Financial Sector (Collection of Data) (reporting standard) determination No. 26 of 2015 - SRS 802.0 - Fund Profile

The Reporting Standard centralises a set of discrete concepts that determine what must be collected, how and when. The instrument’s own definitions and the instructions are the primary source for those meanings (para 17; instructions and glossary). Key concepts are:

• RSE licensee, RSE and reporting population. The Reporting Standard applies to a registrable superannuation entity (RSE) licensee that has SAFs or SMADFs in its business operations. The Schedule makes clear that reporting is at the RSE licensee level in respect of all SAFs and SMADFs within its business operations (para 3; footnote 1). The glossary repeats statutory references to section 10(1) of the SIS Act for RSE and RSE licensee (Interpretation).
• Small APRA fund (SAF) and single member approved deposit fund (SMADF). These are defined by reference to the SIS Act (para 17 and glossary): SAF is a regulated superannuation fund with fewer than five members; SMADF is an approved deposit fund with one member (para 17; glossary).
• Reporting basis distinctions (stock vs flow). Several items have mixed reporting bases. For example, Item 1 (membership and assets) requires some columns reported “as at the end of the reporting period” (stock) and others “with respect to transactions that occurred during the reporting period” (flows) (Item 1 reporting basis in the instructions). Item 2 (ORFR reserve investments) and multiple items set out whether columns are end-of-period or transaction-based (instructions for Item 1, Item 2 and the item-level reporting basis statements).
• Units and measurement. The standard prescribes Australian Accounting Standards as the reporting basis unless otherwise specified, and sets units explicitly: most monetary items are reported in thousands of dollars or thousands for particular columns, while certain counts are reported as whole numbers with no decimals (reporting basis and unit of measurement; several item-level instructions).
• Operational Risk Financial Requirement (ORFR) concepts. Item 2 collects investment-option level detail for ORFR reserves where the ORFR target amount is met by a reserve rather than trustee capital. The instructions explain ORFR target amount, ORFR trustee capital, and ORFR reserve and reference Prudential Standard SPS 114 (Item 2 and glossary).
• Service-provider and outsourcing fields. Items 3 and 4 separate services provided by the RSE licensee itself (item 3) from those provided by external providers (item 4). Item 4 requires classification of service providers as associate or non-associate and flags for material business activity and offshoring; the instructions tie these terms to Prudential Standard SPS 231 (Item 4; glossary; instructions on notifying APRA under SPS 231).
• Transactions with associates. Items 5 and 6 collect income and expense transactions with associates by relationship type (RSE licensee, connected entity, parent entity, director, associate of director, etc.). The instructions specify when aggregation of transactions with associates is permitted and require separate lines where characteristics differ (Items 5 and 6, and the aggregation rules).
• Insurance clusters. Item 7 requires reporting insurance policies that have been in force during the reporting period aggregated by insurer into “clusters” and capturing both counts (member accounts with cover) and aggregate cover amounts by insurance type, with premiums and rebates reported as transactions (Item 7, instructions).
• Fees, rebates and activity fees. Items 8-11 collect fees (excluding activity fees), fee rebates/discounts, activity fees and activity-fee rebates and discounts, with breakdowns by source of payment (member, employer sponsor, reserve, RSE licensee) and instruction to report activity fees in Item 10 (Items 8-11 and the item instructions).
• Quality control and assurance. The RSE auditor must review and test the systems and internal controls that produce SRF 802.0 data at least annually and perform at least a limited assurance engagement consistent with relevant professional standards and SPS 310 to support the reliability and accuracy of the data (para 11; instructions referencing SPS 310 and auditing standards).
• Authorisation and submission controls. Submissions must be electronic via D2A (para 6); digitally signed with a certificate acceptable to APRA (para 13); submitted only by an officer or agent authorised by the CEO or CFO (para 15); and if submitted by an agent, the RSE licensee must obtain and retain a copy of the completed form (para 14).

