Financial Sector (Collection of Data) (reporting standard) determination No. 6 of 2017

Coverage and entities: The Reporting Standard applies to each RSE licensee in respect of each RSE, defined benefit RSE, PST and ERF within its business operations (para 3; Interpretation para in Schedule). The defined scope of “RSE” in the instrument excludes defined benefit RSEs, PSTs, ERFs, small APRA funds and single member approved deposit funds for the definition of RSE used elsewhere in the instructions; defined terms are cross-referenced to the SIS Act and SIS Regulations (Interpretation para, multiple entries).

Reporting architecture: SRF 330.0 is structured around a statement of financial performance for an RSE, with the following high-level sections and mechanics:

• Members’ benefits flows in and out (items 1-3): contributions (employer, member, defined benefit), rollovers, successor transfers, lump sums and pensions, with several items derived and some items restricted by entity type (e.g. PST exclusions; Instructions, Item 1 and Item 2).
• Superannuation activities (items 4-12): investment income (item 4), gains/losses on investments (item 5), other investment income and total investment/income and gains/losses (items 6-7), operating income (item 8), investment expenses (item 9), administration and operating expenses (item 10), advice expenses (item 11) and net flows from superannuation activities (item 12). Derived-item rules and cross‑form equality checks are specified (e.g. Item 4.5 must equal totals on SRF 531.0 and SRF 530.1; Item 5 cross-references SRF 531.0, SRF 530.1 and SRF 534.0).
• Insurance activities (items 13-15): inflows and outflows from acquired insurance and self-insurance, and net insurance flows.
• Profit/loss and reserves (items 16-21): profit or loss before and after tax, income tax expense/benefit, transfers into and out of reserves affecting net assets available to pay members’ benefits, and change in net assets available to pay members’ benefits (derived item 21).

Reporting basis and presentation: All items are to be reported in accordance with Australian Accounting Standards unless otherwise specified, reported as transactions occurring during the reporting period but, for quarterly submissions, reported on a year-to-date basis rather than quarter-only (Instructions: Reporting basis and unit of measurement; Specific instructions). Items must be reported as thousands of dollars.

Quality and assurance: The RSE auditor must review and test the RSE licensee’s systems, procedures and internal controls producing the information, on an annual basis or more frequently if needed, and perform at least a limited assurance engagement consistent with Auditing and Assurance Standards Board guidance insofar as not inconsistent with SPS 310 (para 11). Information marked “[ABS]” is exempt from the auditor testing requirement but must be as accurate as possible or a careful estimate produced by systems and controls (paras 11-14).

Authorisation and submission control: Submissions must be digitally signed through D2A by an officer or agent acceptable to APRA (para 15). If submitted by an agent, the licensee must obtain and retain a copy of the completed form (para 16). The submitting officer or agent must be authorised by the licensee’s CEO or CFO (para 17).

Discretion and variation: APRA may change reporting frequency or vary reporting requirements for a particular licensee or entity by written notice (paras 8, 18). APRA may also grant extensions of due dates in writing (para 10).

Cross-references to other instruments and laws: The Standard refers throughout to the SIS Act, SIS Regulations, Prudential Standards (SPS 160, SPS 250, SPS 310, SPS 510), SGAA, and to other APRA reporting forms (SRF 530.1, SRF 531.0, SRF 534.0, SRF 114.0). Those references set interpretive points and reconciliation obligations (Instructions and Interpretation sections).

Primary obliged parties: The immediate legal payers of the compliance cost are RSE licensees. Paragraph 3 requires that an RSE licensee provide SRF 330.0 information in respect of each RSE, defined benefit RSE, PST and ERF within its business operations. The Reporting Standard therefore affects any entity that holds an RSE licence and operates one or more of the listed RSE types.

Covered reporting units: For reporting purposes, an RSE licensee must complete SRF 330.0 separately for each RSE, defined benefit RSE, PST and ERF it operates (Schedule footnote [1]; Reporting Form SRF 330.0: Reporting level). This means an RSE licensee that is trustee for several distinct RSEs must provide separate forms for each, increasing per-fund reporting effort and data segregation requirements.

Internal stakeholders: Board and senior management bear governance responsibility for ensuring appropriate policies and procedures exist for the internal review and authorisation of information submitted to APRA (para 13). The CEO or CFO must authorise submitting officers or agents (para 17). RSE auditors are explicitly elevated to a verification role: they must review and test the systems and report at least at a limited assurance engagement level (para 11). Where agents submit data, the licensee must retain copies of the completed forms (para 16).

