Financial Sector (Collection of Data) (reporting standard) determination No. 77 of 2023

The Reporting Standard defines a narrow set of recurring data concepts tied to the Operational Risk Charge framework used in APRA’s capital adequacy regime. The principal concepts are:

• Operational Risk Charge for inwards reinsurance business (ORCI): defined as the operational risk charge relating to the insurer’s inwards reinsurance business, calculated using GPS 118 (definitions table; Table 1 Item 1). The Standard treats ORCI as a derived item but requires insurers to report component inputs: ORCI GWP for the 12 months ending on the reporting date; ORCI GWP for the 12 months ending 12 months prior to the reporting date; and a central estimate of net insurance liabilities for the inwards reinsurance business (Table 1 Items 1.1-1.3).
• Operational Risk Charge for business that is not inwards reinsurance (ORCNI): analogous to ORCI but for business written directly by the reporting insurer. ORCNI is also a derived item calculated per GPS 118; insurers must report the same three component items for the non-inwards reinsurance book (Table 1 Items 2.1-2.3).
• Gross written premium (GWP): defined for both ORCI and ORCNI components as written premium revenue recognised for specified 12-month periods (definitions). Importantly, the definition expressly includes levies imposed by state and territory governments, revenue from portfolio transfers and from unclosed business (definitions for GWP fields).
• Central estimate of net insurance liabilities: the central estimate component of outstanding claims liabilities (OCL) and premium liabilities (PL), net of recoveries relating to the gross OCL and PL, determined in accordance with Prudential Standard GPS 340 Insurance Liability Valuation (definitions).
• Reporting basis and units: all items must be reported gross of any outwards reinsurance expense (specific instructions) and in whole Australian dollars (specific instructions).
• Derived items versus reported inputs: the Standard distinguishes the inputs insurers must report (GWP measures and central estimates) and the derived outputs (the ORCI and ORCNI) that are to be calculated in accordance with GPS 118 (Table 1 and definitions).
• Audit and assurance: the Appointed Auditor must review and test reporting systems and controls on an annual basis or more frequently if necessary and perform at least a limited assurance engagement consistent with relevant Australian auditing and assurance standards and GPS 310 (para 10).
• Agency and authorisation mechanics: submissions must be digitally signed by an officer or agent using a certificate acceptable to APRA; if an agent submits the insurer must retain a copy of the completed submission; submitters must be authorised by the Principal Executive Officer or Chief Financial Officer (paras 12-14).

The Standard expressly cross-references other prudential instruments and statutes for definitions and valuation methods: GPS 118 for the operational risk charge formula, GPS 340 for valuation of central estimates, GPS 001 for defined terms, GRS 001 for reporting procedures and a “general instruction guide” (paras 1, 17, Table 1). These references make the core concepts operationally dependent on other prudential standards and guidance.

These conceptual choices mean insurers will not only collect premium and liability estimates, they must ensure those figures are prepared in the manner required by GPS 340 and that they are reported gross, in whole AUD. APRA retains the authority to recast reporting frequency or specific requirements for an insurer (paras 7, 15), which influences how granular or flexible insurers need to make their reporting systems.

The Standard applies to "insurers", defined as general insurers within the meaning of section 11 of the Insurance Act, and expressly states it applies to all general insurers authorised under the Insurance Act (para 3; definitions para 17). The definitions also identify related entities and concepts that may appear in reporting:

• Insurers authorised under the Insurance Act (primary obligors) (para 3).
• Foreign insurers operating in Australia by branch: the Definitions note that references to a branch or branch operation refer to the Australian operations of a foreign insurer (para 17 definitions).
• APRA-authorised reinsurers and non-APRA-authorised reinsurers are defined; a Lloyd’s underwriter is an APRA-authorised reinsurer if it carries on reinsurance business, and the Australian Reinsurance Pool Corporation is included as an APRA-authorised reinsurer for the purposes of the definition (definitions para 17).
• Agents or third-party submitters: persons or firms that submit the information on an insurer’s behalf are covered by authorisation and record-retention rules (paras 12-14).

