 2 insurance group; or
(b) the Chief Financial Officer of the parent entity of the Level 2 insurance group.
Variations
APRA may, by written notice to the parent entity of a Level 2 insurance group, vary the reporting requirements of Form GRF 114.3_G in relation to that Level 2 insurance group.
Transition
A parent entity of a Level 2 insurance group must report under the old reporting standard in respect of a transitional reporting period. For these purposes:
old reporting standard means the reporting standard revoked in the determination making this Reporting Standard (being the reporting standard which this Reporting Standard replaces); and
transitional reporting period means a reporting period under the old reporting standard:
(a) which ended before the date of revocation of the old reporting standard; and
(b) in relation to which the parent entity of the Level 2 insurance group was required, under the old reporting standard, to report by a date on or after the date of revocation of the old reporting standard.
Note: For the avoidance of doubt, if a parent entity of a Level 2 insurance group was required to report under an old reporting standard, and the reporting documents were due before the date of revocation of the old reporting standard, the parent entity of a Level 2 insurance group is still required to provide any overdue reporting documents in accordance with the old reporting standard.
Interpretation
In this Reporting Standard (including the attachments):
(a) unless the contrary intention appears, words and expressions have the meanings given to them in GPS 001; and
(b) APRA-authorised reinsurer means an insurer carrying on reinsurance business. For the purposes of this definition, a Lloyd’s underwriter as defined under the Insurance Act is an APRA-authorised reinsurer if it carries on reinsurance business. The Australian Reinsurance Pool Corporation is also an APRA-authorised reinsurer for the purposes of this definition;
capital standards means the prudential standards which relate to capital adequacy as defined in GPS 001;
Chief Financial Officer means the chief financial officer of the parent entity of the Level 2 insurance group, by whatever name called;
financial year means the financial year (within the meaning of the Corporations Act 2001) of the parent entity of the Level 2 insurance group;
foreign insurer means a foreign general insurer within the meaning of the Insurance Act;
Note: A reference to a ‘branch’ or ‘branch operation’ is a reference to the Australian operations of a foreign insurer.
general instruction guide refers to the general Instruction guide set out in Attachment A of GRS 001;
Group Auditor has the meaning given in GPS 310;
Insurance Act means the Insurance Act 1973;
insurer means a general insurer within the meaning of section 11 of the Insurance Act;
Note: In the forms and instructions, a reference to an ‘authorised insurer’, ‘authorised insurance entity’ or ‘licensed insurer’ is a reference to an insurer, and a reference to an ‘authorised reinsurance entity’ is a reference to an insurer whose business consists only of undertaking liability by way of reinsurance.
non-APRA authorised reinsurer means any reinsurer that is not an APRA-authorised reinsurer;
Principal Executive Officer means the current principal executive officer of the entity, regardless of title, and whether or not he or she is a member of the governing board of the entity; and
reporting period means a period mentioned in subparagraph 6(a) or 6(b) or, if applicable, paragraph 7.
Objective of this Reporting Standard
Objective of this Reporting Standard
Objective of this Reporting Standard
This Reporting Standard sets out the requirements for the provision of information to APRA relating to a Level 2 insurance group’s off-balance sheet business.
It includes Form GRF 114.3_G Off-balance Sheet Business (G) and associated specific instructions and must be read in conjunction with the general instruction guide.
Authority
Authority
Authority
This Reporting Standard is made under section 13 of the Financial Sector (Collection of Data) Act 2001.
Purpose
Purpose
Purpose
Information collected in Form GRF 114.3_G Off-balance Sheet Business (G) (GRF 114.3_G) is used by APRA for the purpose of prudential supervision, including assessing compliance with the capital standards.
Application and commencement
Application and commencement
Application and commencement
This Reporting Standard applies to a parent entity of a Level 2 insurance group as defined in Prudential Standard GPS 001 Definitions (GPS 001). This Reporting Standard applies for reporting periods ending on or after 1 July 2022. The parent entity of a Level 2 group is required to ensure that each requirement in this Reporting Standard is complied with.
Information required
Information required
Information required
The parent entity of a Level 2 insurance group must provide APRA with the information required by Form GRF 114.3_G in respect of the Level 2 insurance group for each reporting period.
Forms and method of submission
Forms and method of submission
Forms and method of submission
The information required by this Reporting Standard must be given to APRA in electronic format using the ‘Direct to APRA’ application or, where ‘Direct to APRA’ is not available, by a method notified by APRA prior to submission.
Note: The ‘Direct to APRA’ application software may be obtained from APRA.
Reporting periods and due dates
Reporting periods and due dates
Reporting periods and due dates
Subject to paragraph 7, the parent entity of a Level 2 insurance group must provide the information required by this Reporting Standard:
(a) in respect of the first half year based on the financial year of the Level 2 insurance group on an unaudited basis; and
(b) in respect of each financial year of the Level 2 insurance group on an audited basis.
Note: The annual information required by paragraphs 4, 5 and 6(b), together with certain annual information required by other reporting standards, will form part of the Level 2 insurance group’s annual accounts within the meaning of GPS 001. Prudential Standard GPS 310 Audit and Related Matters (GPS 310) contains the relevant provisions governing audits.
If, having regard to the particular circumstances of a Level 2 insurance group, APRA considers it necessary or desirable to obtain information more or less frequently than as provided by subparagraph 6(a) or 6(b), APRA may, by notice in writing to the parent entity, change the reporting periods, or specify reporting periods, for the particular Level 2 insurance group.
The information required by this Reporting Standard in respect of a Level 2 insurance group must be provided to APRA:
(a) within the time stated in Reporting Standard GRS 001 Reporting Requirements (GRS 001); or
(b) in the case of information provided in accordance with paragraph 7, within the time specified by notice in writing.
Note: GPS 310 requires a Level 2 insurance group to ensure that its Group Auditor conducts a limited assurance review of the group’s annual accounts. Accordingly, the Group Auditor’s report(s) as required by GPS 310 (relating to the information required by paragraph 4) must be provided to APRA by the time specified in GRS 001 (unless an extension of time is granted under GRS 001).
On the written application of the parent entity of a Level 2 insurance group, APRA may by notice in writing to the parent entity exclude the requirement under subparagraph 6(a) to provide half yearly information.