Service providers and agents: Administrators, custodians, investment managers, IT providers and other service providers that supply data or perform processing functions for an RSE will be affected in practice, because the RSE licensee must ensure the information is the product of systems and controls tested by the RSE auditor (para 11; Schedule “Service provider” definition under Item 9). Agents who use D2A must be able to meet APRA’s digital certificate and submission requirements (para 15).

External users and beneficiaries: APRA and the ABS are the explicit institutional users of the data (para 2). APRA uses the data for prudential supervision and publication; the ABS may use certain items (para 2). Indirect beneficiaries include stakeholders relying on APRA publications and statistics, including journalists, researchers, other regulators and market participants.

Excluded and differently treated entities: The Reporting Standard’s definition of RSE for the form excludes small APRA funds and single member approved deposit funds (Interpretation, footnotes [5] and [6]). Some PST-specific rules are provided in the items (e.g. items that are not to be completed for PSTs; Instructions for Item 1 and Item 2). Items marked “[ABS]” are collected for ABS use and are not required to be audited or tested by the RSE auditor (para 12).

Who pays and who decides: RSE licensees pay compliance costs in time, personnel, IT and audit fees. APRA decides the reporting content, format, frequency, due dates, and any variation or extension by written notice (paras 6-10, 18).

Primary duties imposed by the Determination:

• Duty to report SRF 330.0: An RSE licensee must provide the information required by SRF 330.0 for each reporting period in respect of each relevant entity within its business operations (para 5).
• Duty to use the prescribed submission channel and format: Information must be submitted electronically via D2A or another APRA‑notified method (para 6).
• Timing obligations: Quarterly data within 28 calendar days after quarter end, annual data within three months after year-of-income end, unless APRA specifies otherwise or grants an extension in writing (paras 7-10).
• Duty to produce data from reviewed systems and controls: The reported information must be the product of systems, procedures and internal controls reviewed and tested by the RSE auditor on an annual basis or more frequently if necessary, and at least as part of a limited assurance engagement consistent with Auditing and Assurance Standards Board guidance insofar as not inconsistent with SPS 310 (para 11).
• Duty to ensure internal review and authorisation processes: Board and senior management are responsible for policies and procedures for the authorisation of information submitted to APRA (para 13).
• Duty to ensure ABS items are as accurate as possible: ABS-only items may be estimated if accurate information is not readily available, but the estimate must be the product of dedicated systems, processes and controls (para 14; Instructions).
• Duty to obtain and retain agent-submitted forms: If an agent submits on the licensee’s behalf via D2A, the licensee must obtain and retain the completed form (para 16).
• Duty to authorise submitters: Any officer or agent submitting data must be authorised by the CEO or CFO (para 17).
• Duty to sign digitally: Electronic submissions must be digitally signed using an acceptable digital certificate (para 15).

Discretionary powers granted to APRA:

• Vary reporting frequency or periods for a particular licensee or entity by written notice where APRA considers it necessary or desirable (para 8).
• Vary the reporting requirements of SRF 330.0 in relation to a particular RSE licensee or particular RSEs within its business operations by written notice (para 18).
• Grant written extensions of due dates for specified entities (para 10).

Rights and exceptions in the instrument:

• ABS-only items are not required to be audited by the RSE auditor (para 12).
• If APRA deems D2A unavailable or not appropriate, APRA may notify an alternative submission method in writing (para 6).
• The Determination allows the use of careful estimates for ABS‑only items where accurate information is not readily available, provided those estimates are produced by systems, processes and controls developed for that purpose (para 14; Instructions).

Cross-form and accounting duties:

• The Standard requires reporting in accordance with Australian Accounting Standards unless specified otherwise, and many items are derived and must reconcile to other APRA reporting forms (e.g. Item 4.5 must equal SRF 531.0 and SRF 530.1 totals; Item 5 cross-references SRF 531.0, SRF 530.1 and SRF 534.0) (Instructions under Items 4 and 5). This creates a duty to maintain consistent accounting treatment across forms and to reconcile totals across reporting streams.

What the instrument does not specify (express omissions):

• No penalties or enforcement sanctions appear in the text of the Determination itself. The instrument sets reporting obligations, due dates, authorisation and assurance expectations, and APRA’s powers to vary and extend requirements but does not contain express enforcement mechanisms or civil/criminal penalties in the text provided. Where enforcement or penalties exist, they are not set out in this Determination and would be governed by the Financial Sector (Collection of Data) Act 2001 or other legislation, which are referenced as the authority but are not reproduced in this instrument (Determination preamble; Authority para 1).

