Financial Sector (Collection of Data) (reporting standard) determination No. 73 of 2023

The Standard organises concentration risk reporting around a small set of derived capital-relevant quantities and the data required to calculate them. The principal concepts are:

• Insurance Concentration Risk Charge (ICRC). The top-level item reported in Table 1. APRA permits insurers to omit reporting components that are always materially lower than others (Table note under Table 1). The ICRC is thus an aggregate of several component scenarios (Table 1 header and Units of measurement).

• Natural Perils Vertical Requirement (NP VR). NP VR is a vertical (single-event) loss metric expressed as a derived item: the greater of (NP PML less NP reinsurance recoverables) or net whole-of-portfolio loss, adjusted by reinstatement premiums, reinstatement cost and other adjustments (see Definitions N and Item 1 formula in Table 1). NP PML is the gross single-event loss at the 0.5% annual probability level; net whole-of-portfolio loss is its net counterpart (Definitions N).

• Natural Perils Horizontal Requirement (NP HR). NP HR is a horizontal (multi-event) scenario, the greater of the H3 requirement or the H4 requirement less a PL offset (Definitions N and Item 2 headline). H3 covers losses from three H3 events; H4 covers up to four H4 events.

• H3 and H4 events and components. H3 and H4 scenarios require reporting single-event losses, reinsurance recoverables (only if gross basis selected), aggregate offsets, reinstatement premiums and reinstatement costs. H3 is calculated across three event columns; H4 across four columns (H sections; Item 2.3 and 2.4). Reinstatement costs must reflect market conditions after prior events and must not be less than full original cost unless the insurer demonstrates material overstatement to APRA (H3/H4 reinstatement cost rules).

• Other Accumulations Vertical Requirement (OA VR). OA VR captures non-natural perils or dependent-source accumulations. OA VR equals OA PML plus OA reinstatement cost less PL adjustment to OA PML and OA reinsurance recoverables (Definitions O; Item 3).

• LMI Concentration Risk Charge. A prescribed three‑year economic downturn scenario applied to lenders mortgage insurance business, calculated per GPS 116 (Definitions L; Item 4).

• Reinstatement premiums and costs. These appear across NP, H3, H4 and OA definitions. Insurers must include inward reinstatement premiums from cedants only where the reinsurance contract explicitly stipulates offsetting at time of reinsurance claim payment (Definitions H/NP/O). Reinstatement cost estimation rules require insurers to use contractually agreed rates where available, otherwise to estimate based on prevailing market conditions, and not to understate the original cost except with demonstrable evidence (see repeated provisions in H3/H4/NP/OA).

• Aggregate offsets and PL offset. Aggregate reinsurance recoverables can be included as offsets where treaty attachment is reached. PL offset is the portion of premiums liabilities attributable to catastrophic losses as determined by the Appointed Actuary (Definitions P).

• Gross versus net basis choices. For several components (H3, H4, NP VR) the insurer must select gross or net as the basis and that choice determines which sub-items must be reported (multiple places: B table; Item 1.1; Item 2.3.1/2.4.1). Choosing gross triggers reporting of reinsurance recoverables; choosing net triggers reporting of net whole-of-portfolio loss, etc.

Procedurally, the Standard is a data template and calculation rulebook. It prescribes item numbering, column structure for multi-event items, permitted values (gross/net), units (whole Australian dollars, no decimals), and exceptions where APRA agreement or consultation is required (for example, methodology for aggregate offsets and multiple inception dates for catastrophe reinsurance programs) (C/E/H notes; Units of measurement).

The Standard applies to all general insurers authorised under the Insurance Act 1973, which the instrument defines as an insurer within the meaning of s 11 of the Insurance Act (para 3 and Definitions). The definition list clarifies that references to authorised insurer, authorised insurance entity or licensed insurer are references to an insurer; an insurer whose business is only reinsurance is treated as an APRA-authorised reinsurer where it carries on reinsurance business, and Lloyd’s underwriters carrying on reinsurance business are included (para 17(b)). The Australian Reinsurance Pool Corporation is explicitly listed as an APRA-authorised reinsurer for purposes of the definitions (para 17(b)).

