Financial Sector (Collection of Data) (reporting standard) determination No. 25 of 2021

This Determination, made by a delegate of APRA on 30 July 2021, revokes the prior Financial Sector (Collection of Data) (reporting standard) determination No. 2 of 2019 and replaces Reporting Standard ARS 720.0 ABS/RBA Statement of Financial Position with a new Reporting Standard ARS 720.0 in the form set out in the Schedule. The Determination is made under paragraph 13(1)(a) of the Financial Sector (Collection of Data) Act 2001 and takes effect on registration on the Federal Register of Legislation, with the Reporting Standard applying for reporting periods ending on or after 30 September 2021 (see Authority, commencement and para 6). The instrument explicitly states that the Schedule comprises the new Reporting Standard ARS 720.0 (Schedule, Reporting Standard ARS 720.0).

Mechanically, the Reporting Standard prescribes two reporting forms: ARF 720.0A (Standard) and ARF 720.0B (Reduced), together with detailed instructions and line-item definitions for a comprehensive balance-sheet style submission on a domestic books consolidation basis (paras 2, 7 and Schedule). It sets scope and thresholds for which entities must submit which form (paragraph 4 table and explanatory notes), prescribes reporting frequency and due dates (paras 9 and 10), requires electronic submission via APRA’s Direct to APRA (D2A) application or another APRA-notified method (para 8), and requires digital signing of submissions using a digital certificate or APRA-acceptable digital identity credential (para 15). Quality control and assurance requirements are specified, requiring external auditor review and testing of systems, processes and controls in accordance with Prudential Standard APS 310 for ADIs or Reporting Standard RRS 710.0 for RFCs (para 13), and internal review and authorisation processes (para 14). APRA retains administrative discretions: it may alter thresholds for particular entities (para 5), change reporting periodicity for particular entities (para 11), grant extensions to due dates (para 12), and make minor variations to forms or instructions for technical corrections without changing substantive requirements (paras 16-17). The Standard requires compliance with specific Australian Accounting Standards in many items and refers to ARS 701.0 for definitions used across the Economic and Financial Statistics collection (paras 2, 3 and 18).

The official rationale given in the Reporting Standard is that data collected via ARF 720.0A/B is used by the Australian Bureau of Statistics and the Reserve Bank of Australia for compilation of National Accounts and monetary and credit aggregates, and may also be used by APRA for prudential and publication purposes (para 2). The instrument therefore functions as a data-collection and standardisation tool that operationally dictates what balance-sheet information ADIs and qualifying RFCs must supply, how they must format it, and the assurance and submission channels required.

The Reporting Standard organises the balance-sheet data collection into two forms, a Standard form (ARF 720.0A) and a Reduced form (ARF 720.0B), each with a detailed set of items and instructions that match a conventional statement of financial position split into Sections A (Assets), B (Liabilities) and C (Shareholders’ Equity) (Schedule). Core concepts include:

• Scope and thresholds: Paragraph 4 sets a matrix of institution classes against which the Standard or Reduced form applies. ADI Reporting Category B must complete ARF 720.0A; ADI Category A may be required to complete ARF 720.0B if total assets are at or above $200 million; RFCs complete ARF 720.0A if total assets are at or above $50 million. APRA can alter these thresholds for particular entities and will notify them in writing (para 5). The notes to paragraph 9 specify how "total assets" is to be measured for ADIs (item 13 (column 1) on ARF 720.0A/B or item 11 (column 1) on ARF 323.0 as at 31 December of the prior calendar year) and for RFCs (item 13 as at the last day of the RFC’s prior financial year).

• Reporting level and basis: Reporting is required on a domestic books consolidation basis (para 7). Items are to be reported in Australian dollars or AUD equivalent converted under AASB 121 (Values sections and multiple item instructions) and as whole dollars. The Standard specifies SBR (Standard Business Reporting) accounting types for items and derived items flagged in the forms.

• Frequency and timing: ADIs report monthly; RFCs with total assets ≥ $400 million report monthly; RFCs with total assets < $400 million report annually (para 9). All submissions are due within 10 business days after the end of the reporting period, subject to APRA-granted extensions (para 10 and 12).