The Determination SRS 330.0, as set out in the source, does not specify penalties, fines or enforcement mechanisms within its own text. The instrument prescribes reporting duties, authorisation requirements and assurance expectations but does not create or describe explicit sanctions for non‑compliance in the pages supplied.

Enforcement architecture implied or external to the Determination:

• The Determination is made under the Financial Sector (Collection of Data) Act 2001 (Authority para 1). That Act is cited as the enabling legislation, making APRA’s requirement lawful. The Determination itself, however, does not reproduce the enforcement provisions of the enabling Act. Practitioners should therefore consult the Financial Sector (Collection of Data) Act 2001 for any statutory offence or enforcement provisions (the Determination references paragraph 13(1)(a) of that Act and s 15 for commencement, but the Act text is not included here).
• APRA’s operational enforcement levers suggested in the Reporting Standard are administrative rather than punitive in form: APRA can vary reporting periods and reporting content by written notice to a particular licensee (paras 8 and 18) and can grant written extensions (para 10). These are compliance‑management tools rather than sanctions.
• Assurance obligations and the auditor’s role are the proximate compliance control: the RSE auditor must review and test systems and perform at least a limited assurance engagement consistent with Auditing and Assurance Standards Board guidance and SPS 310 (para 11). Failure to have audit testing consistent with these requirements would create a non‑compliance record and may give APRA grounds to require remedial action under its supervisory powers under the enabling Act, though specific supervisory powers or penalty provisions are not stated here.

Material procedural requirements that act as de facto enforcement risk points:

• Digital-signature requirement for submissions via D2A (para 15) and the authorisation requirement that the submitter be authorised by the CEO or CFO (para 17). A lack of appropriate digital certificates or unauthorised submitters would breach the Reporting Standard’s procedural obligations.
• Retention obligation where an agent submits on behalf of a licensee: the licensee must obtain and retain the completed form (para 16). Failure to retain may impede APRA’s ability to verify submissions and could trigger supervisory follow-up.
• Auditor testing requirements and the requirement that information be the product of reviewed systems, procedures and internal controls (para 11). Shortfalls here can lead to APRA seeking further information, requiring remediation or adjusting its supervisory assessment of the licensee.

Practical implication for advisers: Because the Determination does not itself set out penalties, practitioners must read the Financial Sector (Collection of Data) Act 2001 and related prudential standards to identify statutory enforcement powers and possible sanctions for breach. The Reporting Standard creates several discrete compliance checkpoints that APRA can use administratively to manage adherence (submission timeliness, authorized signatories, auditor attestations, reconciliations to other SRFs).

Direct statutory cross-references in the instrument:

• Superannuation Industry (Supervision) Act 1993 (SIS Act) and SIS Regulations: Many terms (RSE, PST, ERF, year of income) and conceptual duties are tied to the SIS Act and SIS Regulations; the instrument references specific SIS provisions for definitions and interpretative cross-checks (Interpretation section; footnotes [5], [6]; references in item definitions).
• Superannuation Guarantee (Administration) Act 1992 (SGAA): The definition of super guarantee contributions, reported in item 1.1.1, relies on the SGAA (Item definitions).
• Prudential Standards: The Reporting Standard cross-references several Prudential Standards as interpretive or normative anchors:
  • SPS 160 Defined Benefit Matters for defined benefit RSE definitions (Interpretation; defined benefit RSE).
  • SPS 310 Audit and Related Matters for the auditor testing standard expected in the Reporting Standard (para 11; footnote [3]).
  • SPS 250 Insurance in Superannuation for notions of acquired insurance and self-insurance (Instructions: Insurance activities).
  • SPS 510 Governance for the definition and role of Chief Executive Officer (para 19; footnote [4]).
• Income Tax and related law: The instrument uses tax concepts (contributions tax, contributions surcharge, capital gains tax, PAYG withholding) and references the Income Tax Assessment Act 1997 and other tax instruments when explaining items (various item definitions).
• Life Insurance Act 1995 and Insurance Act 1973: The definition of acquired insurance references insurers registered under the Life Insurance Act 1995 or authorised under the Insurance Act 1973 (Instructions: Item 13 definitions).
• Australian Accounting Standards: The Reporting Standard requires reporting in accordance with Australian Accounting Standards unless otherwise specified (Instructions: Reporting basis and unit of measurement).
• Australian Bureau of Statistics (ABS) processes: Items flagged “[ABS]” are identified as being collected solely for ABS purposes; the Reporting Standard specifies different audit and estimation rules for those items (paras 11-14; Instructions).