The standard therefore combines data-model design (fields, units, bases), process controls (auditor review, authorisation, digital signature, retention), and APRA discretion (extensions, variations, changes to reporting frequency). The stated purpose is prudential supervision and publication (para 2), and the instrument cross-references prudential obligations (SPS 114 on ORFR, SPS 231 on outsourcing, SPS 310 on audit and related matters) that affect how specific items are interpreted and used (instructions and glossary).

Primary obliged entity. The RSE licensee is the legal entity obliged to provide the data required by SRF 802.0. Paragraph 3 specifies that the Reporting Standard applies to “each registrable superannuation entity (RSE) licensee of a small APRA fund (SAF) or a single member approved deposit fund (SMADF) in respect of all SAFs and SMADFs within its business operations.” The instructions’ footnote clarifies the breadth of “RSE licensee’s business operations” to include all activities as an RSE licensee and related activities to the extent they affect RSE activity (footnote 1). An RSE licensee that does not have SAFs or SMADFs is not required to report (footnote 1).

Internal roles within the RSE licensee. The standard creates explicit duties or operational responsibilities for several internal roles: the Board and senior management must ensure appropriate policies and procedures authorise information submitted to APRA (para 12). The CEO or CFO must authorise officers or agents who submit information (para 15). The RSE licensee must ensure internal systems, processes and controls are in place for review and authorisation (para 12). The RSE auditor must review and test those systems and perform limited assurance (para 11).

External participants captured in reporting. The form requires detailed information about external service providers (item 4) and income/expense transactions with associates (items 5 and 6), so external entities that act as accountants, administrators, custodians, investment managers, lawyers, platform providers, insurers and others will be identified and their commercial relationships recorded (items 3-4; glossary of roles). Insurers that provide policies to SAF/SMADF members are captured in the insurance cluster reporting (item 7). External auditors and professional indemnity insurers are also listed.

Third-party agents and submitters. The RSE licensee may use an agent to submit via D2A; where an agent submits, the licensee must obtain and retain the completed copy (para 14). The submitter must digitally sign using an APRA-acceptable certificate (para 13). The authorised submitter must be endorsed by the CEO or CFO (para 15).

Auditors and assurance providers. The RSE auditor has mandated tasks under the Reporting Standard: review and test systems, procedures and internal controls that produce the reported information, on an annual basis or more frequently as necessary, and perform limited assurance consistent with professional standards and guidance notes and SPS 310 (para 11).

Who bears the costs. The RSE licensee bears the operational and administrative costs: data extraction (accounting systems to produce items in specified units and reporting bases), audit and assurance costs, digital certificate procurement and maintenance, staff time to collate service-provider and associate transaction data, and any system changes to populate the form. The instructions require Australian Accounting Standards as the reporting basis (unless otherwise specified), which can require accounting teams and reconciliations to the financial statements (instructions: reporting basis and unit of measurement).

Who decides. APRA decides the reporting content and mechanics, including the possibility of written notices to change reporting frequency for particular licensees (para 8), written variation of reporting requirements (para 16), and extensions of due dates (para 10). APRA also determines acceptable digital certificates and the electronic submission platform (para 6; para 13). The instrument is made under APRA’s statutory collection powers (para 1; Authority).

Indirect behavioural effects. The form compels RSE licensees to collect granular information about outsourcing arrangements (item 4), associate transactions (items 5-6), and insurance offerings (item 7). That creates an incentive for RSE licensees to document and monitor service-provider relationships, offshoring practices, materiality of outsourced activities and associated fees in greater detail than they otherwise might for internal management reporting. The instructions explicitly note SPS 231 outsourcing notification requirements and that SRF 331.0 is not a substitute for notifying APRA under SPS 231, which preserves the separate compliance obligations for outsourcing (instructions under Details of services).