• Data content and reconciliation: The Standard requires granular reporting across conventional balance sheet categories (currency, deposits, securities for trading and not for trading, loans and finance leases, property, PPE, intangibles, intra-group assets and liabilities, securitised assets, detailed categories of debt securities and equity securities, deferred fees, provisions, and shareholders’ equity). Several items are derived items and reconciliation across supplementary ARFs (720.1, 720.2, 720.3, 720.4-720.7) is required; the form instructions state that totals on those forms reconcile to ARF 720.0A/B.

• Quality control and external assurance: Systems and processes used to produce the reported information must be reviewed and tested by the external auditor of the ADI or RFC in accordance with Prudential Standard APS 310 (ADIs) or Reporting Standard RRS 710.0 (RFCs). The review and testing frequency is annual or more frequent if required by the external auditor to form an opinion on accuracy and reliability (para 13). Internal review and authorisation procedures are also mandated (para 14).

The Determination explicitly applies to authorised deposit-taking institutions (ADIs) and registered financial corporations (RFCs) as those terms are used in the Financial Sector (Collection of Data) Act 2001 (see Interpretation and para 4). Which specific reporting form an entity must supply is determined by its class and asset-size thresholds in paragraph 4’s table: ADI Reporting Category B entities are required to submit ARF 720.0A (Standard); ADI Reporting Category A entities are required to submit ARF 720.0B (Reduced) if their total assets are at least $200 million; RFCs must submit ARF 720.0A if total assets are at least $50 million. The Reporting Standard also permits APRA to apply a different threshold, or a higher threshold, to a particular ADI or RFC and to notify the entity in writing (para 5). The footnote at the end of the Schedule makes clear that APRA may accept an exemption from one form on condition that an ADI provides the alternative form (for example, exempting an ADI from ARF 720.0A if it provides ARF 720.0B) under paragraph 16(1)(b) of the Financial Sector (Collection of Data) Act 2001.

All affected entities must report on a domestic books consolidation (para 7) and must submit required information electronically using APRA’s D2A application or another APRA-notified web-based solution (para 8). The “reporting period” and frequency are determined by the entity type and size: ADIs monthly; RFCs monthly if assets ≥ $400 million, otherwise annually as defined in the Corporations Act (para 9). The form instructions repeatedly require exclusion or separate treatment of intra-group assets and liabilities (items 1-11 exclude intra-group items, to be reported in items 12 and 13, and Section B requires intra-group liabilities only in items 20 and 21), which will particularly affect entities within financial groups that have significant intra-group exposures or securitisation special purpose vehicles.

Internal governance and external audit functions are directly implicated. Paragraph 13 requires external auditors to review and test systems, processes and controls that produce the information to APRA and to perform that review at least annually or more frequently where necessary. Paragraph 14 requires the entity to maintain internal systems, processes and controls for internal review and authorisation. Paragraph 15 requires an officer or agent to digitally sign submissions using credentials acceptable to APRA. Entities therefore need IT capability to submit, identity management for digital certificates, and audit processes to support auditor assurance, as part of the compliance chain.

Finally, the data is collected for ABS and RBA statistical uses and may be used by APRA for prudential and publication purposes (para 2). That means, in practice, that both statistical agencies and the prudential regulator will rely on the submissions. Entities with specialised balance-sheet features,such as securitisation activity (items 13.1 and 20.1), significant foreign-denominated assets or liabilities (various of which require FX equivalents), trading books, derivatives, or complex intra-group arrangements,will face the largest reporting, mapping and assurance effort.

Duties imposed by the Reporting Standard are procedural, definitional and assurance-related. Key duties:

• Provide specified information: An ADI or RFC to which the Standard applies “must provide APRA with the information required by this Reporting Standard ARF 720.0A/B for each reporting period on a domestic books consolidation” (para 7). The forms and the detailed item-level instructions in the Schedule prescribe the exact content and format.

• Submit electronically and sign: The information must be submitted electronically using APRA’s D2A application or another APRA-notified method (para 8). The submitting officer or agent must digitally sign the relevant information using a digital certificate or other digital identity credential acceptable to APRA (para 15).

• Observe reporting frequency and due dates: Entities must submit according to the reporting periods in paragraph 9 (monthly for ADIs and certain RFCs; annual for small RFCs), and within 10 business days after end of the reporting period (para 10). APRA may change reporting frequency for a particular entity where warranted (para 11) and may grant extensions (para 12).