Operational interactions and reconciliation obligations:

• Cross-reports to other APRA forms: The SRF 330.0 items must reconcile to and be consistent with other APRA reporting forms, specifically SRF 531.0 Investment Flows, SRF 530.1 Investments and Investment Flows, and SRF 534.0 Derivative Financial Instruments, which are explicitly named in Instructions for Items 4 and 5. The Standard thus presumes an integrated APRA reporting regime and imposes reconciliation duties across those streams.
• Interaction with APS/SPS audit requirements: The auditor testing obligation is linked to SPS 310. Where items or methods in the Reporting Standard are “not inconsistent” with SPS 310, auditors must apply professional auditing and assurance guidance subject to that prudential overlay (para 11).
• Data privacy and retention regimes: While not directly referenced, the digital signature, retention of agent-submitted forms, and governance obligations mean that privacy, record-keeping and data security obligations under other laws and prudential requirements will need to be observed in practice, as the Reporting Standard requires retention and signed submissions (paras 15-17).

What the instrument does not do with other laws:

• The Determination does not amend, displace or restate the operative provisions of the SIS Act, tax law or Prudential Standards; instead it references and relies upon those instruments for definitions and cross‑compliance. Practitioners must reconcile the reporting obligations with those primary statutes and prudential standards outside the text of this Determination.

What this instrument changes in the statutory record:

• It expressly revokes Financial Sector (Collection of Data) (reporting standard) determination No. 36 of 2015, including Reporting Standard SRS 330.0 Statement of Financial Performance made under that Determination (Determination preamble, clause (a)).
• It determines a new Reporting Standard SRS 330.0 Statement of Financial Performance in the Schedule, replacing the prior instrument (Determination preamble, clause (b)).
• The Determination declares that the new Reporting Standard applies and that the revoked reporting standard ceases to apply from 1 July 2017 (Determination preamble; declaration under s 15).

Administrative dates and signing:

• The instrument is dated 21 June 2017, signed by Katrina Ellis, General Manager, Statistics, as a delegate of APRA, and states it commences on the date of registration on the Federal Register of Legislation (Determination preamble; commencement clause).

What the record does not contain:

• No subsequent amendments, revocation dates after 2017, or further modifications are included in the text provided. The Schedule itself contains the operative form and instructions as at the Determination’s making. Any later amendments to SRS 330.0 would appear in later Determinations or instruments not included here.

Practical point for compliance advisers:

• This Determination is a replacement instrument; affected entities transitioning from the previous 2015 standard needed to operationalise the new form and instructions by 1 July 2017. Any preparer referencing the current obligations should check for subsequent Determinations or updates after this instrument, because the provided text itself contains only this single replacement action (revocation of No. 36 of 2015 and replacement by No. 6 of 2017).

The text of the Determination and its Schedule, as provided, contains no litigation history, no judicial decisions, and names no cases. The instrument is an administrative instrument made under the Financial Sector (Collection of Data) Act 2001 and does not record any court challenges, interpretations by courts, or prior litigation.

What is known from the instrument:

• The Determination does not reference judicial interpretations or past litigation regarding APRA’s data-collection powers or the content of SRS 330.0. It stands as an administrative reporting regulation replacing an earlier reporting standard.

Implication for practitioners:

• Because the instrument itself does not provide litigation history, compliance teams and advisers who need to understand potential legal risks from contested interpretations must consult:
  • The Financial Sector (Collection of Data) Act 2001 (for statutory enforcement and powers).
  • Any APRA policy statements or guidance that interpret reporting obligations.
  • Subsequent administrative decisions or case law, which are not included in this instrument and therefore require external legal research.

Note on evidence base: Any legal analysis of enforcement risk, or on the meaning of particular terms in litigation, would need to be supported by external primary sources (case law, the enabling Act, or APRA guidance), because the Determination text supplied contains no litigation references.

The Reporting Standard has several specific procedural and technical features that create higher-than-appearing compliance risk if overlooked. The following is a checklist of material pitfalls drawn directly from the instrument text and the Schedule.

