Financial Sector (Collection of Data) (reporting standard) determination No. 27 of 2021

The Reporting Standard organises deposit data collection around a small number of structural concepts that determine who reports, in what format, how often, and what precise breakdowns must be supplied.

1. Two reporting templates (forms) and the standard/reduced split. Reporting Form ARF 720.2A is the Standard form, ARF 720.2B is the Reduced form. The Standard collects a more detailed matrix of deposit balances by counterparty sector and deposit type; the Reduced form is a compact version for smaller or lower‑category reporters (Schedule, forms and instructions).

2. Reporter population and thresholds. Paragraph 4 sets the default allocation:

   • ADI Reporting Category B: ARF 720.2A = No; ARF 720.2B = Yes if total assets ≥ $200m.
   • ADI Reporting Category A: ARF 720.2A = Yes; ARF 720.2B = No (with a footnote allowing APRA discretion, see footnote [1]).
   • RFCs: ARF 720.2A = No; ARF 720.2B = Yes if total assets ≥ $50m (para 4 table). The Reporting Standard also includes a note (para 9) specifying how ‘total assets’ is to be measured for the purpose of threshold tests (values drawn from ARF 720.0A/B or ARF 323.0 as at the relevant prior-year date).

3. Reporting basis and consolidation. Paragraph 7 requires the information to be provided for each reporting period on a domestic‑books consolidation. That fixes the accounting population and consolidation boundary: domestic books, consolidated, not unconsolidated branches or global consolidated groups.

4. Reporting periodicity and timing. Paragraph 9 prescribes monthly or financial‑year reporting depending on reporter type and asset size; paragraph 10 imposes a generic 10 business‑day lodgement deadline; paragraph 11 permits APRA to change frequency for particular reporters; paragraph 12 permits extensions.

5. Data structure and classifications. The forms and detailed instructions require deposit balances split into:

   • Transaction deposits, fixed‑term deposits, and other non‑transaction deposits (columns).
   • Counterparty by residence (resident v non‑resident) and by detailed sector (households, community service organisations, non‑financial businesses with five sub‑classes, general government with sub‑classes, and a large set of financial institution sub‑classes including RBA, ADIs, RFCs, securitisers, money‑market funds, etc.) (forms and instructions). The instructions also identify specific subitems (for example, offset accounts linked to housing loans, retirement savings accounts, non‑interest‑bearing accounts) and require certain derived fields to equal sums of other items (instructions).

6. Quality assurance and auditor involvement. Paragraph 13 requires that all information be the product of systems, processes and controls reviewed and tested by the external auditor in accordance with APS 310 (for ADIs) or RRS 710.0 (for RFCs). The audit review must be at least annual or more frequently if the external auditor requires it.

7. Submission mechanics and digital authorisation. Paragraph 8 requires electronic submissions via D2A or an APRA‑notified method. Paragraph 15 requires the submitting officer or agent to digitally sign the information using an APRA‑acceptable digital certificate/credential.

8. Interform reconciliation. The instructions state that for column 7 of ARF 720.2A, item 1 also equals the value of deposits reported in item 14 (column 1) on ARF 720.0A, and for ARF 720.2B the total deposits for column 4 also equals item 14 on ARF 720.0A/B. That creates an explicit cross‑form consistency obligation.

9. Statutory status. The Reporting Standard is an EFS Reporting Standard made under s 13 of the Financial Sector (Collection of Data) Act 2001 and commences as declared under s 15 of the Act (paras 1 and commencement recital).

These concepts define the data taxonomy, the conditionality of the reporting obligation, and the governance of quality, submission and authorisation.

The instrument affects ADIs and RFCs to differing extents, as set out in paragraph 4 and the forms’ reporting‑level instructions.