• Maintain assurance and internal controls: The entity must ensure that the information is the product of systems, processes and controls reviewed and tested by the external auditor in accordance with Prudential Standard APS 310 for ADIs or Reporting Standard RRS 710.0 for RFCs (para 13). The entity must also maintain internal systems, processes and controls developed for internal review and authorisation of reported information (para 14).

• Follow specified accounting and reporting rules: Unless the instruction says otherwise, the information must comply with Australian Accounting Standards (see multiple instructions and the Values and Reporting basis sections). Specific references include AASB 121 for currency conversion, AASB 119 for defined benefit assets and liabilities, AASB 16 for right-of-use assets and lease liabilities, and references to AASB 9, 132, 7 and AASB 2 concerning hedge/reserve and share-based payment treatments.

• Exclude or report intra-group items in specified lines: Items 1-11 exclude intra-group assets (report in items 12-13); liabilities due to related parties are to be included only in items 20-21 (multiple item instructions). Loans and finance leases must be reported gross of collective and individual provisions (instructions in multiple sections), which differs from presentation under Australian Accounting Standards.

The Determination text does not itself prescribe civil or criminal penalties or the enforcement mechanisms for non-compliance. It is an exercise of APRA’s power under paragraph 13(1)(a) of the Financial Sector (Collection of Data) Act 2001 to make reporting standards and to declare their commencement under section 15 (see Authority and opening clauses). Enforcement provisions, penalties for failure to comply and the processes for notices or directions are not included in the schedule or instructions of this Determination. Those matters are addressed in the principal Act (the Financial Sector (Collection of Data) Act 2001) and in general legislative enforcement frameworks.

What the Determination does set out are administrative levers APRA will use to manage compliance and operational implementation:

• Timeframes and extensions: Submissions are due within 10 business days of the period end (para 10); APRA may grant extensions in writing (para 12). APRA may also change reporting frequency for particular entities on written notice (para 11). These provisions operate as internal compliance management tools that can moderate strict enforcement where APRA decides to exercise discretion.

• Assurance requirements: Paragraph 13 conditions the acceptability of the reported information on external auditor review and testing. The requirement to have external audit assurance in accordance with Prudential Standard APS 310 (for ADIs) or Reporting Standard RRS 710.0 (for RFCs) effectively makes audit attestations part of APRA’s compliance architecture. Failure to meet auditor assurance requirements would be a matter APRA would treat under the Act’s compliance mechanisms.

• Notification obligations: APRA must notify entities in writing when making threshold determinations (para 5) and when making minor variations to forms or instructions (para 17). Written notices form part of the administrative record and are mechanisms for communicating compliance obligations and changes.

Because the Determination does not itself set penalties, a practitioner assessing enforcement outcomes must consult the Financial Sector (Collection of Data) Act 2001 for the statutory consequences of failing to comply with a reporting standard issued under the Act. The Reporting Standard, however, builds in procedural safeguards (extensions, changes to periodicity, written notifications and the ability to issue technical variations) that APRA can use administratively before resorting to statutory enforcement. Entities should therefore align internal compliance risk frameworks to both meet the Reporting Standard and to be able to respond to APRA notices and auditor findings promptly.

The Reporting Standard is embedded in and cross-references a network of legislative and accounting instruments:

• Financial Sector (Collection of Data) Act 2001: The Determination is made under paragraph 13(1)(a) of that Act. The Determination uses section 15 of the Act to declare the commencement date for the Reporting Standard. The Act is therefore the primary statutory authority; enforcement and broader statutory obligations for reporting are governed by it.

• Acts Interpretation Act 1901: The delegate invoked subsection 33(3) of the Acts Interpretation Act 1901 in making the Determination (opening clauses), a standard interpretive mechanism for instrument-making.

• ARS 701.0: The Reporting Standard is an Economic and Financial Statistics Reporting Standard for the purposes of ARS 701.0 ABS/RBA Definitions for the EFS Collection (para 3). Terms defined in ARS 701.0 are used throughout ARS 720.0 and are indicated in the document (para 18). This creates a definitional linkage and ensures consistency across APRA’s EFS collection.