1. Quarter reporting is year-to-date, not quarter-only

   • The Instructions require that items reported "with respect to transactions that occurred during the reporting period" must be reported on a year-to-date basis for quarterly returns rather than for the individual quarter alone (Instructions: Reporting basis and unit of measurement). Failure to produce YTD figures when APRA expects them will create mismatches with other APRA forms and likely trigger follow-up.

2. Derived items and mandatory reconciliations

   • Many items are derived. For example, Item 1.4 (gross contributions) is the sum of employer (1.1), member (1.2) and defined benefit contributions (1.3). Item 3 (net members’ benefits flows) is calculated as item 1.12 minus item 2.7. Item 4.5 must equal totals on SRF 531.0 and SRF 530.1; Item 5 has multiple cross-form equality checks (Instructions for Items 1, 3, 4 and 5). These derivations mean data must be reconciled across forms and between modules; mismatches will raise data-quality flags.

3. Entity-level reporting multiplicity

   • Report separately for each RSE, defined benefit RSE, PST and ERF within the RSE licensee’s business operations (para 3; Schedule footnote [1]). If a licensee is trustee of multiple RSEs, each requires its own SRF 330.0. This increases operational complexity and requires per-fund mappings, chart of accounts segmentation and possibly multiple reconciliations.

4. PST and other exclusions

   • Several items explicitly must not be completed for PSTs (e.g. Items 1.1-1.9 in respect of a PST; Item 2.1-2.4 not to be completed for PSTs). Ensure reporting templates are configured to suppress or handle PST-specific rules (Instructions: Item 1 and Item 2).

5. ABS-only items: audit and estimation rules

   • Items marked “[ABS]” are exempt from auditor testing (para 12), but the Instructions require they be as accurate as possible and permit careful estimates only where accurate data is not readily available, provided those estimates are produced by systems, processes and controls developed for this purpose (para 14; Instructions). Do not treat ABS items as low priority; APRA expects controls over estimates.

6. Auditor testing standard and SPS 310 interface

   • The Reporting Standard requires that the RSE auditor conduct at least a limited assurance engagement consistent with Auditing and Assurance Standards Board guidance as may be amended from time to time, "to the extent that they are not inconsistent with the requirements of SPS 310" (para 11). Auditors must therefore reconcile professional standards with prudential requirements and may need to adjust scope where SPS 310 prescribes a different approach. Expect audit scope negotiation.

7. Digital signing and authorised submitters

   • Submissions must be digitally signed using a digital certificate acceptable to APRA (para 15). The submitter must be authorised by the CEO or CFO (para 17). If an external agent submits, the licensee must obtain and retain the completed form (para 16). Maintain records of authorisations, digital certificates and retained copies.

8. Timing edge cases: non-business days

   • If the due date falls on a non-business day, the information is still required no later than the due date (footnote [2]). There is no implicit grace-period; the obligation remains absolute.

9. “RSE licensee’s business operations” breadth

   • The footnote definition of 'RSE licensee’s business operations' is broad: it includes all activities as an RSE licensee and other activities relevant to or that may impact its RSE activities (footnote [1]). Data from other parts of the corporate group may therefore be in scope if it affects RSE activity.

10. Units and presentation constraints

    • All items must be reported in thousands of dollars and in accordance with Australian Accounting Standards (Instructions). Mismatching unit conventions will create validation errors in D2A.

11. Cross-form dependencies with SRF 531.0/530.1/534.0

    • Where SRF 330.0 totals must equal totals reported on other SRFs, any misalignment in classification policies between forms will produce reconciliation variances and create reporting follow-up. Ensure chart-of-accounts mapping is consistent across SRFs.

12. APRA’s ability to vary or require more frequent reporting

    • APRA can, by written notice, change reporting periods or vary requirements for particular RSEs (paras 8 and 18). Prepare to respond to ad hoc requests and to implement changes quickly, including increased submission frequency.

13. No penalties in the Determination text

    • The Determination does not state enforcement penalties or sanctions. Do not assume the instrument’s silence means absence of legal consequence; consult the enabling Act for statutory enforcement mechanics.

This is a practical compliance checklist drawn from the Reporting Standard text. Each step cites the relevant paragraph or instruction in the instrument.

1. Establish scope and inventory (para 3; footnote [1])

   • Identify every RSE, defined benefit RSE, PST and ERF within the RSE licensee’s business operations.
   • For each entity, create a reporting inventory listing which SRF 330.0 items apply and which are excluded or PST-specific.