Who pays and bears costs

• The insurer bears the operational and compliance cost of providing data, maintaining systems and controls, retaining records of agent submissions, and engaging the Appointed Auditor to perform the required review and limited assurance engagement (para 10; paras 12-14).
• Where an agent submits data on behalf of an insurer, the insurer must obtain and retain a copy of the completed submission (para 13), which transfers record-keeping tasks to the insurer after submission.

Who decides

• APRA decides the reporting format and method (electronic via APRA’s website or another notified method), and may change the reporting periods or frequency for particular insurers by written notice (paras 5-7).
• APRA may vary reporting requirements for a particular insurer by written notice (para 15).
• The insurer’s board and senior management remain responsible for internal policies and procedures for data authorisation and the reliability of the submitted data; the Appointed Auditor provides an external review and limited assurance (para 11; para 10).

Behavioural effects

• Insurers must organise reporting systems to produce GWP figures and central estimate values in the format required, keep the data gross of outwards reinsurance, and ensure the central estimate is calculated in accordance with GPS 340 (definitions; specific instructions).
• The requirement that the Appointed Auditor review and test systems and provide limited assurance on a recurring basis incentivises insurers to document and control data flows used for APRA reporting (para 10).
• APRA’s capacity to vary frequency or requirements for specific insurers incentivises insurers to maintain readiness for ad hoc changes in reporting cadence (paras 7, 15).

Entities not covered

• The Standard is specific to general insurers authorised under the Insurance Act; it does not purport to apply to life insurers, superannuation entities, banks or other financial institutions unless those entities are general insurers under the Insurance Act (para 3; definitions).

This section summarises the explicit positive duties imposed by the Standard and the rights or discretions available to APRA and to insurers as set out in the text.

Mandatory duties placed on insurers

• Provide the information required by the Reporting Standard for each reporting period (para 4).
• Submit required information electronically via APRA’s website or other APRA-notified method (para 5).
• Meet reporting periods: quarterly and annual reporting based on the insurer’s financial year (para 6); comply with due dates , quarterly within 20 business days, annual within three months (para 8).
• Ensure annual information that forms part of yearly statutory accounts is audited consistent with paragraph 49J(1)(a) of the Insurance Act and that the principal auditor provides the certificate required under subsection 49J(3) (para 6 note).
• Ensure the data are the product of systems, processes and controls reviewed and tested by the Appointed Auditor; the Appointed Auditor must review and test on an annual basis or more frequently and at least perform a limited assurance engagement in accordance with professional standards and GPS 310 (para 10).
• Maintain internal systems, processes and controls for internal review and authorisation of reported information; the Board and senior management are responsible for ensuring appropriate policies and procedures exist (para 11).
• Digitally sign electronic submissions with an APRA-acceptable digital certificate (para 12).
• If using an agent, obtain and retain a copy of the completed information provided to APRA (para 13).
• Ensure that submitters (officers or agents) are authorised by the Principal Executive Officer or Chief Financial Officer (para 14).

APRA’s rights and discretions

• Change reporting periods or specify reporting periods for a particular insurer by written notice if APRA considers it necessary or desirable (para 7).
• Grant extensions of due dates in writing (para 9).
• Vary reporting requirements in relation to a specific insurer by written notice (para 15).
• Prescribe submission method (para 5).

Reporting content duties

• Report ORCI and ORCNI component items (GWP for two rolling 12-month periods and central estimate of net insurance liabilities) and in whole Australian dollars; report gross of any associated outwards reinsurance expense (specific instructions; Table 1).

Enforceable rights and obligations tied to other legislation

• The annual reporting requirement ties into the Insurance Act’s yearly statutory accounts and auditor certificate obligations noted in the Standard’s explanatory notes (para 6 note). That creates an interlocking obligation between this Reporting Standard and statutory audit obligations under the Insurance Act (para 6 note).
• Definitions and terms are to be read in the context of GPS 001 and other prudential standards (para 17), which means insurers have the right to interpret terms using those primary instruments when preparing reports.

Procedural duties for transition and variation

• Insurers must follow transition rules if they have a reporting period under the old reporting standard that ended before 1 July 2023 but for which reporting was due after revocation (para 16).
• Where APRA issues a notice changing reporting periods or varying requirements, insurers must comply within the timeframes specified (paras 7, 15, 8(c)).