• ADIs. The universe of ADIs is split by APRA reporting category:
  • ADI Reporting Category A must complete ARF 720.2A (Standard) (para 4 table). The instruction text for ARF 720.2A reiterates that it must be completed by each ADI to which the Reporting Standard applies under paragraph 4 or 5 (ARF 720.2A instructions, Reporting level).
  • ADI Reporting Category B is treated differently: ARF 720.2B (Reduced) applies if total assets ≥ $200 million; otherwise, per the table, ARF 720.2B is not required (para 4 table). The note explains how to measure an ADI’s total assets for this purpose (para 9 note).
• Registered financial corporations (RFCs). RFCs do not complete the Standard form by default. They complete the Reduced form ARF 720.2B only if total assets ≥ $50 million (para 4 table). The Reporting Standard also sets a separate monthly/annual reporting frequency for RFCs depending on whether their total assets are ≥ $400 million or < $400 million respectively (para 9(b) and its note).
• Related entities and intra‑group items. The instructions require exclusion of deposits by related parties (intra‑group deposits) from the forms; those are reported through ARF 720.3 (instructions under ARF 720.2A and ARF 720.2B). That places a reporting burden on groups to segregate intra‑group balances and file a separate intercompany form.
• APRA itself. APRA is the recipient and controller of the reporting regime: APRA may vary thresholds for particular ADIs or RFCs in writing (para 5), change reporting periods for particular ADIs or RFCs having regard to their circumstances and ABS/RBA needs (para 11), grant extensions (para 12), and notify alternative submission methods (para 8). APRA may also use the collected data for prudential and publication purposes in addition to supplying the ABS and RBA (paras 2-3).
• External auditors. The external auditor of each reporter has a role: para 13 requires they review and test the reporter’s systems and controls supporting the information, in accordance with APS 310 for ADIs or RRS 710.0 for RFCs, and relevant AU Auditing and Assurance Standards provide scope guidance. The auditor must perform this review at least annually or more frequently if required.

Who pays and who decides:

• Who pays: The direct costs fall on the reporting ADIs and RFCs, which must compile the required data, maintain internal controls, obtain external auditor review, and provision digital credentials and submission infrastructure. The schedules and forms impose detailed classification and reconciliation work that will consume internal finance, data and compliance resources. The Reporting Standard does not create a fee schedule in the instrument itself; compliance costs are borne by the reporting entities.
• Who decides: APRA decides which entities must report which form in practice: APRA can set or adjust thresholds for specific entities (para 5), change reporting frequency per entity (para 11), and notify submission methods (para 8). APRA also determines whether an ADI may be exempt on condition of submitting alternative information (footnote [1] and referenced paragraph 16(1)(b) of the Act in the footnote).

Behavioural consequences for affected parties include changes to internal data architecture (to produce the required sectoral and product splits), investment in audit and control processes to satisfy para 13, administrative steps to manage D2A digital certificates, and potentially more frequent reporting if APRA imposes higher frequency under para 11.

The Reporting Standard imposes specific duties on reporting ADIs and RFCs and creates certain administrative rights for APRA. The duties and rights are stated principally in the numbered paragraphs of the Reporting Standard and in the form instructions.

Key duties on reporters

• Duty to provide required information. Paragraph 7: "An ADI or RFC to which this Reporting Standard applies must provide APRA with the information required by this Reporting Standard for each reporting period on a domestic books consolidation." This is the core statutory duty to report the specified dataset for each reporting period.

• Duty to use specified forms and units. The forms and instructions require reporting on ARF 720.2A or ARF 720.2B as applicable (para 4 table; ARF instructions). Reporters must report monetary amounts in Australian dollars, or AUD equivalents for foreign currencies, converting per AASB 121 (instructions).

• Duty to exclude intra‑group deposits from these forms. The instructions for both forms instruct reporters to exclude deposits by related parties and to report intra‑group details on ARF 720.3.

• Duty on timeliness. Paragraph 10: information must be provided within 10 business days after the end of the reporting period; paragraph 12 allows APRA to grant extensions in writing.

• Duty to use electronic submission and digital authorisation. Paragraph 8 requires electronic format via D2A or an APRA‑notified web method; paragraph 15 requires the submitting officer or agent to digitally sign using a digital certificate or other APRA‑acceptable digital identity.

• Duty to maintain and test systems and controls, and to have external auditor review. Paragraph 13 requires that the information be the product of systems, processes and controls reviewed and tested by the external auditor in accordance with APS 310 (ADIs) or RRS 710.0 (RFCs). Paragraph 14 requires internal review and authorisation systems to assure completeness and reliability.

• Duty to apply prescribed classifications and derived calculations. The instructions enumerate precise sectoral classifications and derived fields that must equal the sum of specified subitems (instructions).

Administrative rights for APRA and discretions

• Right to determine thresholds for particular entities. Paragraph 5: APRA may determine that a threshold, or a higher threshold than that specified, will apply to a particular ADI or RFC and will notify the ADI or RFC in writing.