2. Map accounting sources to SRF items (Instructions: Reporting basis and Specific instructions)

   • Ensure all SRF 330.0 items are mapped to chart-of-accounts lines and source systems. Use Australian Accounting Standards treatments as the default basis.
   • Determine derived-item formulas (e.g. item 1.4 = sum of 1.1 + 1.2 + 1.3) and ensure system-derived totals reconcile.

3. Configure systems for required presentation conventions (Instructions)

   • Configure systems to report in thousands of dollars and to produce YTD figures for quarterly submissions.
   • Ensure unit-level segregation so PSTs, defined benefit RSEs and ERFs are reported separately.

4. Reconciliation controls to other SRFs (Instructions for Items 4 and 5)

   • Establish automated reconciliations between SRF 330.0 and SRF 531.0, SRF 530.1, SRF 534.0 where cross-form equality is mandated.
   • Document reconciliation procedures and exception handling.

5. Implement internal review, authorisation and governance (para 13)

   • Board and senior management must approve policies and procedures for internal review and authorisation.
   • Maintain a delegation matrix requiring CEO or CFO authorisation for submitting officers or agents (para 17).

6. Prepare for auditor testing (para 11)

   • Ensure the RSE auditor can review and test the systems, procedures and internal controls producing the reporting data, at least annually and as part of a limited assurance engagement consistent with Auditing and Assurance Standards Board guidance and SPS 310.
   • Provide auditors with documentation, system access and control evidence. Schedule internal testing ahead of auditor testing to resolve issues.

7. Control ABS-only items and estimation practice (paras 11-14; Instructions)

   • Identify which items are ABS-only and establish controls and documented methodologies for careful estimates where accurate data is not readily available.
   • Maintain evidence that ABS-only estimates are produced by dedicated systems, processes and controls.

8. Set up D2A submission and digital certificates (para 6, 15)

   • Obtain and test Direct to APRA (D2A) access and ensure the appropriate digital certificate acceptable to APRA is available for the authorised submitter.
   • If using an external agent to submit, require receipt of a completed form and retain as required (para 16).

9. Prepare submission calendar and resource plan (paras 7-10; footnote [2])

   • Calendar quarterly due dates (28 days after quarter end) and annual due dates (three months after year-of-income end). Build in time for auditor testing and internal authorisation.
   • Include contingency for APRA notice to change frequency or due dates and for APRA-granted extensions.

10. Evidence retention and audit trail (para 16)

    • Retain completed forms, signed submissions and evidence of internal authorisation, reconciliations and auditor attestations.
    • Keep records in a way that supports APRA enquiries and demonstrates the information was produced from reviewed systems and controls.

11. System and change management for APRA variations (paras 8, 18)

    • Maintain capacity to implement APRA notice-driven changes to frequencies, item content or reporting periods quickly.
    • Log and version-control any changes to mapping logic, formulas or classification consistent with APRA notices.

12. Test end-to-end submission in advance

    • Execute a full mock quarterly and annual run-through with the RSE auditor reviewing the outputs. Confirm reconciliation to linked SRFs and that the D2A sign-off works with the authorised officer’s digital certificate.

13. Address PST and ERF specifics

    • Modify templates for PST reporting to omit items not required for PSTs (Instructions: Item 1 and Item 2).
    • Ensure the treatment of PST units (items like 1.10 and 2.5) and payments to unit holders are captured where applicable.

14. Monitoring and ongoing improvement

    • Monitor APRA publications and communications for guidance and changes to reporting standards.
    • Periodically validate ABS-only estimates and rework controls if quality issues arise.

Minimum compliance checklist prior to submission

• Entity list and scope confirmed for each SRF 330.0 (para 3).
• Mapping to Australian Accounting Standards and chart-of-accounts done (Instructions).
• YTD figures for quarterly returns confirmed (Instructions).
• Derived items reconciled and cross-SRF reconciliations executed (Item-specific Instructions).
• RSE auditor engagement scheduled and evidence prepared (para 11).
• Internal authorisation and board-level governance documented (para 13).
• Digital certificate active and authorised submitter identified (paras 15-17).
• Agent-submitted forms process established and retention confirmed (para 16).
• ABS-item estimation methodology documented where necessary (para 14).
• Submission via D2A tested and successful.

By following this sequence and aligning internal controls with the audit testing expectations in para 11, an RSE licensee can produce SRF 330.0 data that meets the Reporting Standard’s structural, timing and assurance requirements.