Statutory and instrument-level duties

• Duty to report the information in SRF 802.0 for each reporting period: paragraph 5 requires the RSE licensee to provide APRA with the information required by SRF 802.0 in respect of each reporting period.
• Duty to use electronic submission: paragraph 6 requires submissions in electronic format using the Direct to APRA application (D2A), or by a method APRA notifies in writing where D2A is not available.
• Duty on timing: paragraphs 7-9 set the reporting frequency and due dates. The default reporting frequency is each year of income (para 7). The report must be provided within three months after the end of the year of income to which the information relates (para 9(a)). APRA may change the reporting periods for a particular RSE licensee by written notice (para 8).
• Duty of quality control and auditor involvement: paragraph 11 mandates the RSE auditor to review and test the RSE licensee’s systems, procedures and internal controls for reliable reporting on at least an annual basis and to perform at least a limited assurance engagement consistent with auditing standards and SPS 310.
• Duty of internal authorisation and retention: paragraph 12 makes the Board and senior management responsible for ensuring appropriate policies and procedures for authorisation are in place. Paragraph 14 requires the RSE licensee to obtain and retain a copy of the completed form where an agent submits on the licensee’s behalf.
• Duty of authorised submitter and digital signature: paragraph 13 requires digital signing of submissions using a certificate acceptable to APRA. Paragraph 15 requires the submitter to be authorised by the CEO or CFO.
• Duty to follow item-level instructions and units: the attached SRF 802.0 instructions require reporting in specified units and bases (thousands of dollars or whole numbers, Australian Accounting Standards) and provide detailed field-by-field rules (instructions).

APRA’s procedural rights and discretions

• Right to alter reporting frequency: paragraph 8 allows APRA, by written notice, to change the reporting periods for a particular RSE licensee.
• Right to vary reporting requirements: paragraph 16 allows APRA to vary the reporting requirements of SRF 802.0 in relation to any RSE licensee by written notice.
• Right to grant extensions: paragraph 10 allows APRA, in writing, to grant an extension to a due date.
• Right to require digital certificate standards and D2A usage: paragraph 6 and 13 give APRA practical control over the electronic submission and authentication requirements.

Assurance and audit obligations

• The RSE auditor must perform review and testing of systems, processes and internal controls designed to enable reliable reporting and must carry out at least a limited assurance engagement consistent with professional standards and guidance notes issued by the Auditing and Assurance Standards Board, to the extent they are not inconsistent with SPS 310 (para 11).

Information retention and authorisation duties

• The RSE licensee must retain copies of completed forms submitted by an agent and ensure internal review and authorisation systems (paras 12, 14). The CEO/CFO must authorise submitters (para 15).

Data-use statements and purpose

• APRA states the information collected is used for prudential supervision and publication (para 2). That is the purpose articulated in the Schedule, and it is the declared use APRA relies on in prescribing the fields and controls.

What the instrument does not itself do

• The Determination does not itself set out civil or criminal penalties for non‑compliance. Enforcement consequences, if any, would arise under the Act or other applicable legislation and are not specified in this Determination (the Determination does not specify penalties or enforcement mechanisms beyond APRA’s procedural powers such as granting extensions and varying requirements; see paras 8, 10 and 16).

The Reporting Standard defines duties and process controls but does not itself create a schedule of penalties or detailed enforcement mechanisms. The Determination is made under the Financial Sector (Collection of Data) Act 2001 (para 1; Authority). That Act contains APRA’s statutory data-collection powers and (separately) provisions that deal with non-compliance; however, the text of those enforcement provisions is not reproduced in this Determination. The instrument focuses on reporting mechanics, assurance and APRA’s administrative discretions.

What the Determination does provide about APRA’s administrative enforcement levers:

• APRA can modify reporting requirements and frequency by written notice (paras 8 and 16). These are administrative tools that allow APRA to adjust compliance obligations for particular licensees rather than a sanctions regime.
• APRA can grant extensions of time in writing (para 10), which functions as an administrative mitigation for due-date breaches when exercised.
• The standard requires controlled submission processes (D2A platform, digital certificates, authorisation by CEO/CFO, retention of agent-submitted copies) that create audit trails and technical controls for APRA to assess compliance (paras 6, 13-15). Those controls facilitate detection of non-compliance, though the Determination itself refrains from specifying the follow-up enforcement steps.

Assurance requirement as an enforcement adjunct. The RSE auditor’s obligation to review and test the RSE licensee’s systems and internal controls and to undertake at least a limited assurance engagement (para 11) functions as a quality-control mechanism that supports APRA’s supervisory objectives. It puts procedural pressure on RSE licensees to maintain reliable internal control environments and provides APRA with independent assurance over reported data, but it is not presented as a penalty or sanction in the Determination.