• Prudential Standard APS 310 and Reporting Standard RRS 710.0: External auditor review and testing required under para 13 must be performed as set out in APS 310 for ADIs and RRS 710.0 for RFCs. Those instruments therefore supply the audit scope and expectations that undergird the assurance duty in ARS 720.0.

• Australian Accounting Standards: The forms and instructions require reporting to comply with Australian Accounting Standards unless otherwise stated (see Values and many item-specific instructions). Specific references include:

  • AASB 121 The Effects of Changes in Foreign Exchange Rates for FX conversion (Values and item instructions).
  • AASB 119 for defined benefit assets and liabilities reporting (items 10.8, 18.2-18.3).
  • AASB 16 Leases for right-of-use assets and lease liabilities (items 10.12.1 and 18.11/18.12.6).
  • AASB 9, AASB 132, and AASB 7 for cash flow hedge reserves and associated disclosures (item 23.5 references).
  • AASB 2 for share-based payment reserves (item 23.6). These references ensure that the statistical reporting maps to accounting categories established under Australian GAAP, while also requiring some departures for statistical purposes (for example, loans reported gross of collective and individual provisions).

The Determination itself records a single immediate amendment history item: it revokes Financial Sector (Collection of Data) (reporting standard) determination No. 2 of 2019 and replaces Reporting Standard ARS 720.0 made under that prior Determination with this new Reporting Standard ARS 720.0 (opening clauses (a) and (b)). The instrument is dated 30 July 2021 and commences on the day it is registered on the Federal Register of Legislation (commencement clause and para 6). The Reporting Standard applies for reporting periods ending on or after 30 September 2021 (para 6).

Beyond the explicit revocation of the 2019 Determination, the Reporting Standard builds in mechanisms by which APRA can effect minor, operational-level changes without a further formal instrument: APRA may make minor variations to forms and instructions to correct technical, programming or logical errors or to clarify application without changing substantive requirements, and must notify affected ADIs or RFCs in writing if it does so (paras 16-17). That creates a practical amendment pathway for technical adjustments.

APRA’s discretion under paragraph 5 to determine that a threshold, or a higher threshold, than that specified in paragraph 4 will apply to a particular ADI or RFC functions as an entity-specific amendment power: it permits APRA to vary the application of the Standard to individual entities by written notification. Paragraph 11 likewise allows APRA, by notice in writing, to change reporting periods for a particular entity to require more or less frequent reporting. The schedule’s footnote and closing note show APRA may exempt an ADI from an obligation under ARF 720.0A on the condition that it provides ARF 720.0B, exercising powers under paragraph 16(1)(b) of the Act. These provisions represent administrative amendment channels rather than formal legislative amendment processes and therefore reduce the need for repeated instrument-making for operational changes.

No other amendments, schedules of transition, or staged rollout periods are included in the text beyond the commencement date and the revocation of the 2019 instrument. Practitioners should therefore track APRA written notices and minor variations (paras 16-17 and para 5 written notices) for subsequent operational changes rather than expecting further legislative instruments for every technical change.

The Determination and its Schedule do not contain any references to prior litigation, judicial decisions or administrative tribunal proceedings. The text does not cite cases, nor does it record any judicial or administrative review outcomes. The instrument is an administrative reporting instrument made under the Financial Sector (Collection of Data) Act 2001; its contents are prescriptive operational requirements rather than adjudicative decisions. There is therefore no litigation history contained within the instrument itself to report.

For practitioners concerned with legal risk or dispute, any litigation or administrative challenge would likely engage provisions of the Financial Sector (Collection of Data) Act 2001 (for example, judicial review of APRA decision-making under that Act) or general administrative law remedies; however, the Determination does not describe or reference such remedies. If a party contemplates litigation or administrative review regarding APRA’s exercise of its powers under this Determination,such as a challenge to threshold determinations, variations to reporting frequency, or the application of minor variations,advice should be sought that examines the principal Act, APRA’s procedural fairness in issuing notices, and any relevant common law or statutory review avenues. The Reporting Standard itself contains no litigation record.