• Right to vary reporting frequency. Paragraph 11: APRA may change the reporting periods, or specified reporting periods, for a particular ADI or RFC (to require more or less frequent reporting), having regard to the ADI or RFC’s circumstances and the extent to which the information is required for the purposes of the ABS or RBA.

• Right to grant due‑date extensions. Paragraph 12: APRA may grant an ADI or RFC an extension of a due date in writing.

• Right to accept alternative submission methods. Paragraph 8 allows APRA to notify a method, other than D2A, for submission.

• Discretion to accept exemptions conditioned on alternative information. The footnote and final explanatory material indicate APRA may exempt an ADI from providing information under this Reporting Standard on the condition that it provides other information required by the Reporting Standard; APRA may exercise this to ensure the information collected accords with the stated Purpose (footnote [1] and related explanatory note).

Other rights/duties drawn from instructions

• Duty to reconcile to other APRA forms. The instructions state that some totals must reconcile to item 14 (column 1) on ARF 720.0A/B (instructions for ARF 720.2A and ARF 720.2B), imposing an internal reconciliation duty.

• Duty to report according to Australian Accounting Standards. The instructions require reporting in accordance with Australian Accounting Standards unless otherwise specified.

What is not in the instrument

• No penalty regime is specified within the Reporting Standard itself. The instrument does not set out sanctions or enforcement procedures; enforcement powers and penalties, if applicable, lie within the Financial Sector (Collection of Data) Act 2001 under which the standard is made (the Determination notes it is made under s 13 of that Act and commenced under s 15). The Reporting Standard does not itself articulate administrative sanctions, fines or other enforcement mechanisms.

The text of Determination No. 27 of 2021 and Reporting Standard ARS 720.2, as provided, does not specify penalties, monetary fines or enforcement procedures within the instrument itself. The Reporting Standard repeatedly states its statutory basis: it is made under section 13 of the Financial Sector (Collection of Data) Act 2001 (para 1), and the Determination declares commencement under section 15 of the Act (Determination recital). That locates obligations in the Act, but the Reporting Standard document supplied does not reproduce the enforcement or sanctioning provisions of the Act.

Concrete points drawn from the source

• Statutory authority and commencement. The Reporting Standard is issued under s 13 of the Act and declared to commence under s 15 (para 1 and Determination recital). Those references anchor the legal force of the Reporting Standard to the Act, which contains APRA’s data‑collection powers and the enforcement regime. The Reporting Standard itself does not restate the Act’s enforcement provisions.

• Administrative levers within the Standard. While no penalties are specified, the Standard provides administrative controls APRA may exercise: varying thresholds for particular reporters (para 5), changing reporting periods (para 11), granting extensions of due dates (para 12), and exempting reporters on condition they provide alternate information (footnote [1] referencing para 16(1)(b) of the Act). These give APRA discretion to tailor the reporting burden and to insist on alternate compliance paths.

Practical implication for entities

• Enforcement mechanisms and sanctions likely derive from the parent statute (Financial Sector (Collection of Data) Act 2001) and APRA’s general regulatory powers, not from the Reporting Standard. Because the Reporting Standard requires adherence to APS 310 / RRS 710.0 for external auditor work (para 13), non‑compliance with its auditor‑review obligations could expose an ADI or RFC to prudential or regulatory follow‑up through APRA’s statutory powers (though those powers and remedies are not enumerated in the text provided).

• In the absence of specified penalties within this instrument, affected entities should treat the Reporting Standard as carrying statutory force and be mindful that APRA’s discretions (para 5, para 11, para 12 and footnote [1]) may be used to require remedies or alternative reporting where APRA judges the information necessary.

If a practitioner needs to advise on enforcement consequences (fines, directions, notices), they must consult the Financial Sector (Collection of Data) Act 2001 itself and APRA’s enforcement guidance, since those instruments contain the enforcement architecture not reproduced in the Reporting Standard text.

The Reporting Standard sits as subordinate instrument under the Financial Sector (Collection of Data) Act 2001 and interfaces with other prudential and reporting standards and with Australian Accounting and Auditing Standards, as stated in the text.