Absence of penalty detail in the instrument. Because the Reporting Standard does not list specific penalties or enforcement actions, parties relying on this instrument should look to the Financial Sector (Collection of Data) Act 2001 and other relevant legislation (for example, the SIS Act and Prudential Standards) for the statutory enforcement framework. The Determination allows APRA to vary, change reporting frequency, and grant extensions, which are administrative mechanisms APRA can use to manage compliance (paras 8, 10, 16).

Practical implication. In practice, failure to comply with reporting obligations set by APRA typically invites APRA supervisory attention and escalation under the statutory framework that enables APRA to require information and take enforcement actions. The Reporting Standard builds process controls (digital signature, auditor involvement, CEO/CFO authorisation) that reduce the risk of inadvertent non-compliance and create documentary evidence for APRA supervision (paras 11-15), but the Determination does not itself prescribe sanctions.

The Reporting Standard is cross-referenced to, and relies upon, definitions and requirements in other laws and prudential instruments. The Schedule explicitly references the SIS Act, the Income Tax Assessment Act 1997, and multiple Prudential Standards and Regulations. Interactions in the instrument are of three types: definitional cross‑references, prudential-policy cross-references that affect interpretation, and procedural references that affect other regulatory obligations.

Definitional cross-references

• SIS Act definitions. The instrument repeatedly relies on the SIS Act for statutory definitions: “RSE licensee” and RSE (para 17), SMADF and SAF definitions (para 17; glossary). Many role and relationship terms are defined in the instructions by cross-reference to the SIS Act (e.g. associate in section 12 of the SIS Act; glossary).
• Income Tax Assessment Act 1997. The Reporting Standard defines “year of income” by reference to “income year” in s 995‑1 of the Income Tax Assessment Act 1997 (para 17).

Prudential and regulatory cross-references

• Prudential Standard SPS 114 (Operational Risk Financial Requirement) is referenced in the Item 2 instructions for ORFR target amount, ORFR trustee capital and ORFR reserve. The treatment of ORFR reserve investment reporting depends on whether the ORFR target is met through trustee capital or a reserve (Item 2 instructions; glossary).
• Prudential Standard SPS 231 (Outsourcing) is referenced in item 4 and the notes on notification. The instructions explicitly state that SPS 231 requires notification to APRA when outsourcing agreements are entered into, ceased or changed (Details of services - Notifying APRA of new outsourcing agreements and updated information). The SRF forms are not substitutes for the SPS 231 notification requirement; SRF 331.0 cannot be used to notify APRA for SPS 231 purposes (instructions). Item 4 collects offshoring and material business activity flags that match SPS 231 concepts.
• Prudential Standard SPS 310 (Audit and Related Matters) is referenced in para 11 and the instructions. The required assurance level is tied to auditing standards and must not be inconsistent with SPS 310; that standard frames the way the RSE auditor’s work is to be done.
• Prudential Standard SPS 250 (Insurance in Superannuation) is referenced in the definition of insurer used in Item 7 (glossary).
• SIS Regulations are referenced for the meaning of “defined benefit interests” and for income protection definitions (Item 1 and Item 7 instructions).

Operational interactions and consequences

• The Reporting Standard’s fields interact with other reporting returns. The instructions note that certain income should not be included in Item 5 where that income is reported on Reporting Form SRF 800.0 Financial Statements under certain categories (instructions under Item 5). That preserves consistency across APRA forms and prevents double-counting or misclassification.
• The Reporting Standard does not replace SPS 231 notification obligations. While SRF 802.0 collects outsourcing data as at the end of the reporting period or for transactions during the reporting period (depending on the column), SPS 231’s notification duties are separate and often require contemporaneous notification when outsourcing arrangements change (Details of services , Notifying APRA of new outsourcing agreements).
• Audit and assurance overlap. The RSE auditor duties under the Reporting Standard (para 11) must align with SPS 310 obligations. This creates parallel obligations on auditors: to the RSE licensee for statutory audit/assurance tasks under SPS 310 and to the RSE licensee for the specific review and testing required to support APRA reporting under SRF 802.0.