Rights of insurers

• Insurers may receive extensions of due dates from APRA in writing (para 9).
• Insurers may be notified by APRA of alternative submission methods (para 5(b)).
• The Standard does not itself grant appeal rights; the text is silent on appeal or dispute resolution mechanisms concerning APRA’s notices or variations.

Interplay between duties

• The duty to have an Appointed Auditor perform reviews and limited assurance (para 10) interacts with the Insurance Act’s yearly statutory accounts and auditor certificate requirement (para 6 note). Insurers must structure audit evidence and internal controls to serve both APRA reporting and statutory audit certificate obligations.

The Reporting Standard text itself does not set out civil or criminal penalties or a bespoke enforcement regime. It prescribes reporting obligations, audit and assurance requirements, and administrative procedures (paras 4-15, 10-14), but contains no clause that prescribes fines, sanctions, or specific enforcement measures within this instrument.

What the Standard does specify about enforcement-adjacent mechanisms

• APRA’s administrative discretions: APRA may change reporting periods or frequency for particular insurers (para 7), vary reporting requirements by written notice (para 15), and grant extensions of due dates in writing (para 9). These are administrative powers rather than specified penalties.
• Audit linkage into statutory obligations: the Standard notes that annual information forms part of the insurer’s yearly statutory accounts within the meaning of section 3 of the Insurance Act and must be audited in accordance with paragraph 49J(1)(a) of the Insurance Act; the principal auditor must give the insurer a certificate under subsection 49J(3), and that certificate must contain statements of the auditor’s opinions on matters required by prudential standards (para 6 note). Non-compliance with statutory accounts or audit requirements under the Insurance Act may engage the legal consequences in the Insurance Act, but those consequences are not specified here.
• Authorisation mechanics: the Standard requires digital signature using an APRA-acceptable digital certificate (para 12) and insurer-authorisation of submitters (para 14). Failure to meet these procedural rules may lead to APRA querying or rejecting submissions, but the Standard does not specify the consequences.

What is not in the Standard

• Specific civil sanctions, pecuniary penalties, or criminal offences are not established in this Reporting Standard text.
• The Standard does not set out enforcement processes such as infringement notices, directions, civil penalties, or administrative notices with specified consequences.

How to interpret enforcement risk

• Because the Standard is made under section 13 of the Financial Sector (Collection of Data) Act 2001 (para 1), failure to comply with the data collection powers exercised under that Act could lead to enforcement action under the parent statute or other prudential statutes. The Standard itself does not recapitulate those downstream enforcement powers. Users must therefore consult the Financial Sector (Collection of Data) Act 2001 and the Insurance Act for statutory enforcement provisions applicable to failures to provide information or to meet statutory audit obligations (para 1; para 6 note).
• APRA’s ability to vary or require different reporting cadence (paras 7, 15) gives it tools to address non-compliance administratively (for example, requiring more frequent reporting), but the Standard does not describe sanctions for failing to comply with APRA’s notices.

Practical consequence

• The practical enforcement environment is therefore a combination of: this Reporting Standard’s mandatory reporting and audit requirements (paras 4-14), APRA’s administrative discretion (paras 7, 9, 15), and the statutory enforcement powers that sit in the Financial Sector (Collection of Data) Act and the Insurance Act which are referenced but not set out in the text (para 1; para 6 note). Users should consult those Acts for explicit sanctioning powers.

The Reporting Standard is explicitly drafted as an information-collection instrument that operates in a network of prudential standards and statutes. The text cross-references multiple instruments; its operation must be read in conjunction with those instruments.

Statutory authority

• The Standard is made under section 13 of the Financial Sector (Collection of Data) Act 2001 (para 1). That Act supplies the legal power for APRA to make the Reporting Standard. To understand the full scope of APRA’s enforcement or notice powers vis-à-vis data collection, one must read that Act alongside this Standard (para 1).

Insurance Act linkages

• The Standard applies to insurers authorised under the Insurance Act 1973 (para 3) and it links annual reporting obligations to the Insurance Act’s yearly statutory accounts and audit certificate requirements (para 6 note, referencing paragraph 49J(1)(a) and subsection 49J(3) of the Insurance Act). Consequently, annual reporting under this Standard becomes part of statutory accounts obligations under the Insurance Act, and insurers must ensure compliance with the Insurance Act’s audit and certification requirements.