Other categories engaged by the Standard:

• Foreign insurers and branches. The Definitions adopt the Insurance Act’s concept of foreign general insurer; a reference to a branch or branch operation is a reference to Australian operations of a foreign insurer, so Australian branches of foreign insurers authorised under the Insurance Act fall within scope (para 17(b)-(d) notes).

• Insurers writing reinsurance. Specific provisions govern inward reinstatement premiums and reporting of reinsurance-related items (H sections, NP and OA definitions) and require consultation with APRA on aggregate offset methodologies.

• Appointed Auditor and Principal Executive Officer/Chief Financial Officer. The Standard imposes duties on the Appointed Auditor to review systems, processes and controls and to provide limited assurance engagements (para 10); it requires submissions to be authorised by either the Principal Executive Officer or the Chief Financial Officer (para 14). These roles are defined in para 17.

• Agents submitting on behalf of insurers. Agents may submit but insurers must obtain and retain a copy of the completed information (para 13) and ensure the agent is properly authorised (para 14).

Who bears the direct cost and compliance burden? The instrument places reporting, assurance and internal-control obligations on insurers’ boards and senior management (para 11), and on insurers’ auditors (para 10). Insurers that write reinsurance must account for reinsurance structures (reinstatements, aggregate treaty attachment points, inward reinstatement premiums) and agree methodologies with APRA where stated (H definitions; other adjustments). Insurers with LMI business must apply GPS 116 formulae for the LMI concentration risk charge (Definitions L).

The Standard gives APRA discretionary authority to impose different reporting cadences or content for a particular insurer by written notice (para 7, para 15). That discretion means APRA can target specific firms without changing the standard for the entire population.

Duties imposed by the Standard are concrete and operational. Principal duties include:

• Provision of required information for each reporting period. An insurer must provide APRA with the information required by the Reporting Standard for each reporting period (para 4). The defined reporting periods are quarterly and annual tied to the insurer’s financial year as default (para 6).

• Submission format and method. All information must be provided in electronic format using an APRA electronic method, or by another method APRA notifies (para 5). Values must be reported in whole Australian dollars with no decimals (Units of measurement).

• Timing obligations and extensions. Quarterly returns must be lodged within 20 business days of period end; annual information within three months after financial year end (para 8). APRA may grant an extension in writing (para 9). APRA may require more or less frequent reporting for a particular insurer by written notice (para 7). If reporting due dates fall on non-business days, insurers must nonetheless submit by the due date (Note to para 9).

• Quality control and assurance. Reported information must be the product of systems, processes and controls reviewed and tested by the Appointed Auditor. That review must be performed at least annually or more frequently as necessary, and must include at least a limited assurance engagement consistent with Auditing and Assurance Standards Board professional standards and Prudential Standard GPS 310 (para 10). The insurer’s Board and senior management are responsible for establishing internal review and authorisation policies and procedures for data submitted to APRA (para 11).

• Authorisation and retention. Electronic submissions must be digitally signed with a digital certificate acceptable to APRA (para 12). If an agent submits data, the insurer must obtain and retain a copy of what was submitted (para 13). The submitting officer or agent must be authorised by the insurer’s Principal Executive Officer or Chief Financial Officer (para 14).

• Specific reporting calculation duties. Insurers must select gross/net bases where required, calculate H3/H4 event columns as set out, include or exclude reinstatement premiums only where contractually appropriate, and estimate reinstatement costs using contractual rates where available or market conditions otherwise. Reinstatement costs may not be less than the full original cost unless the insurer demonstrates to APRA that the amount materially overstates the post-event market cost (H sections; NP/OA definitions).