Compliance with accounting law

• The instructions require reporting “in accordance with the Australian Accounting Standards unless otherwise specified” and specify units of measurement. This ties the SRF returns to recognised accounting frameworks and will require reconciliation between the financial statements and the SRF fields where units and reporting bases differ (reporting basis and unit of measurement).

Administrative law and procedural interaction

• The Determination itself is made under section 13 of the Financial Sector (Collection of Data) Act 2001 and the commencement declaration is made under section 15 of that Act (Authority; introductory recital). APRA’s power to vary, grant extensions and change reporting periods is exercised by written notice under the instrument (paras 8, 10 and 16) and must conform to administrative law expectations about reasoned decision‑making, though the Determination sets no further procedural constraints.

Summary. The Reporting Standard is tightly integrated with prudential norms and statutory definitions in the SIS Act, the Income Tax Assessment Act, and several Prudential Standards (SPS 114, SPS 231, SPS 310, SPS 250). Reporting entities must therefore interpret SRF 802.0 using the instrument’s definitions and the cross-referenced regulatory instruments. The Reporting Standard is part of APRA’s broader data-collection architecture, and it is not a stand-alone source of compliance obligations: it informs, and is informed by, prudential obligations elsewhere.

This Determination records a specific amendment event and replaces an earlier instrument. The history contained in the source is limited and precise:

• Revocation of the earlier instrument. The Determination expressly revokes Financial Sector (Collection of Data) (reporting standard) determination No. 96 of 2013, including the Reporting Standard SRS 802.0 made under that Determination (introductory recital (a)). That establishes the 2015 instrument as the operative text from its declared application date.
• Making and authorising officer. The instrument was made by Charles Littrell, delegate of APRA, in the capacity Executive General Manager, Policy, Statistics and International Division, and dated 10 June 2015 (introductory recital and signature block).
• Commencement and application date. The instrument commences on the date of registration on the Federal Register of Legislative Instruments (introductory paragraph under commencement). Separately, APRA declared under section 15 of the Act that the reporting standard shall begin to apply to affected financial sector entities and the revoked reporting standard shall cease to apply on 1 July 2015 (introductory recital (Under section 15 of the Act, I DECLARE...)). Paragraph 4 of the Schedule reiterates that the Reporting Standard applies for reporting periods ending on or after 1 July 2015.
• Structure of the Schedule. The Schedule states that Reporting Standard SRS 802.0 Fund Profile “comprises the 25 pages commencing on the following page” (Schedule). The Schedule then sets out the SRF 802.0 form and detailed instructions, which are the operative content for reporting.

No further amendment traces are recorded within the text supplied. The instrument authorises APRA to make individual variations to reporting requirements in relation to particular RSE licensees (para 16), which provides APRA with an administrative mechanism to vary obligations without amending the Determination itself. Paragraph 8 also allows APRA by written notice to change reporting periods for particular RSE licensees. Those clauses function as amendment-by-notice powers at the firm-specific level rather than formal legislative amendment.

Items to note for tracking amendments in practice

• APRA’s power to vary requirements for particular licensees (para 16) and to change reporting periods (para 8) can result in different reporting obligations across licensees without a formal instrument amendment. Users must therefore track APRA notices to particular licensees in addition to checking the Federal Register for formal amendments.
• Because the instrument references other prudential standards and the SIS Act for definitions and interpretation (para 17; instructions and glossary), changes to those instruments may affect how SRF 802.0 is completed even without amendment to the Determination itself.

The Determination and the Schedule do not contain or reference any litigation, case law or judicial decisions. The text makes no mention of legal challenges, authorities or precedent decisions. It is a statute‑making administrative instrument and, in the material supplied, there is no litigation history recorded.

If legal challenges or judicial interpretations exist outside this text, those are not stated here. The Determination itself is silent on dispute resolution, appeals or litigation processes related to the reporting obligations; those matters would be governed by the Financial Sector (Collection of Data) Act 2001, related prudential standards, and general administrative law, none of which is reproduced in a way that discloses any litigation history within this instrument.