Quality control
Quality control
Quality control
The information provided by the parent entity of a Level 2 insurance group under this Reporting Standard must be the product of systems, processes and controls that have been reviewed and tested by the Group Auditor of the Level 2 insurance group. This will require the Group Auditor to review and test the Level 2 insurance group’s systems, processes and controls designed to enable the group to report reliable financial information to APRA. This review and testing must be done on:
(a) an annual basis or more frequently if necessary to enable the Group Auditor to form an opinion on the reliability and accuracy of data; and
(b) at least a limited assurance engagement consistent with professional standards and guidance notes issued by the Auditing and Assurance Standards Board (AUASB) as may be amended from time to time, to the extent that they are not inconsistent with the requirements of GPS 310.
All information provided by the parent entity of a Level 2 insurance group under this Reporting Standard must be subject to systems, processes and controls developed by the Level 2 insurance group for the internal review and authorisation of that information. It is the responsibility of the Board and senior management of the parent entity of the Level 2 insurance group to ensure that an appropriate set of policies and procedures for the authorisation of data submitted to APRA is in place.
Authorisation
Authorisation
Authorisation
When an officer, or agent, of a parent entity of a Level 2 insurance group provides the information required by this Reporting Standard using the ‘Direct to APRA’ software it will be necessary for an officer, or agent, to digitally sign the relevant information using a digital certificate acceptable to APRA.
If a parent entity of a Level 2 insurance group provides the information required by this Reporting Standard through an agent who submits using the ‘Direct to APRA’ software, on the parent entity of the Level 2 insurance group’s behalf, the parent entity of the Level 2 insurance group must:
(a) obtain from the agent a copy of the completed form with the information provided to APRA; and
(b) retain the completed copy.
An officer, or agent, of a parent entity of a Level 2 insurance group who submits the information under this Reporting Standard for, or on behalf of, the parent entity of a Level 2 insurance group must be authorised by either:
(a) the Principal Executive Officer of the parent entity of the Level 2 insurance group; or
(b) the Chief Financial Officer of the parent entity of the Level 2 insurance group.
Variations
Variations
Variations
APRA may, by written notice to the parent entity of a Level 2 insurance group, vary the reporting requirements of Form GRF 114.3_G in relation to that Level 2 insurance group.
Transition
Transition
Transition
A parent entity of a Level 2 insurance group must report under the old reporting standard in respect of a transitional reporting period. For these purposes:
old reporting standard means the reporting standard revoked in the determination making this Reporting Standard (being the reporting standard which this Reporting Standard replaces); and
transitional reporting period means a reporting period under the old reporting standard:
(a) which ended before the date of revocation of the old reporting standard; and
(b) in relation to which the parent entity of the Level 2 insurance group was required, under the old reporting standard, to report by a date on or after the date of revocation of the old reporting standard.
Note: For the avoidance of doubt, if a parent entity of a Level 2 insurance group was required to report under an old reporting standard, and the reporting documents were due before the date of revocation of the old reporting standard, the parent entity of a Level 2 insurance group is still required to provide any overdue reporting documents in accordance with the old reporting standard.
Interpretation
Interpretation
Interpretation
In this Reporting Standard (including the attachments):
(a) unless the contrary intention appears, words and expressions have the meanings given to them in GPS 001; and
(b) APRA-authorised reinsurer means an insurer carrying on reinsurance business. For the purposes of this definition, a Lloyd’s underwriter as defined under the Insurance Act is an APRA-authorised reinsurer if it carries on reinsurance business. The Australian Reinsurance Pool Corporation is also an APRA-authorised reinsurer for the purposes of this definition;
capital standards means the prudential standards which relate to capital adequacy as defined in GPS 001;
Chief Financial Officer means the chief financial officer of the parent entity of the Level 2 insurance group, by whatever name called;
financial year means the financial year (within the meaning of the Corporations Act 2001) of the parent entity of the Level 2 insurance group;
foreign insurer means a foreign general insurer within the meaning of the Insurance Act;
Note: A reference to a ‘branch’ or ‘branch operation’ is a reference to the Australian operations of a foreign insurer.
general instruction guide refers to the general Instruction guide set out in Attachment A of GRS 001;
Group Auditor has the meaning given in GPS 310;
Insurance Act means the Insurance Act 1973;
insurer means a general insurer within the meaning of section 11 of the Insurance Act;
Note: In the forms and instructions, a reference to an ‘authorised insurer’, ‘authorised insurance entity’ or ‘licensed insurer’ is a reference to an insurer, and a reference to an ‘authorised reinsurance entity’ is a reference to an insurer whose business consists only of undertaking liability by way of reinsurance.
non-APRA authorised reinsurer means any reinsurer that is not an APRA-authorised reinsurer;
Principal Executive Officer means the current principal executive officer of the entity, regardless of title, and whether or not he or she is a member of the governing board of the entity; and
reporting period means a period mentioned in subparagraph 6(a) or 6(b) or, if applicable, paragraph 7.
Source text: opening excerpt
Sourced from the Federal Register of Legislation (legislation.gov.au), CC BY 4.0.
Reporting Standard GRS 114.3_G Reporting Standard GRS 114.3_G
Reporting Standard GRS 114.3_G
Off-balance Sheet Business (Level 2 Insurance Group)
Objective of this Reporting Standard
This Reporting Standard sets out the requirements for the provision of information to APRA relating to a Level 2 insurance group’s off-balance sheet business.
It includes Form GRF 114.3_G Off-balance Sheet Business (G) and associated specific instructions and must be read in conjunction with the general instruction guide.
Authority
This Reporting Standard is made under section 13 of the Financial Sector (Collection of Data) Act 2001.
Purpose
Information collected in Form GRF 114.3_G Off-balance Sheet Business (G) (GRF 114.3_G) is used by APRA for the purpose of prudential supervision, including assessing compliance with the capital standards.
Application and commencement
This Reporting Standard applies to a parent entity of a Level 2 insurance group as defined in Prudential Standard GPS 001 Definitions (GPS 001). This Reporting Standard applies for reporting periods ending on or after 1 July 2022. The parent entity of a Level 2 group is required to ensure that each requirement in this Reporting Standard is complied with.
Information required
The parent entity of a Level 2 insurance group must provide APRA with the information required by Form GRF 114.3_G in respect of the Level 2 insurance group for each reporting period.
Forms and method of submission
The information required by this Reporting Standard must be given to APRA in electronic format using the ‘Direct to APRA’ application or, where ‘Direct to APRA’ is not available, by a method notified by APRA prior to submission.
Note: The ‘Direct to APRA’ application software may be obtained from APRA.