Several practical and legal pitfalls are embedded in the Reporting Standard that can create compliance risk, operational friction, or reporting errors if not anticipated:

• Scope determination depends on precise measurement of "total assets": The forms require entities to determine which form applies based on total assets measured in specific ways: for ADIs, item 13 (column 1) on ARF 720.0A/B or item 11 (column 1) on ARF 323.0 as at 31 December of the prior calendar year; for RFCs, item 13 (column 1) on ARF 720.0A as at the last day of the RFC’s prior financial year (note to para 9). Misapplying the measurement timing or source can cause an entity to use the wrong form or reporting frequency.

• Loans and finance leases reported gross of provisions: The instruction to report credit outstanding for loans and finance leases gross of collective provisions and individual provisions departs from typical accounting presentation (multiple instances, “Counterparties” notes and loan instructions). Entities commonly work off AASB-presented net figures; mapping to gross figures requires ledger-level granularity and reconciliations to provisioning schedules.

• Intra-group exclusion rules and securitisation mapping: Items 1-11 and 14-19 exclude intra-group assets and liabilities, which must be reported separately in items 12-13 and 20-21. Firms with complex group structures, related-party repo and SPV arrangements, or self-securitisation must prepare detailed intra-group mappings. Item 13.1 and item 20.1 require matching securitised assets to SPV liabilities, which can be technically challenging where derecognition rules or partial securitisations are involved.

• Derived items and reconciliation across multiple ARFs: Many fields are derived items (shaded in grey per instructions) and must reconcile across ARF 720.1/720.2/720.3 and supplementary ARFs (720.4-720.7). If source systems feed different ARFs, timing and aggregation differences can produce reconciliations issues and trigger APRA queries.

• Currency conversion and foreign-denominated breakdowns: Multiple items require reporting “of which denominated in FX (AUD equivalent)” and conversion in accordance with AASB 121. Entities must ensure consistent FX translation rules and cut-off dates across accounting and reporting systems.

• Electronic submission and digital signature requirements: Submissions must be made via D2A or an APRA-notified method (para 8) and digitally signed using a credential acceptable to APRA (para 15). Entities must have access to D2A or implement interoperability with APRA’s alternate method, and must manage digital identity certificates and signing processes. The D2A application is obtainable from APRA (para 8 note), but integrating reporting workflows can require IT project work.

A practical compliance roadmap, grounded in the Reporting Standard’s text, requires legal, accounting and operational steps:

1. Scope and form selection

   • Determine whether the entity is an ADI or RFC as defined in the Financial Sector (Collection of Data) Act 2001 (Interpretation and para 4).
   • Measure “total assets” using the specified source and date: for ADIs, item 13 (column 1) on ARF 720.0A/B or item 11 (column 1) on ARF 323.0 as at 31 December of the prior calendar year; for RFCs, item 13 (column 1) on ARF 720.0A as at the last day of the prior financial year (note to para 9). That determines whether the entity must complete ARF 720.0A or ARF 720.0B.

2. Reporting cadence and due dates

   • For ADIs: prepare to report monthly unless APRA has notified otherwise (para 9(a)). For RFCs: determine monthly reporting if assets ≥ $400 million, otherwise annual reporting as per Corporations Act definition (para 9(b)-(c)).
   • Calendarise submission deadlines: submissions are due within 10 business days after the end of the reporting period (para 10). Seek APRA extensions in writing if needed (para 12).

3. Data mapping and system readiness

   • Map general ledger and sub-ledger balances to the ARF line items. Pay attention to:
     • Loans and finance leases to be reported gross of collective and individual provisions (loan instructions and repeated notes).
     • Exclusion of intra-group assets and liabilities from items 1-11 and 14-19 and reporting of those in items 12-13 and 20-21 (Section A and B instructions).
     • Derived items: implement automated calculations per the form instructions (many items are derived; treat shading as instruction).
     • Currency conversion per AASB 121 for all FX-denominated reporting (Values section and multiple items).
     • Reconciliation requirements to ARF 720.1A/B, 720.2A/B, 720.3 and supplementary ARFs (instructions).
   • Ensure systems can produce whole-dollar values and SBR-coded output with accounting-type indicators (SBR instructions and various item notes).

4. Electronic submission and digital identity

   • Obtain and configure APRA’s D2A application or implement the method APRA notifies in writing (para 8). Note: APRA provides D2A (para 8 note).