Practitioners seeking litigation history will therefore need to consult external legal databases and APRA enforcement records; nothing in the SRF 802.0 text provides such case citations or outcomes.

The Reporting Standard contains a number of places where common misunderstandings or implementation errors are likely unless attention is paid to the instructions and the cross‑references. These are the principal “gotchas” that practitioners should watch for, grounded in the instrument text.

1. Reporting basis mix: stock versus flow. Several items require mixing “as at the end of the reporting period” with “with respect to transactions that occurred during the reporting period.” Item 1 explicitly requires column 2 and column 5 and column 6 “as at the end of the reporting period” and columns 3, 4 and 7 “with respect to transactions that occurred during the reporting period” (Item 1 reporting basis). Misplacing a stock figure into a flow column (or vice versa) will create mismatches with APRA expectations and with other SRF returns (instructions for Items 1-2).

2. Units and rounding. The instructions mandate reporting units: many monetary fields are thousands of dollars and some counts must be whole numbers. The unit of measurement is repeatedly specified (report columns 3 to 7 as whole numbers; column 2 and 6 as thousands of dollars, etc.). Failure to transform or round correctly will produce submission errors or require correction (reporting basis and unit of measurement; item-level instructions).

3. Aggregation rules for transactions with associates. Items 5 and 6 allow aggregation only where transactions occurred during the same reporting period, and where counterparty, relationship and other characteristics are the same. The instructions emphasise reporting each transaction with associates as a separate line if characteristics differ. Reporting aggregated numbers across varying counterparties or differing characteristics is incorrect (Items 5 and 6 instructions).

4. Insurance cluster reporting nuance. Item 7 requires aggregation of all insurance policies by insurer into “clusters.” Reporting must include both the number of member accounts covered and aggregate cover amounts by insurance type, and premiums/rebates must be reported as transactions for the reporting period. If a cluster ceased during the reporting period, the instructions require reporting 0 for columns 5-9 but still reporting premiums and rebates for the period prior to cessation (Item 7 instructions). Misunderstanding “cluster” can yield inconsistent reporting.

5. ORFR trustee capital versus reserve. If the ORFR target amount is met using trustee capital, Item 2 must be left blank; only where an ORFR reserve is used does Item 2 require investment option detail (Item 2 instructions). Reporting both trustee capital and reserve without applying this rule will lead to errors.

6. D2A dependency and alternative submission methods. The standard requires electronic submission using D2A, but acknowledges D2A may be unavailable and that APRA may notify an alternative method in writing (para 6). Practitioners who rely on internal systems for submission should verify D2A availability and APRA notifications in good time.

7. Certification and authorisation chain. Submissions must be digitally signed with a certificate acceptable to APRA (para 13). Only officers or agents authorised by the CEO or CFO may submit (para 15). If an agent submits, the RSE licensee must retain the completed copy provided by the agent (para 14). Failure to maintain the authorisation records and retention copies will breach the standard’s procedural requirements.

8. Auditor assurance and scope limitations. Para 11 requires the RSE auditor to conduct at least a limited assurance engagement consistent with professional standards to enable formation of an opinion on reliability and accuracy of information. The phrase “to the extent that they are not inconsistent with the requirements of SPS 310” indicates concurrency with SPS 310, which can affect the scope of assurance an auditor may provide. Practitioners should ensure their auditors are clear about the nexus between auditing standards and SPS 310.

9. Outsourcing notification is separate. The instructions explicitly note that Prudential Standard SPS 231 requires separate and, in many cases, contemporaneous notification of outsourcing changes, and that SRF forms cannot substitute for that (Details of services , Notifying APRA of new outsourcing agreements). Treat SRF 802.0 reporting and SPS 231 notification obligations as distinct workflows.

10. APRA’s variation powers. APRA may vary reporting requirements and reporting periods for particular licensees by written notice (paras 8 and 16). That creates the risk of non-uniform obligations across licensees; entities must monitor APRA notices to be sure they are complying with any firm-specific variations or amended due dates.