Direct legal relationships mentioned in the document

• Parent Act. The Reporting Standard is made under section 13 of the Financial Sector (Collection of Data) Act 2001 and commenced under section 15 (para 1 and Determination recital). That Act supplies APRA’s legal authority to require data. The Reporting Standard itself does not reproduce the Act’s full provisions; practitioners must consult the Act for the statutory enforcement regime and for APRA’s broader powers referenced in the footnote (for example, paragraph 16(1)(b) of the Act is referenced in the explanatory footnote).

• Prudential standards for auditor procedures. Paragraph 13 requires external auditor review and testing “as set out in Prudential Standard APS 310 Audit and Related Matters for ADIs or Reporting Standard RRS 710.0 ABS/RBA Audit Requirements for Registered Financial Corporations for RFCs.” That creates a compliance link: the auditing procedures and scope that APS 310 and RRS 710.0 mandate become prescriptive inputs into the Reporting Standard’s quality control obligations. APRA’s prudential standards are separate instruments that must be applied to satisfy the Reporting Standard’s auditor review requirement.

• ARS 701.0 definitions and EFS framework. Paragraph 3 designates ARS 720.2 as an Economic and Financial Statistics (EFS) Reporting Standard for the purposes of ARS 701.0 ABS/RBA Definitions for the EFS Collection. The Reporting Standard therefore relies on definitions established in ARS 701.0; the instructions stress that terms defined in ARS 701.1 appear in bold and italics (para 16). Paragraph 18 explicitly states references to Acts, Prudential Standards, Reporting Standards and Australian Accounting or Auditing Standards are to instruments “as in force or existing from time to time,” creating an explicit dynamic link to those bodies of law and practice.

• ARF 720.0 and ARF 323.0. The Reporting Standard requires reconciliation (instructions) and uses figures from ARF 720.0A/B and ARF 323.0 to measure thresholds and to cross‑check totals. Specifically, the note to paragraph 9 explains how to measure total assets for ADIs and RFCs using values reported in ARF 720.0A/B (item 13 column 1) or ARF 323.0 (item 11 column 1) as at 31 December prior calendar year or last day of RFC’s prior financial year. The forms also reconcile totals to item 14 on ARF 720.0A/B, so the Reporting Standard is operationally interdependent with those other APRA reporting forms.

• Australian Accounting and Auditing Standards. The instructions require reporting in accordance with Australian Accounting Standards and specify that foreign currency amounts be converted in accordance with AASB 121 The Effects of Changes in Foreign Exchange Rates (instructions). The auditor review requirement explicitly references Auditing and Assurance Standards Board standards for scope and nature guidance (para 13).

Areas of interaction and practical consequences

• Cross‑form consistency. The requirement to reconcile ARF 720.2 totals to ARF 720.0A/B item 14 (instructions) means that accounting classification and consolidation choices made for financial‑statement reporting will directly affect compliance with the Reporting Standard. Entities must ensure their ARF 720.0/X returns and ARF 720.2 returns are aligned.

• Overlap with prudential auditor obligations. External auditor work performed to satisfy APS 310 or RRS 710.0 may overlap with external audit work performed for financial‑statement audits under Auditing Standards. The Reporting Standard explicitly points auditors to relevant auditing standards for guidance (para 13). Entities should coordinate auditor engagements to avoid duplication and to document the scope required by the Reporting Standard.

• Interaction with APRA discretions. APRA’s ability to set different thresholds (para 5), change reporting periods (para 11) and accept alternative reporting or exemptions (footnote [1]) means APRA may use parts of its statutory toolkit under the Act to harmonise or tailor obligations where other laws or reporting requirements create conflicts or overlapping burdens. Those administrative adjustments will be given in writing.

• No express data‑privacy or information‑sharing terms in the Standard. The Reporting Standard states the data will be used by ABS and RBA for their purposes and may be used by APRA for prudential and publication purposes (paras 2-3). The instrument does not restate record‑retention, confidentiality or privacy regimes; those will be governed by the Act and other law. Practitioners should consult the Act and APRA policy on confidentiality and information sharing for the precise legal constraints.

If precise enforcement, confidentiality or data‑sharing obligations under the parent statute or other laws are material, the Reporting Standard as provided requires practitioners to refer to the Financial Sector (Collection of Data) Act 2001 and to APRA’s public policy statements and the ABS/RBA data‑access arrangements.