Reporting periods and due dates
Subject to paragraph 7, the parent entity of a Level 2 insurance group must provide the information required by this Reporting Standard:
(a) in respect of the first half year based on the financial year of the Level 2 insurance group on an unaudited basis; and
(b) in respect of each financial year of the Level 2 insurance group on an audited basis.
Note: The annual information required by paragraphs 4, 5 and 6(b), together with certain annual information required by other reporting standards, will form part of the Level 2 insurance group’s annual accounts within the meaning of GPS 001. Prudential Standard GPS 310 Audit and Related Matters (GPS 310) contains the relevant provisions governing audits.
Gives APRA specific administrative powers: APRA may vary the reporting requirements of the form in relation to a particular Level 2 insurance group (para 15), and it can exempt a parent entity from half-yearly reporting on written application (para 9).
Contains transitional instructions: reporting under the prior (revoked) standard may be required for transitional reporting periods as defined (para 16).
Provides interpretative cross-references: unless a contrary intention appears, definitions are those in GPS 001, and a number of specific definitions are restated (para 17).
The instrument also states purpose: APRA will use the data for prudential supervision, “including assessing compliance with the capital standards” (para 2). The form and its associated instructions must be read together with the general instruction guide (objective and para 17).
Mechanically, the Standard imposes an on-going data collection and assurance regime that ties the off-balance sheet disclosure to the group’s audited annual accounts (note after para 6) and to the Group Auditor’s limited assurance work under GPS 310. APRA retains discretion to alter frequency and content for individual groups (paras 7 and 15). The parent entity remains the responsible party for ensuring compliance across the group (para 3).
Main concepts
The instrument revolves around a set of consistent administrative and governance concepts. These concepts are the vocabulary and operational touchpoints for applying the Standard.
Level 2 insurance group and parent entity: the Standard applies specifically to the parent entity of a Level 2 insurance group, as that term is defined in GPS 001 (para 3). The parent entity is the legal actor responsible for compliance with each requirement (para 3).
Off-balance sheet business: the subject-matter of the required reporting is the group’s off-balance sheet business. The specific data points are those in Form GRF 114.3_G and associated instructions; the Standard expressly includes the form and instructions and requires they be read with the general instruction guide (objective and para 4).
Reporting periods and assurance levels: reporting is required on a half-yearly basis (unaudited) and on an annual basis (audited) tied to the group financial year (para 6). The annual information forms part of the group’s annual accounts as defined in GPS 001 and is subject to the audit regime in GPS 310 (note after para 6).
Quality control and audit involvement: the Group Auditor must review and test the group’s systems, processes and controls used to produce the information. This work must be performed annually or more frequently if necessary and includes a limited assurance engagement consistent with AUASB standards, insofar as those are not inconsistent with GPS 310 (para 10(b) and para 10 generally).
Authorisation and digital signature: electronic submission requires a digital signature via a digital certificate acceptable to APRA (para 12). Submitters must be authorised by the Principal Executive Officer or Chief Financial Officer (para 14). Where an agent submits on behalf of the parent entity, the parent must receive and retain a copy of the completed form (para 13).
APRA discretion and variations: APRA can change reporting frequency or specify different reporting periods for a particular Level 2 group (para 7). APRA can also, by written notice, vary the reporting requirements of Form GRF 114.3_G for a particular group (para 15). A written application from the parent entity can lead to APRA excluding the half-year requirement (para 9).
Transition mechanics: the Standard sets out a transition rule requiring reporting under the old reporting standard for certain transitional reporting periods that straddle revocation (para 16).
Cross-references and definitions: the Standard uses defined terms from GPS 001 unless the contrary intention appears, and reiterates specific definitions (APRA-authorised reinsurer, capital standards, Group Auditor, Insurance Act, etc.) (para 17).
These concepts structure the duties (what must be reported, when, and by whom), the assurance model (limited assurance review of annual accounts and auditor testing of controls), and the regulatory levers (APRA’s power to vary, exempt or otherwise direct reporting requirements). The Standard therefore functions as both a data specification and a governance framework connecting reporting outputs to group-level audit oversight.
Who it affects
Primary obligations attach to the parent entity of a Level 2 insurance group. Paragraph 3 states the Standard applies to a parent entity of a Level 2 insurance group as defined in GPS 001, and further requires the parent entity to ensure that each requirement is complied with. The term “parent entity” places legal accountability at group-head level rather than on subsidiary entities that may generate the off-balance sheet exposures.
Other named parties with explicit duties:
Group Auditor: the Group Auditor must review and test the group’s systems, processes and controls that produce the information provided to APRA (para 10). That review must be at least annual and include a limited assurance engagement consistent with AUASB standards and GPS 310 (para 10(b)).
Board and senior management of the parent entity: para 11 assigns responsibility to the Board and senior management to ensure an appropriate set of policies and procedures for internal review and authorisation of data submitted to APRA is in place.
Officers or agents who submit information: submissions must be digitally signed by an officer or agent using an APRA-acceptable digital certificate (para 12). Submitters must be authorised by either the Principal Executive Officer or the Chief Financial Officer (para 14).
Agents engaged to submit: if an agent submits on the parent entity’s behalf using Direct to APRA, the parent must obtain and retain a copy of the completed form (para 13).
APRA: the regulator is both the recipient and a decision-maker; it can vary reporting requirements (para 15), alter reporting periods for a particular group (para 7), exclude half-yearly requirements on application (para 9), and specify alternative submission methods where Direct to APRA is unavailable (para 5).
Reinsurers and insurers referenced in definitions: para 17 contains definitions relevant to the classification of counterparties (APRA-authorised reinsurer, non-APRA authorised reinsurer, insurer, Lloyd’s underwriter), which can affect how off-balance sheet items are reported where counterparties are reinsurers.
Indirectly affected parties include:
Group finance, risk and compliance functions: they must build and maintain the systems and controls that generate the reported information and implement the board-approved policies required by para 11.
External auditors and audit firms: the Group Auditor role may be performed by a firm external to the group; auditors must plan for review and limited assurance procedures consistent with GPS 310 and AUASB standards (para 10 and the note to para 6).
IT and cyber security providers: the directive to use APRA’s Direct to APRA application (para 5) and to use an APRA-acceptable digital certificate for signing submissions (para 12) creates interactions with IT providers and certificate authorities.