11. Exclusion of certain revenue lines from Item 5. Item 5 excludes income that is reported on SRF 800.0 Financial Statements under certain investment income categories. Misclassification can cause APRA to question reconciliations between the RSE’s financial statements and SRF returns.

12. “Business operations” breadth. The footnote clarifying “RSE licensee’s business operations” is broad: it includes all activities as an RSE licensee and other activities to the extent they are relevant to or may impact on its activities as an RSE licensee (footnote 1). The consequence is that RSE licensees may need to survey activity beyond a narrow fund-level scope when completing the form.

13. Date and consolidation fields. The form header contains fields for Reporting Period, Scale Factor and Reporting Consolidation. Practitioners should correctly apply scale factors and consolidation choices (form header) to avoid aggregation errors.

These points are all drawn from the text of the Reporting Standard and its instructions. They are procedural and interpretive hazards that will cause incorrect submissions or require remedial interaction with APRA if not handled in advance.

This section provides a step-by-step, source-grounded compliance checklist and practical mapping to the instrument’s requirements. All steps refer to the Reporting Standard (paras and SRF 802.0 instructions) and the specific items in the Schedule.

1. Confirm applicability and scope (para 3; footnote 1; para 4)

   • Determine whether the RSE licensee has any SAFs or SMADFs within its business operations. The standard applies only to RSE licensees that operate SAFs (fewer than five members) or SMADFs (single-member approved deposit funds) (para 3; para 17).
   • If none, no SRF 802.0 submission is required (footnote 1).

2. Establish reporting calendar and due dates (paras 7-10)

   • Default reporting frequency is annually for each year of income (para 7).
   • The default due date is within three months after the end of the year of income to which the information relates (para 9(a)); obtain the precise date for your income-year definition (the instrument adopts “income year” as defined in s 995‑1 of the Income Tax Assessment Act 1997; para 17).
   • If a different reporting period or frequency is needed or already specified by APRA, record any firm-specific written notices from APRA changing reporting frequency (para 8).
   • If you need more time, apply to APRA for an extension in writing; APRA may grant an extension and will set a new due date (para 10).

3. Map data sources to SRF fields and reporting bases (instructions: reporting basis and unit of measurement; Items 1-11)

   • Use Australian Accounting Standards as the reporting basis unless otherwise specified (instructions).
   • Carefully map each SRF field to the source ledger or system that can produce the required basis (stock as at period end versus transactions in the period) and unit (thousands of dollars or whole numbers). For instance, Item 1 requires column 2 and column 5 and column 6 as at period end, but columns 3, 4 and 7 are transaction measures (Item 1 reporting basis).
   • Prepare reconciliations between the financial statements (SRF 800.0) and SRF 802.0 as necessary (Item 5 instructions emphasise treatment of investment income reported on SRF 800.0).

4. Prepare service-provider and outsourcing schedules (Items 3 and 4; Details of services instructions)

   • Compile a complete list of internal (item 3) and external (item 4) service providers, their roles (choose from the specified role types or report “other” with description), service-provider status (existing/new/no longer service provider), expenses for the reporting period, portion of business activity (%), and for external providers whether they are associate providers, whether the activity is material, offshoring flags, ABNs, dates of last review and whether they are associate providers (Item 4 reporting columns and instructions).
   • Ensure you have documented reviews consistent with the Date of last review definition (Item 4 glossary).

5. Extract transactions with associates (Items 5 and 6)

   • Identify income and expense transactions with associates during the reporting period. Report each transaction on a separate line unless aggregation is permissible (i.e. same reporting period, same counterparty, same relationship, same characteristics) (Item 5 and Item 6 aggregation rules).
   • Classify relationships precisely using the defined relationship types in the glossary (RSE licensee, connected entity, parent, director, associate of director, etc.) and record ABNs, name, value (thousands of dollars as specified), income/expense type and description.

6. Insurance reporting (Item 7)

   • Aggregate insurance policies by insurer into clusters and report the number of member accounts with each type of cover (life, TPD, income protection, other), the aggregate cover amounts, premiums collected and rebates received during the reporting period.
   • If a cluster ceased during the reporting period, report zeros for counts and cover amounts but still report premiums and rebates that occurred prior to cessation (Item 7 instructions).