The instrument itself records a single discrete amendment action at the time of issue: APRA, by delegate Alison Bliss, revoked Financial Sector (Collection of Data) (reporting standard) determination No. 4 of 2019 and determined Reporting Standard ARS 720.2 ABS/RBA Deposits in its place (Determination recital). The instrument is dated 30 July 2021 and declares that the new Reporting Standard applies and the revoked standard ceases to apply on the day it is registered on the Federal Register of Legislation (Determination recital; commencement clause).

Elements of the amendment action and timeline recorded in the document

• Revocation. The Determination expressly revokes Determination No. 4 of 2019, including Reporting Standard ARS 720.2 ABS/RBA Deposits made under that previous Determination (Determination recital (a)).

• New determination. The current Reporting Standard ARS 720.2 ABS/RBA Deposits is presented in the Schedule and applies to the financial sector entities as provided in paragraph 4 of the Reporting Standard (Determination recital (b); Schedule contents).

• Commencement. Under section 15 of the Act, the delegate declares the Reporting Standard shall begin to apply to those financial sector entities and the revoked reporting standard shall cease to apply on the day the instrument is registered on the Federal Register of Legislation; the instrument’s specific line “This instrument commences upon registration on the Federal Register of Legislation” repeats that (Determination recital and final lines).

• Effective reporting period. Paragraph 6 of the Reporting Standard states: "This Reporting Standard applies for reporting periods ending on or after 30 September 2021." That sets the effective date for the data‑collection obligations.

• Footnote exception framework. The instrument includes a footnote (to the table in para 4) and an explanatory note showing APRA may, in practice, exempt an ADI from providing ARF 720.2A if it provides ARF 720.2B instead, under paragraph 16(1)(b) of the Act, as an example of how APRA may use its discretion (footnote and final explanatory paragraph). That suggests an administrative mechanism to modify reporting in particular cases without amending the instrument.

What the instrument does not record

• The document contains no chronological amendment log beyond this one revocation and replacement action. No subsequent amending instruments or historical variations are recorded in the text provided. For a full amendment history after 30 July 2021, one must consult the Federal Register of Legislation or APRA’s repository for subsequent variations.

• The Reporting Standard itself contemplates that APRA may change thresholds, reporting frequency or grant extensions for particular entities (paras 5, 11-12), but those are administrative variations and will be implemented in writing to the relevant entities; they do not appear as formal amendments to the Reporting Standard text itself.

Practical note for compliance teams

• Treat 30 September 2021 as the starting point for reporting periods covered by this version (para 6), and ensure that any revocations of the 2019 instrument and new reporting obligations are embedded in the compliance calendar, systems and auditor engagement letters accordingly.

The text supplied contains no litigation history. The Reporting Standard document does not mention any judicial or tribunal decisions, challenges, or judicial interpretation of the instrument. It names no cases.

What practitioners should take from that absence

• No case law is provided in the instrument to clarify ambiguous definitions or contested application issues. If disputable points arise in practice (for example, interpretation of a particular counterparty category, consolidation boundary or treatment of a particular deposit product), there is no litigation precedent cited in this instrument to follow.

• Disputes about the legal effect, application, or enforcement of ARS 720.2 will turn on the language of the Reporting Standard and the parent Act (Financial Sector (Collection of Data) Act 2001), and if litigated would create new authority. Absent case law, internal legal analysis should be grounded in the text of the standard, APRA guidance and the Act.

If litigation history is material to a client matter, the practitioner must consult court databases and the Federal Register of Legislation for any subsequent cases or judicial interpretation post‑dating this instrument.

The Reporting Standard contains several implementation pitfalls, ambiguities that could create operational risk, and points where a failure to follow the precise technical instructions will lead to inconsistency with other APRA returns. The following “gotchas” are drawn from the instrument text and instructions.

1. Threshold measurement timing and source fields. Paragraph 9 and its notes specify that an ADI’s total assets is measured by the value reported in 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, total assets is measured by item 13 (column 1) on ARF 720.0A as at the last day of the RFC’s prior financial year. Practitioners must ensure they pull the exact ARF items specified, not a general balance‑sheet total, and use the precise reference date. Mis‑reading this could place an entity in the wrong filing cohort.