APRA’s express rights and discretions in the instrument:

• Change reporting periods. APRA may change the reporting frequency for a particular insurer by written notice where APRA considers it necessary or desirable (para 7).

• Vary reporting requirements. APRA may, by written notice, vary the reporting requirements of this Reporting Standard in relation to that insurer (para 15).

• Grant extensions. APRA may grant time extensions in writing under para 9.

• Require methodology agreement. Where an insurer uses aggregate reinsurance offsets, the insurer must agree a methodology with APRA for determination of the adjustment (H definitions).

Rights implicit in the instrument include APRA’s entitlement to receive audited annual reports and auditor certificates as required by the Insurance Act and the prudential standards (see Note to para 6 referencing Insurance Act paras 49J and 49L and requirement that annual data form part of yearly statutory accounts).

What the Standard does not do (as per its text): it does not itself set out civil penalties, criminal sanctions or supervisory actions; enforcement powers lie in the enabling legislation referenced by the Standard rather than within the reporting standard text (no penalty provisions appear in the provided document).

The Reporting Standard’s text does not specify standalone prescribed penalties, fines or criminal sanctions for non‑compliance. The instrument is an APRA reporting determination made under section 13 of the Financial Sector (Collection of Data) Act 2001 (Authority), and it cross-references audit and lodging obligations under the Insurance Act 1973 (see the Note to para 6 that invokes paragraph 49J(1)(a), subsection 49J(3) and paragraph 49L(1)(a) of the Insurance Act). Those cross-references indicate that failure to provide annual audited statutory accounts and auditor certificates in line with the Insurance Act will engage the audit and lodging framework in that Act.

Because the Standard is a reporting instrument, enforcement of its requirements will be situated in the broader APRA supervisory and enforcement powers provided by the enabling legislation (the Financial Sector (Collection of Data) Act 2001 and the Insurance Act 1973). The Standard itself makes APRA’s supervisory objective explicit,use of the information for prudential supervision including assessing compliance with capital standards (para 2),but it leaves legal enforcement mechanics to the parent Acts. The document does provide specific supervisory levers that APRA can exercise administratively:

• APRA can alter reporting cadence or content for a particular insurer by written notice (para 7, para 15), which is an administrative instrument to increase scrutiny.

• APRA can require insurers to agree methodologies for aggregate offset adjustments, meaning APRA can require methodological alignment as a condition of accepting reported offsets (H definitions).

• APRA can grant extensions in writing (para 9), which is an administrative discretion useful in supervisory timetable management.

The Standard instructs insurers to obtain limited assurance engagements consistent with Auditing and Assurance Standards Board guidance and Prudential Standard GPS 310 (para 10). Failure to obtain the required auditor review could mean that annual information does not meet the audit/certificate requirements that form part of an insurer’s yearly statutory accounts under the Insurance Act (Note to para 6). That, in turn, would likely engage the enforcement powers available under the Insurance Act and related APRA prudential standards (though the Standard does not itself list the specific statutory sanctions).

In short, the document creates reporting and assurance obligations, and situates enforcement within APRA’s statutory toolkit and the Insurance Act’s audit and lodgement provisions. The text does not enumerate fines or criminal offences in the Standard itself.

The Standard is embedded in a network of statutes, prudential standards and professional standards that it cross-references repeatedly. The primary legal and regulatory touchpoints in the Standard are:

• Financial Sector (Collection of Data) Act 2001. This is the statutory power under which the Reporting Standard is made (Authority). Section 13 of that Act is cited as the source of APRA’s power to make reporting determinations.

• Insurance Act 1973. The Standard applies to general insurers authorised under that Act and expressly treats annual reporting items as part of the insurer’s yearly statutory accounts within the meaning of section 3 of the Insurance Act (Note to para 6). The Standard cross-references audit requirements and auditor certificates under Insurance Act paragraph 49J(1)(a), subsection 49J(3), and paragraph 49L(1)(a) (Note to para 6 and para 8 commentary).