7. Fees and activity fees (Items 8-11)

   • Collate all fee types (administration, advice, exit, insurance, investment, switching, other) and report by source of payment (member, employer sponsor, reserve, RSE licensee), with values gross of any rebate (Item 8).
   • Separately report fee rebates/discounts for each fee type (Item 9).
   • Report activity fees in Item 10, indicating whether the fee relates to financial product advice and the source of payment (Item 10).
   • Report activity-fee rebates/discounts in Item 11 where applicable.

8. ORFR reserve and investment option detail (Item 2)

   • Determine whether the ORFR target amount is met via trustee capital or a reserve; if met by trustee capital, leave Item 2 blank. If an ORFR reserve is used, report each investment option the reserve is invested in, with unique identifier and value (Item 2 instructions referencing SPS 114).

9. Implement internal controls and documentation (paras 11-12)

   • Ensure systems, procedures and internal controls are in place and documented so an RSE auditor can review and test them (para 11). The Board and senior management must ensure appropriate authorisation policies are in place (para 12).
   • Keep a documented record of the internal review and authorisation process required by paragraph 12.

10. Engage the RSE auditor and plan the assurance engagement (para 11)

    • Arrange for the RSE auditor to review and test systems and controls, at least annually, and to perform a limited assurance engagement consistent with professional standards and guidance notes, to the extent not inconsistent with SPS 310 (para 11).
    • Coordinate timing so the auditor’s assurance supports the RSE licensee’s submission timetable.

11. Electronic submission and digital signature (paras 6 and 13)

    • Obtain access to the Direct to APRA (D2A) software and ensure internal submitters are trained. If D2A is not available, APRA must have notified an alternative method in writing (para 6).
    • Obtain and install a digital certificate acceptable to APRA and ensure submission processes produce the digital signature required (para 13).

12. Authorisation, agent use and retention (paras 14-15)

    • Authorise the officer or agent who will submit: CEO or CFO must authorise the named submitter (para 15).
    • If an agent submits on the RSE licensee’s behalf, obtain from the agent the completed form and retain it (para 14).

13. Reconciliation and internal review before submission

    • Perform final reconciliations between SRF 802.0 totals, the general ledger and any related SRF forms (for example SRF 800.0). Ensure units and rounding conform to the form’s requirements.
    • Ensure the Board/senior management authorisation procedures are followed and recorded (para 12).

14. Monitor APRA notices for variations (paras 8 and 16)

    • Track any written notices from APRA that change reporting periods or vary reporting requirements for your RSE licensee. Treat such notices as binding and update your reporting plan accordingly.

15. Retain records and audit trails

    • Maintain copies of submitted forms, audit working papers produced in support of the RSE auditor’s limited assurance engagement, authorisation records from the CEO/CFO, digital certificate records and agent-submitted copies where relevant (paras 11, 12, 14, 15).

16. Document governance and policies

    • Establish or update internal policies describing who is responsible for each SRF item, how often data is validated, how external providers’ data is obtained and the review cadence for service-provider relationships and associate transactions (para 12; item-level instructions on service-provider reviews and last review dates).

17. Practical sequencing and responsibilities

    • Start early: mapping and extraction of service‑provider, insurance and associate transaction data across many small funds within an RSE licensee’s business operations can be time-consuming.
    • Coordinate accounting, operations, compliance and IT teams to convert GL data into the SRF shapes, plan auditor engagement, obtain CEO/CFO authorisation paperwork and schedule D2A submission before the due date.

All of these compliance steps are grounded in the text of the Reporting Standard: the duty to provide SRF 802.0 (para 5), the D2A submission and digital certificate rules (paras 6 and 13), due dates and extension mechanism (paras 7-10), auditor assurance and quality controls (paras 11-12), authorisation and retention requirements (paras 14-15), and the detailed item-level reporting bases, units and definitions in the SRF 802.0 instructions and glossary.

Practitioners should keep the SRF 802.0 instructions at hand while building internal processes, and ensure their RSE auditor understands the limited assurance scope required by para 11 and referenced auditing standards and SPS 310.