2. Domestic books consolidation requirement. Paragraph 7 requires reporting on a domestic books consolidation. Many institutions maintain multiple consolidation bases (legal entity, group consolidated, branch‑level). Using the wrong consolidation basis will produce numbers that do not reconcile with other APRA reports that may use different consolidation conventions.

3. Resident v non‑resident treatment differs from ARF 720.0. The ARF 720.2 forms collect resident and non‑resident deposits separately; ARF 720.0 does not separate non‑residents. That difference can cause reconciliation surprises when comparing forms unless teams explicitly split non‑resident deposits per the ARF 720.2 instructions.

4. Intra‑group exclusion and separate reporting. Both forms require exclusion of intra‑group deposits and direction to report those on ARF 720.3. Organisations that do not segregate intra‑group balances in their general ledger must build a separate extraction process to populate ARF 720.2 and ARF 720.3 respectively.

5. Reconciliation obligations to ARF 720.0A/B. The forms state that certain totals must equal item 14 on ARF 720.0A/B (instructions). If internal accounting treatment or timing mismatches cause divergence between ARF 720.2 totals and ARF 720.0 totals, that will trigger remedial queries and possibly APRA follow‑up.

6. FX conversion rule and AASB 121. The instructions require converting foreign‑currency amounts to AUD per AASB 121. Different business units may apply different FX spots or closing rates; the requirement to follow AASB 121 (which prescribes translation approaches) means corporate treasury must ensure consistent and auditable FX translation for the reporting to match audited financial statements.

7. Auditor‑review timing. Paragraph 13 requires external auditor review and testing on an annual basis or more frequently if the external auditor requires. That creates dependency on the auditor’s schedule. Entities should align engagement letters with APRA timelines to ensure auditors can perform required procedures within APRA deadlines.

8. Electronic submission and digital certificate logistics. Paragraphs 8 and 15 require electronic filing via D2A or APRA‑notified web solution and digital signing with an APRA‑acceptable credential. Procurement of digital certificates and the provisioning of users in D2A can take time; failure to provision certificates before a reporting period can block timely submission.

9. APRA discretions create uncertainty. APRA can change thresholds for individual entities (para 5), change reporting frequency (para 11) and grant extensions (para 12). While these powers improve regulatory flexibility, they also mean that a reported obligation can change by APRA notice. Entities should track APRA notices and maintain a compliance log of any APRA‑issued threshold or frequency variations.

10. Derived fields and grey cells. The forms include derived fields shaded in grey in the templates and require mathematical derivation (instructions). Automated extract‑transform‑load (ETL) processes must handle these derived fields correctly; otherwise, the digital submission might fail reconciliation checks.

11. Differing rounding or unit practices. The instructions require whole‑dollar reporting and state “for reporting purposes, unless specified otherwise, enter data as a positive number.” Ensure unit conversions and rounding are consistently applied across systems.

12. RFC reporting period alignment. RFCs with total assets < $400m report on a financial year basis while many ADIs report monthly (para 9). For RFCs that operate on a different fiscal year end from their parent ADI or group, aggregation and timing for consolidation can be a source of mismatch.

13. Use of APRA’s “exempt on condition” power. The footnote and explanatory note show APRA may exempt an ADI from providing ARF 720.2A conditional on providing ARF 720.2B. Entities should not assume this discretion will automatically be exercised in their favour; an explicit written APRA exemption is required.

Each of these items is traceable to the text of the Reporting Standard, its instructions, or the Determination recital and should inform implementation planning, system mapping and auditor engagement.

A practical compliance checklist follows. Each step is derived from a specific provision in the Reporting Standard and its instructions; practitioners should document evidence of compliance (workpapers, reconciliations, auditor reports) to satisfy APRA and auditors.

1. Determine reporting status and form to lodge (para 4, para 5).

   • Identify whether your institution is an ADI or RFC and your APRA reporting category.
   • Calculate ‘total assets’ according to the specified source and date: ADIs use item 13 (column 1) on ARF 720.0A/B or item 11 (column 1) on ARF 323.0 as at 31 December prior calendar year; RFCs use item 13 (column 1) on ARF 720.0A as at last day of prior financial year (para 9 note).
   • Apply the table in paragraph 4 to decide whether to file ARF 720.2A (Standard) or ARF 720.2B (Reduced).
   • If in doubt, request APRA confirmation in writing under para 5, which allows APRA to determine thresholds for particular entities.