Who pays: the parent entity bears the costs of complying , systems, staff time, audit fees for the limited assurance engagement, procurement of a digital certificate acceptable to APRA, agent fees where applicable, and record-retention obligations (paras 10-14).
Who decides: APRA retains material discretion (paras 7, 9 and 15) and can impose bespoke reporting regimes. The parent entity’s senior management and Board set internal authorisation and control policies (para 11). The Principal Executive Officer or Chief Financial Officer decide who may submit (para 14).
Behavioural consequences: reporting obligations and auditor scrutiny shift work to centralised group functions, require closer integration between actuarial/insurance teams and finance, and bring off-balance sheet items within APRA’s prudential oversight (purpose para 2). Entities may adjust their off-balance sheet practices, risk aggregation or disclosure processes in response to the need to capture and report specified information to APRA.
Key duties and rights
The Standard creates a set of affirmative duties for the parent entity, the Group Auditor, submitters and the Board, and confers procedural rights in relation to APRA’s discretionary powers.
Key duties for the parent entity
To provide APRA with the information required by Form GRF 114.3_G in respect of the Level 2 insurance group for each reporting period (para 4). This is the core reporting duty.
To ensure compliance with each requirement in the Standard (para 3). This places an internal supervisory duty on the parent entity beyond mere submission.
To use the electronic submission channel prescribed by APRA, namely Direct to APRA, or an APRA-notified alternative if Direct to APRA is unavailable (para 5).
To obtain and retain a completed copy of the form where an agent submits on its behalf (para 13).
To ensure internal systems, processes and controls for preparing the data are in place and subject to internal review and authorisation policies and procedures (para 11).
To apply for exclusion from half-yearly reporting if the parent entity considers it appropriate (para 9 outlines APRA’s power to exclude following written application).
Duties for the Group Auditor
To review and test the Level 2 insurance group’s systems, processes and controls designed to enable reporting to APRA (para 10).
To perform that review and testing on at least an annual basis or more frequently if necessary, and to carry out a limited assurance engagement consistent with AUASB standards and GPS 310 (para 10).
Duties for submitters, officers and agents
To digitally sign submissions using a digital certificate acceptable to APRA (para 12).
To be authorised by either the Principal Executive Officer or Chief Financial Officer of the parent entity prior to submitting (para 14).
Duties for the board and senior management
To ensure an appropriate set of policies and procedures for the authorisation of data submitted to APRA is in place (para 11).
Rights and procedural mechanisms
APRA’s right to vary or tailor reporting: APRA may change reporting periods or specify reporting periods for a particular Level 2 insurance group by written notice (para 7), and may vary the reporting requirements of Form GRF 114.3_G by written notice (para 15).
Right to apply for exemption: the parent entity can apply in writing for APRA to exclude the half-yearly reporting requirement; APRA may grant that exclusion by notice in writing (para 9).
Submission process: the parent entity has the right to use an APRA-notified alternative method where Direct to APRA is not available (para 5).
Specified dependencies and cross-obligations
The annual information forms part of the Level 2 group’s annual accounts within GPS 001 and is therefore subject to GPS 310 audit requirements (note after para 6). This creates an implied coordination duty between reporting and the group’s broader statutory accounts and audit processes.
The Group Auditor must provide the required limited assurance reports in timeframes set out in GRS 001 (note to para 8), linking the timing of audit work to APRA’s reporting calendar.
Limitations in the instrument
The Standard itself does not set out statutory penalties or sanctions for non-compliance; enforcement mechanisms are not described in the text of the Standard (paras 1-17 contain obligations but no penalty clauses). The instrument’s authority is s13 of the Financial Sector (Collection of Data) Act 2001 (para 1), and further supervisory or enforcement consequences would arise from that Act or other prudential standards, not from this Standard’s text directly.
In short, duties concentrate on data provision, assurance, authorisation and record-keeping. Rights are largely procedural , applicants can seek exemption from half-yearly reporting and APRA can tailor requirements for a particular group.
Penalties and enforcement
The Reporting Standard sets out procedural and reporting duties but does not itself specify penalties or enforcement actions against entities that fail to comply. Its authority is expressly derived from section 13 of the Financial Sector (Collection of Data) Act 2001 (para 1). The Standard contains administrative levers (APRA may issue notices varying reporting requirements under paras 7 and 15; APRA may accept alternative submission methods where Direct to APRA is unavailable under para 5; APRA may exclude half-yearly reporting at the parent entity’s written application under para 9).
What the Standard itself prescribes as assurance and control work
The Group Auditor is required to review and test the systems, processes and controls that produce the reported information and to undertake at least a limited assurance engagement consistent with AUASB professional standards and GPS 310 (para 10). That creates an audit trail and professional obligations for auditors and audit firms, and it ties reporting accuracy to the Group Auditor’s opinion processes.
What the Standard does not do in its text
It does not create or specify civil or criminal penalties, infringement notices, or monetary sanctions. There is no schedule of penalties contained within paragraphs 1-17.
It does not set out APRA’s supervisory actions following non-compliance, such as directions, enforceable undertakings, or public statements. Those enforcement powers, if any, would arise from the Financial Sector (Collection of Data) Act 2001 or other prudential standards, but the Reporting Standard itself does not record them.
Practical implications for enforcement risk
Because the Standard requires the information to be part of the group’s annual accounts and to be subject to the Group Auditor’s limited assurance under GPS 310 (note to para 6 and para 10), non-compliance can become visible through the audit process. That visibility creates a practical enforcement pathway: auditors may identify deficiencies that APRA can then address under its broader statutory powers.
APRA’s ability to vary reporting for particular groups (paras 7 and 15) is an administrative enforcement tool: APRA can require more frequent reporting or additional fields where it deems necessary to meet prudential supervision objectives.
The instrument places responsibility on Boards and senior management to implement authorisation controls for data submitted to APRA (para 11). Failure to implement such governance could have reputational, regulatory and professional consequences outside the Standard itself.
Recommendation for practitioners
To assess enforcement exposure, consult the Financial Sector (Collection of Data) Act 2001 and the prudential standard framework (GPS 001, GPS 310, GRS 001) for the statutory enforcement tools and possible sanctions that sit outside this Reporting Standard. The Standard creates duties and audit expectations; the enforcement mechanisms that APRA may employ are located in the enabling legislation and prudential regime rather than in the Standard’s text.
How it interacts with other laws
The Reporting Standard explicitly cross-references multiple prudential instruments and statutes; these cross-references establish dependencies that affect interpretation, audit timing, assurance standards and definition scope.