• Prudential Standards (especially GPS 001, GPS 310 and GPS 116). The Standard imports definitions from Prudential Standard GPS 001 (para 17(a)) and instructs that the Appointed Auditor’s assurance engagement should be consistent with GPS 310 Audit and Related Matters, noting that the Auditing and Assurance Standards Board’s standards and guidance apply to the extent not inconsistent with GPS 310 (para 10). The LMI Concentration Risk Charge is to be determined using the formulae and requirements set out in GPS 116 (Definition L).

• Corporations Act 2001. The Standard uses the Corporations Act meaning of "financial year" in its Definitions (para 17(c)) and thereby aligns reporting periods with that statutory definition.

• Auditing and Assurance Standards Board professional standards. The Standard directs that limited assurance engagements be consistent with professional standards and guidance issued by the Auditing and Assurance Standards Board (para 10).

• APRA’s other reporting and instruction documents. The Standard refers to GRS 001 general instruction guide and other reporting standards for certain annual information and for lodgement timing rules (Notes to para 6 and elsewhere). It also states that where an insurer has multiple inception dates for catastrophe reinsurance programmes it must consult APRA to determine the relevant commencement or end date (C and E tables).

Operational interactions that arise from those references include:

• Audit and lodgement: Annual data required by this Standard feed into the insurer’s yearly statutory accounts and therefore interact with statutory audit obligations under the Insurance Act and reporting timetables under GRS 001 (Note to para 6; para 8).

• Capital standards and prudential supervision: The Standard exists to provide data APRA will use in assessing compliance with capital adequacy prudential standards (para 2). That situates the Standard logically upstream of capital calculations in prudential standards and creates dependencies on GPS 116 for LMI and GPS 001 for definitions (para 17).

• Professional assurance compatibility: Insurers must reconcile the assurance work required by this Reporting Standard with professional auditing standards; the Standard requires at least a limited assurance engagement consistent with Auditing and Assurance Standards Board guidance and not inconsistent with GPS 310 (para 10).

• Reinsurance contract terms and Australian law. The Standard’s treatment of reinstatement premiums and aggregate offsets depends on contractual stipulations (for example, inclusion of inward reinstatement premiums only where the reinsurance contract specifically stipulates offsetting with a cedant) and on whether aggregate reinsurance cover has reached attachment points (Definitions H/N/O). That requires insurers to map contract terms into statutory reporting categories.

Because the Standard routinely defers to APRA consultation or written notice for methodology issues (aggregate offsets, multiple inception dates, APRA-accepted digital certificate method, etc.), its practical operation involves bilateral interaction between insurers and APRA rather than unilateral standardised calculation in every case (C/E/H notes; paras 5, 7, 15).

The Standard as provided contains explicit temporal application and transitional provisions but does not carry a multi-year amendment log in the text supplied. The instrument states:

• Commencement: The Standard applies for reporting periods ending on or after 1 July 2023 (para 3).

• Revocation/transition: The Standard replaces an old reporting standard (the one revoked by the determination that made this Standard). Transitional reporting rules require an insurer to report under the old reporting standard for transitional reporting periods , defined as reporting periods under the old reporting standard that ended before 1 July 2023 but for which the insurer was required to report by a date on or after the revocation of the old standard (para 16). The Note to para 16 makes clear that overdue reporting documents under the old standard remain required under the old standard if their due dates fell before the revocation.

• Continuity of audit obligations: The Note to para 6 cross-references Insurance Act auditing and lodgement requirements and states that the auditor’s certificate relating to annual information must be provided to APRA by the time specified in GRS 001, unless an extension is granted under GRS 001. That creates an operational tie to the timing rules in GRS 001 which may change separately.