2. Establish reporting periods and due dates for your entity (paras 9-12).

   • If required to report monthly (para 9(a)), calendarise these obligations and set internal deadlines that allow for audit review and digital signing before the 10 business‑day due date (para 10).
   • If RFC with assets < $400m, align reporting to the financial year (para 9(b)).
   • Monitor APRA notices for any entity‑specific changes to reporting frequency (para 11) and administrative extensions (para 12).

3. Map data sources, accounting basis and consolidation boundary (para 7; instructions).

   • Prepare a domestic books consolidation extract as required by paragraph 7.
   • Map ledger accounts to the deposit‑type classification (transaction, fixed‑term, other non‑transaction) and to the counterparty sector classification in the forms, noting the detailed subitems (instructions).
   • Ensure FX balances are converted per AASB 121 and amounts are reported in whole dollars (instructions).

4. Exclude intra‑group items and map to ARF 720.3 (instructions).

   • Segregate related‑party deposit balances from the main ARF 720.2 submission and prepare ARF 720.3 for intra‑group assets and liabilities as directed by the ARF instructions.

5. Implement internal controls and documentation (paras 13-14).

   • Document systems, processes and controls that produce the reported figures, including ETL logic, mapping tables, reconciliations to general ledger and to ARF 720.0A/B where required.
   • Establish an internal review and authorisation workflow, with named officers responsible for sign‑off consistent with paragraph 14.

6. Engage external auditors for required review/testing (para 13).

   • Amend auditor engagement letters to include the external auditor review and testing requirement in line with APS 310 (for ADIs) or RRS 710.0 (for RFCs) and the Auditing and Assurance Standards Board guidance referenced in para 13.
   • Schedule auditor procedures early enough to allow auditors to perform on an annual basis or more frequently if they require (para 13). Document the auditor’s opinion or review memo as evidence.

7. Prepare reconciliations to other APRA returns (instructions).

   • Reconcile ARF 720.2 totals to item 14 (column 1) on ARF 720.0A/B as specified in the ARF instructions; retain reconciliation workpapers to demonstrate consistency and to address any queries.

8. Provision submission mechanics and digital identity (paras 8, 15).

   • Register for APRA’s Direct to APRA (D2A) application and obtain any necessary user provisioning.
   • Acquire an APRA‑acceptable digital certificate or credential and test digital signing of the electronic submission (para 15).
   • If APRA notifies an alternative submission method, obtain the notification in writing and document the method.

9. Implement derived-field calculations and validation logic (forms/instructions).

   • Ensure automated calculations for derived fields (grey fields) conform to the mathematical expressions described in the instructions, and embed validation checks to avoid submission rejections.

10. Establish ongoing monitoring for APRA notifications and changes (paras 5, 11-12).

    • Maintain a compliance register noting whether APRA has issued any threshold exceptions, frequency changes or extensions in writing; update internal reporting schedules accordingly.

11. Plan for audit trail and record retention.

    • Retain source data, mapping documentation, auditor review outputs, reconciliations and APRA correspondence that supports each submission. The Reporting Standard requires that information be the product of tested systems; preserve evidence of those tests.

12. Test end‑to‑end submission process.

    • Conduct dry runs to ensure that figures reconcile to internal ledgers and ARF 720.0A/B, that digital signing works, and that D2A accepts the file formats. Test FX translation and whole‑dollar rounding.

13. Address special cases proactively.

    • If you believe an exemption or alternative submission would be appropriate, seek written APRA determination under para 5 or an exemption under the Act (as discussed in the footnote) rather than relying on informal understandings.

14. Coordinate with group entities and auditors for group reporting.

    • Where the domestic books consolidation relies on inputs from subsidiaries, branches or affiliates, coordinate collection timelines and data definitions to meet the 10 business‑day deadline (para 10).

15. Maintain internal lines of authority for sign‑off.

    • Ensure the officer or agent authorised to sign via the D2A digital certificate is an identified and authorised signatory with a documented delegation consistent with paragraph 15.

If a reporting entity needs a template program plan, it should map the ARF 720.2 line items to ledger accounts, create a validation matrix that flags totals that must reconcile to ARF 720.0, assign controls owners, and schedule auditor involvement at least one quarter in advance of the first submission date. All of these steps are supported by the provisions cited above (paras 4, 7-15 and the ARF instructions).