Explicit cross-references in the instrument
Financial Sector (Collection of Data) Act 2001: the Standard is made under s13 of that Act (para 1). That Act is the enabling statute for APRA’s collection powers; enforcement and penalty mechanisms will be found in the Act rather than in the Reporting Standard.
Prudential Standard GPS 001 Definitions (GPS 001): the Standard applies to a parent entity of a Level 2 insurance group “as defined in GPS 001” and para 17(a) states that words and expressions have GPS 001 meanings unless the contrary intention appears (para 3 and para 17(a)). This ties the Standard’s scope and defined terms (for example, Level 2 group, capital standards) to GPS 001.
Prudential Standard GPS 310 Audit and Related Matters (GPS 310): the note after para 6 and para 10 refer to GPS 310 for the audit regime and the Group Auditor definition. GPS 310 contains the requirements governing audits and the Group Auditor’s duties referenced in this Standard.
Reporting Standard GRS 001 Reporting Requirements (GRS 001): timing and due-date requirements are linked to GRS 001 (para 8 references the time stated in GRS 001). The Standard therefore delegates reporting timelines and any extension powers to GRS 001.
Corporations Act 2001: the term “financial year” is defined as within the meaning of the Corporations Act (para 17). This ties reporting cycles to the corporate statutory accounting year.
Insurance Act 1973: the instrument refers to the Insurance Act when defining insurer, foreign insurer and Lloyd’s underwriter references (para 17).
Auditing and Assurance Standards Board (AUASB) professional standards and guidance notes: para 10(b) requires the limited assurance engagement to be consistent with AUASB standards to the extent not inconsistent with GPS 310.
Operational consequences of these interactions
Definitions and scope are not self-contained: because the Standard defers definitions to GPS 001 (para 17(a)), users must read GPS 001 to determine whether an entity falls within scope and how certain terms are to be understood. Practitioners should not treat the Standard in isolation.
Audit and assurance alignment: the Group Auditor’s work is governed by GPS 310 and must align with AUASB standards (para 10). That means the nature and extent of auditor procedures, the timing of assurance reports and the auditor’s independence and reporting obligations will involve GPS 310 and AUASB requirements.
Timing and extensions: reporting due dates are governed by GRS 001 (para 8). Where GRS 001 provides for extensions or specific lodgement dates, those provisions will dictate compliance timing for this form as well.
Legal and regulatory remedies: the Standard does not itself prescribe sanctions. Any enforcement actions, notices or sanctions would rely on the powers in the Financial Sector (Collection of Data) Act 2001 and related prudential standards. Practitioners should map the Standard’s reporting duties against the wider statutory enforcement regime to assess risk.
Interaction with insurers and reinsurers: para 17 defines APRA-authorised reinsurer, non-APRA authorised reinsurer and insurer in terms that reference the Insurance Act and specific entities (e.g. the Australian Reinsurance Pool Corporation). How off-balance sheet items involving reinsurance counterparties are categorised in the form will therefore depend on these definitions.
In summary, the Reporting Standard functions as a data-specification module embedded in APRA’s broader prudential architecture. Compliance requires combining the Standard with GPS 001 for definitions, GPS 310 for audit and assurance, GRS 001 for timing, the Corporations Act for accounting year definitions and AUASB standards for assurance engagement methodology. Practitioners must therefore treat the Standard as part of an integrated compliance task rather than a stand-alone instrument.
Amendment history
The text contains limited explicit amendment detail, but it does set a commencement point and prescribes transitional treatment for the predecessor instrument.
Commencement and replacement
The Standard applies for reporting periods ending on or after 1 July 2022 (para 3). That is the stated commencement for application.
Paragraph 16 makes provision for transitional reporting under the “old reporting standard”, defined as the reporting standard revoked in the determination making this Reporting Standard. The instrument therefore replaces a prior reporting standard and establishes rules for reporting periods that straddle the revocation date.
Transitional mechanics
Transitional reporting period is defined as a reporting period under the old reporting standard which ended before the date of revocation of the old reporting standard and for which the parent entity was required under the old standard to report by a date on or after the date of revocation (para 16).
The parent entity must report under the old reporting standard in respect of a transitional reporting period (para 16).
The instrument contains a note clarifying that overdue reports under the old reporting standard that were due before revocation remain required under the old standard (para 16 note).
What the Standard does not record
The instrument does not include a revocation date, the text of the previous standard, versioning metadata or a sequence of prior amendments. It refers generically to the “old reporting standard” but provides no legislative history of when prior amendments occurred or what changed between versions.
It does not document the substantive changes from the old reporting standard to the current version beyond the transitional rule.
How to reconstruct amendment history in practice
To establish a full amendment chronology a practitioner will need to consult APRA’s determinations, the revoked instrument referenced in the determination, and any published determination materials. The current text gives the effective application date (1 July 2022) and the existence of a revocation-based transition, but not a clause-by-clause amendment log.
Implication for compliance
Because the Standard requires some transitional reporting under the old standard in narrowly defined circumstances (para 16), a parent entity should check whether any reporting obligations it still has fall under the revoked instrument. That will require access to the determination that revoked the old standard as well as the old standard itself.
Litigation history
The Reporting Standard itself records no litigation, cases or judicial decisions. The numbered paragraphs 1-17 set rules, definitions and administrative procedures and do not cite any court decisions or tribunals. There are no named legal proceedings, disputes or judicial interpretations within the instrument.
Implications for practitioners
Because the instrument contains no litigation history, there is no text-based precedent or judicial interpretation supplied within the Standard that would guide contested questions of meaning or scope.
Where questions of interpretation or enforcement arise in practice, guidance will come either from APRA’s supervisory communications, published guidance materials, the broader prudential standards (GPS 001, GPS 310, GRS 001) and, if disputed, from the courts or tribunals applying the enabling legislation (the Financial Sector (Collection of Data) Act 2001 and related statutes).
Recommended next steps for research
If litigation or contested interpretations are relevant to a particular compliance strategy, practitioners should search external legal databases, court records and APRA’s published decisions and enforcement actions for matters concerning reporting standards, GPS 001, GPS 310 and GRS 001 to see whether any judicial or tribunal decisions have interpreted similar reporting obligations or APRA notices.
Consult APRA’s published guidance and technical notes for any clarifications or FAQs that may reduce the risk of disputes arising from ambiguous form requirements.