No other amendments, prior versions, or change history entries are present in the provided text. The Standard contemplates future variation by APRA for particular insurers by written notice (para 15), which is an administrative amendment mechanism for individual firms but not an instrument amendment affecting all insurers. The text also allows APRA to change reporting periods for a particular insurer (para 7), which operates as a targeted amendment power.

If a reader needs to trace prior versions or prior amendments beyond what the provided instrument states, they must consult the instrument’s legislative or APRA register entry (not included in the text supplied) or the earlier reporting standard that was revoked. The document itself documents the cut-over (apply from 1 July 2023 and transitional rules) but no multi-version chronology appears.

The provided text contains no case law, legal challenges or litigation history. It does not cite, summarise or reference any judicial decisions. The instrument is an administrative reporting standard and the document itself does not record contested enforcement, judicial review proceedings, or litigation outcomes. The Definitions and Notes cite statutory provisions (Insurance Act paragraphs 49J and 49L) and prudential standards, but the text does not record any precedent or litigation that has interpreted those provisions in the context of this reporting standard.

Therefore, within the four corners of the Standard provided, there is no litigation history to report. Practitioners seeking to know whether any legal challenges have concerned GRS 116.0 or the prior standard will need to search external databases (court judgments, tribunal decisions, APRA determinations or public registers) because the instrument itself contains no litigation annotations or history.

This Standard contains several operational and legal detail points that commonly trip up insurers, their finance and actuarial teams, and auditors. The following are concrete pitfalls surfaced by the Standard text:

• Gross vs net selection affects reporting scope. When an insurer chooses gross versus net for H3, H4 and NP VR bases, it determines which items must be reported. For example, if ‘gross’ is selected for NP VR (Item 1.1), the insurer must report NP PML and NP reinsurance recoverables (Item 1.2 and 1.3). If ‘net’ is chosen, the insurer reports net whole‑of‑portfolio loss (Item 1.4) instead. Mis‑selecting or inconsistently applying the gross/net choice across linked items will create internally inconsistent submissions (B table; Item 1 and Item 2.3/2.4).

• Reinsurance recoverables reporting conditional on gross basis. The Standard repeatedly conditions reporting of reinsurance recoverables on gross selection (H3/H4 reinsurance recoverables must only be reported if insurer selected ‘gross’ in the relevant item). That means insurers that choose a gross basis must map their reinsurance recoverable calculations into the required items; those using net must ensure net whole‑of‑portfolio calculations are robust (Item 2.3.3/2.4.3 and related notes).

• Reinstatement costs floor. The Standard imposes a non‑downward bias: reinstatement cost amounts "must not be less than the full original cost of the cover" unless an insurer can demonstrate to APRA that the amount materially overstates the market cost after the events (H3/H4/NP/OA reinstatement cost notes). This rule pushes insurers to report reinstatement costs at least equal to original premium cost, which may be conservative relative to some market expectations, and requires documented justification to depart.

• Inward reinstatement premiums only if contractually stipulated. Offsetting inward reinstatement premiums from cedants can be included only where the reinsurance contract "specifically stipulates that offsetting with the cedant will occur at the time of the payment of the reinsurance claim." Insurers cannot assume automatic inclusion of inward premiums; they must verify contractual language (H and NP definitions).

• Aggregate reinsurance offsets require APRA-agreed methodology. Aggregate offsets (H3/H4 and other adjustments) require that insurers agree with APRA on a methodology for determination of the adjustment. That creates a need for early engagement with APRA for insurers using aggregate reinsurance covers (H definitions).

• Multiple inception dates for catastrophe reinsurance programs. Where insurers have multiple inception dates, they must consult APRA to determine the commencement and end dates to report. Failing to consult risks inconsistent or incomplete reporting (C and E entries).

• Detailed multi-column event reporting. H3 requires three columns (first/second/third event) and H4 four columns, with separate reporting of reinsurance recoverables, aggregate offsets, reinstatement premiums and reinstatement costs per column (Item 2.3 and 2.4). Data systems must support event-level allocations and summations.