Gotchas
The Standard includes several traps for the unwary and points where compliance failure is plausible if a parent entity treats the form as a simple data upload rather than a governed, audited, board-approved output. The following are the main operational and legal "gotchas", each linked to the relevant paragraph(s).
Scope relies on GPS 001 definitions (para 3 and para 17(a))
Gotcha: whether an entity is a Level 2 insurance group is not determined by this Standard; it depends on GPS 001 definitions. Failure to check GPS 001 may lead to incorrect assumptions about applicability and reporting obligations.
Annual information forms part of annual accounts (note after para 6)
Gotcha: the data reported becomes part of the group’s annual accounts as defined in GPS 001, exposing it to audit scrutiny under GPS 310. Treating the form as a mere regulatory return rather than a component of audited accounts increases the likelihood that errors will be caught and escalated by auditors.
Limited assurance requirement and auditor testing (para 10)
Gotcha: the Group Auditor must review and test systems, processes and controls and perform a limited assurance engagement consistent with AUASB standards to the extent not inconsistent with GPS 310. If the Group Auditor is not engaged early enough, the audit timetable may not accommodate required procedures and the assurance report may be delayed.
Timing governed by GRS 001 (para 8)
Gotcha: due dates are those stated in GRS 001. Assuming calendar-based dates or relying on internal accounts deadlines without checking GRS 001 can result in late lodgement.
Digital signature and certificate requirement (para 12)
Gotcha: APRA requires a digital certificate acceptable to APRA. Obtaining and operationalising such a certificate, ensuring it is valid for the relevant submitters and integrating it into IT workflows, can take time and vendor selection.
Agent submissions and retention (para 13)
Gotcha: if an agent submits, the parent entity must obtain and retain a copy of the completed form. Failure to secure or retain the agent’s submission can breach the retention obligation.
Submitter authorisation (para 14)
Gotcha: submitters must be authorised by the Principal Executive Officer or Chief Financial Officer. Delegation and role-mapping need to be documented in policies; otherwise APRA may question the validity of submissions.
APRA’s discretionary powers to vary or change reporting (paras 7 and 15)
Gotcha: APRA can impose bespoke reporting or change frequency for a particular group by notice in writing. A group that relies on standard templates may be surprised by an APRA notice requiring different fields or more frequent reporting.
Transition rules may require reporting under the old standard (para 16)
Gotcha: for reporting periods that ended before revocation but for which reporting was due after revocation, the parent entity must report under the old standard. Keeping track of the revocation date and the timing of due dates is essential.
Board and senior management responsibility for policies (para 11)
Gotcha: the Board and senior management are explicitly responsible for ensuring appropriate policies and procedures for data authorisation. Absent board-level sign-off and documented procedures, APRA could view compliance as weak governance.
AUASB standards subject to GPS 310 consistency (para 10(b))
Gotcha: limited assurance engagement must be consistent with AUASB standards to the extent not inconsistent with GPS 310. If GPS 310 contains conflicting requirements, practitioners must reconcile them, not simply follow AUASB practice mechanically.
No penalty clause in the Standard (paras 1-17)
Gotcha: the absence of penalty clauses in the Standard does not mean non-compliance is without consequence. Enforcement tools are located elsewhere. Do not interpret silence as immunity.
Records and audit trail management
Gotcha: because Form GRF 114.3_G is part of audited annual accounts and the Group Auditor must perform assurance work, poor record-keeping on off-balance sheet instruments can lead to audit findings and APRA scrutiny.
Reliance on “Direct to APRA”
Gotcha: the mandated electronic channel may involve versioning, schema updates or data validation rules. Failure to test submissions through Direct to APRA prior to lodgement can lead to technical rejections or data quality issues.
Practitioners should map these gotchas into a compliance project plan with milestones tied to GRS 001 deadlines, the audit timetable under GPS 310, and APRA’s direct submission requirements.
How to comply
Compliance requires coordination between group finance, audit, risk, IT and senior management. Below is a practical step-by-step compliance checklist derived from the Standard’s text and the cross-references the Standard relies upon (paras referenced throughout).
Confirm scope and reporting responsibility (paras 3 and 4)
Verify that the entity is the parent of a Level 2 insurance group under GPS 001. The parent entity is legally responsible for complying with each requirement (para 3).
Map the Level 2 group’s population of off-balance sheet exposures that will populate Form GRF 114.3_G (para 4).
Align reporting calendar with GRS 001 and GPS 310 (paras 6 and 8)
Obtain the lodgement dates in GRS 001 and integrate them into the group’s reporting calendar (para 8).
Ensure half-yearly (unaudited) and annual (audited) reporting cycles are scheduled per para 6, unless APRA has issued a notice specifying different periods for the group (para 7).
Engage and schedule the Group Auditor early (paras 10 and note to para 6)
Engage the Group Auditor to plan the required system and control reviews and the limited assurance engagement well ahead of the annual audit timetable (para 10).
Confirm the scope of the Group Auditor’s testing is consistent with AUASB standards and GPS 310 requirements (para 10(b) and note to para 6).
Build or adapt systems, processes and controls (paras 10-11)
Design or map systems to capture off-balance sheet instruments, reconciliations, and the data fields required by Form GRF 114.3_G (para 4 and para 10).
Document policies and procedures for internal review and authorisation of data, and obtain Board and senior management sign-off (para 11).
Authorisation and role assignments (paras 12-14)
Appoint authorised submitters and document delegations such that submissions are authorised by the Principal Executive Officer or Chief Financial Officer (para 14).
Obtain and configure a digital certificate for the authorised officer or agent that meets APRA’s acceptability criteria and integrate digital signing into the Direct to APRA workflow (para 12).
Direct to APRA testing and technical readiness (para 5)
Register for, and test submissions through, Direct to APRA. Where Direct to APRA is not available, confirm the APRA-provided alternative submission method and test that route (para 5).
Agent arrangements and retention (para 13)
If engaging an agent to submit on behalf of the parent entity, document the agent relationship, require the agent to provide a signed copy of the completed form and maintain the completed copy in the parent entity’s records (para 13).
Assurance and audit deliverables (paras 10 and note to para 8)
Schedule the Group Auditor’s limited assurance work to produce the required assurance report(s) in time for lodgement, recognising the timing requirements in GRS 001 (para 10 and para 8 note).
Monitor APRA notices and tailor reporting as required (paras 7 and 15)
Establish a monitoring process for written notices from APRA that may change reporting periods or vary form requirements for the group (paras 7 and 15).
Maintain an internal change-log and impact assessment when APRA issues a notice requiring additional or different fields.
Apply for exemption from half-yearly reporting if appropriate (para 9)
If the parent entity prefers to be exempted from the half-yearly unaudited requirement, prepare a written application and supporting justification for APRA. Ensure the Board approves the application and that the application is tracked until APRA issues a written notice (para 9).
Transitional reporting checks (para 16)
Review historical reporting obligations to identify any transitional reporting periods that must still be reported under the old standard. Establish a process to comply with those obligations if they apply (para 16).
Records, retention and governance (paras 11 and 13)
Maintain an auditable trail of data inputs, reconciliations, authorisations, Group Auditor working papers and copies of the submitted forms. Ensure the Board and senior management approve and review the policies governing those records (para 11 and para 13).
Training and periodic review
Train staff involved in data gathering, controls and submission on the Standard’s requirements, Direct to APRA procedures, and the company’s authorisation policy. Periodically review systems and controls to ensure they remain compliant and auditable (para 10 and para 11).
Legal and regulatory mapping
Cross-check the reporting content and definitions with GPS 001 and GPS 310, and align the reporting outputs with the group’s statutory accounts and the Corporations Act-defined financial year (note after para 6 and para 17). Where uncertainty arises, seek advice from legal or regulatory counsel.
Contingency planning
Prepare contingency procedures for technical submission failures (Direct to APRA downtime), including how to engage APRA for alternative submission methods (para 5), and documented processes for urgent re-submissions if APRA issues a variation notice requiring additional information (paras 7 and 15).
Practical project timeline
Begin the compliance project at least one audit cycle ahead of the first submission date relevant to your group. Allow time for: systems mapping (2-3 months), Group Auditor scoping and engagement (3-6 months prior to year-end), Direct to APRA testing (1-2 months), board sign-offs and policy finalisation (1 month), and contingency testing.
By following these steps and tying each task to the paragraph references in the Standard, a parent entity can convert the Reporting Standard’s requirements into operational deliverables aligned with the audit calendar, APRA’s submission mechanics and the board’s governance duties.
If, having regard to the particular circumstances of a Level 2 insurance group, APRA considers it necessary or desirable to obtain information more or less frequently than as provided by subparagraph 6(a) or 6(b), APRA may, by notice in writing to the parent entity, change the reporting periods, or specify reporting periods, for the particular Level 2 insurance group.
The information required by this Reporting Standard in respect of a Level 2 insurance group must be provided to APRA:
(a) within the time stated in Reporting Standard GRS 001 Reporting Requirements (GRS 001); or
(b) in the case of information provided in accordance with paragraph 7, within the time specified by notice in writing.
Note: GPS 310 requires a Level 2 insurance group to ensure that its Group Auditor conducts a limited assurance review of the group’s annual accounts. Accordingly, the Group Auditor’s report(s) as required by GPS 310 (relating to the information required by paragraph 4) must be provided to APRA by the time specified in GRS 001 (unless an extension of time is granted under GRS 001).
On the written application of the parent entity of a Level 2 insurance group, APRA may by notice in writing to the parent entity exclude the requirement under subparagraph 6(a) to provide half yearly information.
Quality control
The information provided by the parent entity of a Level 2 insurance group under this Reporting Standard must be the product of systems, processes and controls that have been reviewed and tested by the Group Auditor of the Level 2 insurance group. This will require the Group Auditor to review and test the Level 2 insurance group’s systems, processes and controls designed to enable the group to report reliable financial information to APRA. This review and testing must be done on:
(a) an annual basis or more frequently if necessary to enable the Group Auditor to form an opinion on the reliability and accuracy of data; and
(b) at least a limited assurance engagement consistent with professional standards and guidance notes issued by the Auditing and Assurance Standards Board (AUASB) as may be amended from time to time, to the extent that they are not inconsistent with the requirements of GPS 310.
All information provided by the parent entity of a Level 2 insurance group under this Reporting Standard must be subject to systems, processes and controls developed by the Level 2 insurance group for the internal review and authorisation of that information. It is the responsibility of the Board and senior management of the parent entity of the Level 2 insurance group to ensure that an appropriate set of policies and procedures for the authorisation of data submitted to APRA is in place.
Authorisation
When an officer, or agent, of a parent entity of a Level 2 insurance group provides the information required by this Reporting Standard using the ‘Direct to APRA’ software it will be necessary for an officer, or agent, to digitally sign the relevant information using a digital certificate acceptable to APRA.
If a parent entity of a Level 2 insurance group provides the information required by this Reporting Standard through an agent who submits using the ‘Direct to APRA’ software, on the parent entity of the Level 2 insurance group’s behalf, the parent entity of the Level 2 insurance group must:
(a) obtain from the agent a copy of the completed form with the information provided to APRA; and
(b) retain the completed copy.
An officer, or agent, of a parent entity of a Level 2 insurance group who submits the information under this Reporting Standard for, or on behalf of, the parent entity of a Level 2 insurance group must be authorised by either:
(a) the Principal Executive Officer of the parent entity of the Level 2 insurance group; or
(b) the Chief Financial Officer of the parent entity of the Level 2 insurance group.
Variations
APRA may, by written notice to the parent entity of a Level 2 insurance group, vary the reporting requirements of Form GRF 114.3_G in relation to that Level 2 insurance group.
Transition
A parent entity of a Level 2 insurance group must report under the old reporting standard in respect of a transitional reporting period. For these purposes:
old reporting standard means the reporting standard revoked in the determination making this Reporting Standard (being the reporting standard which this Reporting Standard replaces); and
transitional reporting period means a reporting period under the old reporting standard:
(a) which ended before the date of revocation of the old reporting standard; and
(b) in relation to which the parent entity of the Level 2 insurance group was required, under the old reporting standard, to report by a date on or after the date of revocation of the old reporting standard.
Note: For the avoidance of doubt, if a parent entity of a Level 2 insurance group was required to report under an old reporting standard, and the reporting documents were due before the date of revocation of the old reporting standard, the parent entity of a Level 2 insurance group is still required to provide any overdue reporting documents in accordance with the old reporting standard.