• Appointed Auditor obligations and limited assurance scope. Para 10 requires Appointed Auditors to review systems, processes and controls and to perform at least a limited assurance engagement consistent with Auditing and Assurance Standards Board guidance and GPS 310. Insurers must ensure auditors understand the specific limited assurance scope APRA expects and that auditor testing covers the systems that feed these specific items.

• Digital signature and agent retention. Electronic submissions must be digitally signed with APRA‑acceptable certificates (para 12). If an agent submits on behalf of an insurer, the insurer must retain a copy of the completed submission (para 13) and ensure proper authorisation by CEO/CFO (para 14). Failure to maintain auditable authorisation trails or the right digital certificate could lead to APRA rejecting submissions or querying authenticity.

• Units and rounding. All items must be reported in whole Australian dollars, no decimals (Units of measurement). Aggregation and rounding rules must be applied consistently across items to avoid arithmetic mismatches.

• Omission of components where immaterial. The Standard allows insurers not to report each component of the ICRC where a component is always expected to be materially lower than another (Table 1 note). But that is an expectation test , insurers will need to document materiality assumptions in case APRA asks for the omitted detail.

• Different reporting cadence per insurer. APRA can require more or less frequent reporting by written notice (para 7). Insurers facing a written notice changing cadence must operationally adjust and ensure systems and auditor schedules can meet new frequencies.

• Transitional reporting traps. For reporting periods ending before 1 July 2023 but with reporting due after revocation, insurers must report under the old standard (para 16). Overlooking this may lead to dual obligations or missed submissions around the cut-over.

Each of these items is explicitly set out in the Standard’s text or notes. Practicalising compliance therefore requires mapping contractual reinsurance terms, actuarial scenario outputs (PMLs, net whole‑of‑portfolio), reinstatement cost estimates, and systems dataflows into the Standard’s item structure, while ensuring auditor testing and Board/senior management sign‑offs are completed within the prescribed time frames.

This section offers a structured compliance checklist tied directly to the Standard’s provisions. It is operational and intended for insurers, in‑house counsel, CFOs, chief actuaries and audit teams.

1. Confirm scope and reporting periods (para 3; para 6)

   • Verify you are an "insurer" as defined under the Insurance Act (para 17). Include branches of foreign insurers operating in Australia.
   • Set reporting cadence to insurer financial year quarterly/annual by default. If APRA has notified a different cadence, record the written notice and adjust systems (para 6-7).

2. Map required items to internal systems and models (Table 1; H/N/O/P/S definitions)

   • Identify outputs that feed NP PML, net whole-of-portfolio loss, NP reinsurance recoverables, NP reinstatement cost and premiums, H3/H4 single-event losses, H3/H4 reinsurance recoverables, aggregate offsets, OA PML, OA reinsurance recoverables, OA reinstatement cost, PL offset and LMI charge per GPS 116.
   • For H3/H4, ensure you can produce event-level columns (first/second/third and fourth where required) and summations (Item 2.3.7 and 2.4.7).
   • Document logic for "gross" vs "net" selection for NP VR, H3 and H4 (B table; Items 1.1, 2.3.1, 2.4.1). Ensure choice is consistently applied across related items and is justified by modelling outcomes.

3. Reinsurance and contractual mapping (H/NP/O definitions)

   • Extract contractual clauses on reinstatement premiums, inward reinstatement offsets from cedants, aggregate treaty attachment points, and reinstatement cost rates.
   • If you plan to include aggregate offsets, prepare a proposed methodology and engage APRA early, as the Standard requires agreement with APRA (H definitions).

4. Estimate reinstatement costs consistent with the Standard (H/NP/O)

   • Use contractually agreed rates if available. If not, establish an estimation methodology based on prevailing market conditions and document assumptions.
   • Apply the floor that reinstatement cost must not be less than full original cost unless you can demonstrate to APRA that the amount materially overstates the post-event market cost. Maintain documentation supporting any departure.

5. Prepare actuarial inputs and PL offset (Definitions P)

   • Have the Appointed Actuary determine the PL offset - the portion of premium liabilities attributable to catastrophic losses.
   • Where OA PML overlaps with items already considered in premiums liabilities, calculate and document any PL adjustment to OA PML (Item 3.2).

6. Data formatting and units (Units of measurement)

   • Ensure all reported values are in whole Australian dollars (no decimal places). Create rounding rules and apply them consistently across columns and summed totals.

7. Systems, controls and audit-readiness (paras 10-11)

   • Put in place systems, processes and controls to capture and reconcile data feeding the reporting template. Ensure change controls and traceability from source systems through actuarial models to report fields.
   • The Appointed Auditor must review and test systems, processes and controls at least annually and perform a limited assurance engagement consistent with Auditing and Assurance Standards Board guidance and GPS 310 (para 10). Coordinate auditor timelines and scope early.

8. Internal approval, digital signature and agent arrangements (paras 12-14)

   • Implement a process for authorised officers or agents to digitally sign submissions using an APRA-acceptable digital certificate (para 12).
   • If using an agent, require the agent to provide a copy of the completed submission and retain it (para 13). Ensure the agent and the submitting officer are authorised by either the Principal Executive Officer or the Chief Financial Officer (para 14). Keep written authorisations on file.

9. Timing and lodgement (para 8-9, Note to para 6)

   • Build submission timelines that meet 20 business days for quarterly returns and three months for annual returns. Factor in auditor limited assurance work and any Board sign-off required for annual statutory accounts. Allow lead time for the auditor’s certificate that must be lodged with yearly statutory accounts per Insurance Act cross-references (Note to para 6).
   • If necessary, apply to APRA for an extension in writing and retain APRA’s written extension notice (para 9).

10. Engage APRA proactively for exception handling (paras 5, 7, 15; C/E/H notes)

    • Consult APRA where multiple inception dates for catastrophe reinsurance programmes exist to determine which commencement and end dates to report (C & E notes).
    • If you require a different reporting frequency or content for legitimate reasons, expect APRA to issue a written notice under para 7 or para 15; prepare a formal engagement request with supporting reasons and timelines.

11. Documentation and retention

    • Keep a complete audit trail for each reporting period: actuarial models, contract extracts, valuation methodologies (especially for reinstatement cost estimates), Board/senior management approvals of policies and procedures for authorisation of data (para 11), auditor review reports and the limited assurance engagement working papers.
    • Log any materiality judgments that permit omission of components per Table 1 note (do not assume omission without documented rationale).

12. Governance assignment

    • Ensure the Board and senior management have approved policies and procedures for data authorisation (para 11). Assign clear responsibility for ownership of each reported item (actuary, head of reinsurance, CFO, actuarial modeller, etc.) and map sign‑offs to the Principal Executive Officer or CFO authorising officer.

13. Test runs and reconciliation

    • Conduct parallel test submissions ahead of the first live reporting date under this Standard (first applicable reporting periods on/after 1 July 2023). Reconcile totals across item groupings (NP VR, NP HR, OA VR, LMI) and ensure arithmetic matches the derived item formulae in Item 1-3.

14. Review for cross-standard implications

    • Check that NP/ICRC outputs feed into capital adequacy calculations in prudential standards (GPS 116 and other capital standards referenced in the Standard). Engage capital and regulatory reporting teams to ensure the ICRC items reconcile with capital computation templates.

Following these steps will align insurer operations with the Standard’s explicit requirements (paras 4-18, Table 1 and specific item instructions). The key operational imperatives are to: (a) document gross/net choices; (b) establish reinstatement cost methodologies and documentary support; (c) get early auditor buy‑in for limited assurance coverage; and (d) maintain contemporaneous records of APRA consultations and any APRA notices altering cadence or content.