Interpretation
In this Reporting Standard (including the attachments):
(a) unless the contrary intention appears, words and expressions have the meanings given to them in GPS 001; and
(b) APRA-authorised reinsurer means an insurer carrying on reinsurance business. For the purposes of this definition, a Lloyd’s underwriter as defined under the Insurance Act is an APRA-authorised reinsurer if it carries on reinsurance business. The Australian Reinsurance Pool Corporation is also an APRA-authorised reinsurer for the purposes of this definition;
capital standards means the prudential standards which relate to capital adequacy as defined in GPS 001;
Chief Financial Officer means the chief financial officer of the parent entity of the Level 2 insurance group, by whatever name called;
financial year means the financial year (within the meaning of the Corporations Act 2001) of the parent entity of the Level 2 insurance group;
foreign insurer means a foreign general insurer within the meaning of the Insurance Act;
Note: A reference to a ‘branch’ or ‘branch operation’ is a reference to the Australian operations of a foreign insurer.
general instruction guide refers to the general Instruction guide set out in Attachment A of GRS 001;
Group Auditor has the meaning given in GPS 310;
Insurance Act means the Insurance Act 1973;
insurer means a general insurer within the meaning of section 11 of the Insurance Act;
Note: In the forms and instructions, a reference to an ‘authorised insurer’, ‘authorised insurance entity’ or ‘licensed insurer’ is a reference to an insurer, and a reference to an ‘authorised reinsurance entity’ is a reference to an insurer whose business consists only of undertaking liability by way of reinsurance.
non-APRA authorised reinsurer means any reinsurer that is not an APRA-authorised reinsurer;
Principal Executive Officer means the current principal executive officer of the entity, regardless of title, and whether or not he or she is a member of the governing board of the entity; and
reporting period means a period mentioned in subparagraph 6(a) or 6(b) or, if applicable, paragraph 7.
Off-balance Sheet Business (Level 2 Insu Off-balance Sheet Business (Level 2 Insurance Group)
Off-balance Sheet Business (Level 2 Insurance Group)
Objective of this Reporting Standard
This Reporting Standard sets out the requirements for the provision of information to APRA relating to a Level 2 insurance group’s off-balance sheet business.
It includes Form GRF 114.3_G Off-balance Sheet Business (G) and associated specific instructions and must be read in conjunction with the general instruction guide.
Authority
This Reporting Standard is made under section 13 of the Financial Sector (Collection of Data) Act 2001.
Purpose
Information collected in Form GRF 114.3_G Off-balance Sheet Business (G) (GRF 114.3_G) is used by APRA for the purpose of prudential supervision, including assessing compliance with the capital standards.
Application and commencement
This Reporting Standard applies to a parent entity of a Level 2 insurance group as defined in Prudential Standard GPS 001 Definitions (GPS 001). This Reporting Standard applies for reporting periods ending on or after 1 July 2022. The parent entity of a Level 2 group is required to ensure that each requirement in this Reporting Standard is complied with.
Information required
The parent entity of a Level 2 insurance group must provide APRA with the information required by Form GRF 114.3_G in respect of the Level 2 insurance group for each reporting period.
Forms and method of submission
The information required by this Reporting Standard must be given to APRA in electronic format using the ‘Direct to APRA’ application or, where ‘Direct to APRA’ is not available, by a method notified by APRA prior to submission.
Note: The ‘Direct to APRA’ application software may be obtained from APRA.
Reporting periods and due dates
Subject to paragraph 7, the parent entity of a Level 2 insurance group must provide the information required by this Reporting Standard:
(a) in respect of the first half year based on the financial year of the Level 2 insurance group on an unaudited basis; and
(b) in respect of each financial year of the Level 2 insurance group on an audited basis.
Note: The annual information required by paragraphs 4, 5 and 6(b), together with certain annual information required by other reporting standards, will form part of the Level 2 insurance group’s annual accounts within the meaning of GPS 001. Prudential Standard GPS 310 Audit and Related Matters (GPS 310) contains the relevant provisions governing audits.
If, having regard to the particular circumstances of a Level 2 insurance group, APRA considers it necessary or desirable to obtain information more or less frequently than as provided by subparagraph 6(a) or 6(b), APRA may, by notice in writing to the parent entity, change the reporting periods, or specify reporting periods, for the particular Level 2 insurance group.
The information required by this Reporting Standard in respect of a Level 2 insurance group must be provided to APRA:
(a) within the time stated in Reporting Standard GRS 001 Reporting Requirements (GRS 001); or
(b) in the case of information provided in accordance with paragraph 7, within the time specified by notice in writing.
Note: GPS 310 requires a Level 2 insurance group to ensure that its Group Auditor conducts a limited assurance review of the group’s annual accounts. Accordingly, the Group Auditor’s report(s) as required by GPS 310 (relating to the information required by paragraph 4) must be provided to APRA by the time specified in GRS 001 (unless an extension of time is granted under GRS 001).
On the written application of the parent entity of a Level 2 insurance group, APRA may by notice in writing to the parent entity exclude the requirement under subparagraph 6(a) to provide half yearly information.
Quality control
The information provided by the parent entity of a Level 2 insurance group under this Reporting Standard must be the product of systems, processes and controls that have been reviewed and tested by the Group Auditor of the Level 2 insurance group. This will require the Group Auditor to review and test the Level 2 insurance group’s systems, processes and controls designed to enable the group to report reliable financial information to APRA. This review and testing must be done on:
(a) an annual basis or more frequently if necessary to enable the Group Auditor to form an opinion on the reliability and accuracy of data; and
(b) at least a limited assurance engagement consistent with professional standards and guidance notes issued by the Auditing and Assurance Standards Board (AUASB) as may be amended from time to time, to the extent that they are not inconsistent with the requirements of GPS 310.
All information provided by the parent entity of a Level 2 insurance group under this Reporting Standard must be subject to systems, processes and controls developed by the Level 2 insurance group for the internal review and authorisation of that information. It is the responsibility of the Board and senior management of the parent entity of the Level 2 insurance group to ensure that an appropriate set of policies and procedures for the authorisation of data submitted to APRA is in place.
Authorisation
When an officer, or agent, of a parent entity of a Level 2 insurance group provides the information required by this Reporting Standard using the ‘Direct to APRA’ software it will be necessary for an officer, or agent, to digitally sign the relevant information using a digital certificate acceptable to APRA.
If a parent entity of a Level 2 insurance group provides the information required by this Reporting Standard through an agent who submits using the ‘Direct to APRA’ software, on the parent entity of the Level 2 insurance group’s behalf, the parent entity of the Level 2 insurance group must:
(a) obtain
This is an opening excerpt, not the complete document.