Prudential standards and definitions

• Definitions: words and expressions are to be read as defined in Prudential Standard GPS 001 Definitions unless a contrary intention appears (para 17(a)). That places GPS 001 as the primary definitional source.
• Capital adequacy and ORC calculation: the Standard uses GPS 118 as the source of the ORC formula and treats ORCI and ORCNI as derived items calculated in accordance with GPS 118 (Table 1 and definition entries). Therefore, changes in GPS 118 will directly affect the derived ORC values and may change reporting expectations.
• Insurance liability valuation: determination of the central estimate of net insurance liabilities is to be done in accordance with Prudential Standard GPS 340 Insurance Liability Valuation (definitions and Table 1). GPS 340 governs the accounting/valuation basis for OCL and PL components, so any changes to GPS 340 will change how insurers compute central estimates for this Reporting Standard.
• Audit and assurance: the Appointed Auditor’s review and limited assurance engagement must be consistent with professional standards issued by the Auditing and Assurance Standards Board and with Prudential Standard GPS 310 Audit and Related Matters (para 10). This ties APRA’s reporting audit requirements to national auditing standards and GPS 310.

Reporting framework cross-reference

• GRS 001 Reporting Requirements: the Standard must be read in conjunction with GRS 001 and the general instruction guide (para 1 and para 17 definitions). GRS 001 sets out broader reporting procedures, and the general instruction guide (Attachment A of GRS 001) contains cross-cutting instructions such as lodgement mechanics, nil reporting, and other standard reporting obligations that will affect implementation of this Standard.

Corporations Act reference

• The term “financial year” is defined by reference to the Corporations Act 2001 (definitions para 17), so reporting periods are aligned to statutory accounting periods governed by the Corporations Act.

Transition and revocation interactions

• The Standard includes a transitional rule referencing an "old reporting standard" revoked when this Standard was made; transitional reporting periods that ended before 1 July 2023 but for which reporting was due on or after revocation must still be reported under the old standard (para 16). This creates an interaction with the previous instrument and its revocation process.

Operational consequences of these interactions

• Insurers preparing reports under this Standard must ensure internal systems and valuation methodologies are consistent with GPS 340 and GPS 118; they must align audit evidence and processes with GPS 310 and Australian auditing standards; and they must follow reporting procedures and timing in GRS 001. Changes in any of those instruments will affect reporting content, calculation method, audit approach and timing.
• APRA’s administrative discretion to change periods or vary requirements (paras 7, 15) operates within the statutory powers conferred by the Financial Sector (Collection of Data) Act and the Insurance Act. That means insurers should monitor changes not only to this Standard but to the cross-referenced prudential standards and to relevant statutory provisions.

The instrument text itself identifies a commencement date and an express transitional rule; it does not provide a multi-item amendment history or a schedule of previous versions inside the text provided.

What the text states about commencement and transition

• Commencement: the Standard applies for reporting periods ending on or after 1 July 2023 (para 3).
• Transition: paragraph 16 provides specific transitional arrangements. It defines "old reporting standard" as the reporting standard revoked in the determination making this Reporting Standard, and "transitional reporting period" as a reporting period under the old reporting standard which ended before 1 July 2023 and in relation to which the insurer was required, under the old reporting standard, to report by a date on or after the date of revocation (para 16).
• The note following para 16 clarifies that if reporting was due before the revocation date under the old reporting standard, the insurer must still provide overdue reporting documents under the old reporting standard (para 16 note).

What the text does not state

• The Standard does not include a schedule of prior amendments, version numbers, or dates of revocation beyond the transitional description. It does not list footnote-style changes or prior instrument titles. The text names only that an old reporting standard was revoked in the making of this Standard but does not reproduce that old instrument or its date of revocation.

Practical implication for record-keeping and audit evidence

• Because annual information is integrated with yearly statutory accounts (para 6 note), auditors and insurers must ensure continuity between reporting under the old standard and the new one for transitional periods. Where reports due under the old standard were outstanding at revocation, insurers still must provide those reports (para 16 note).
• Where GPS 118, GPS 340, GPS 001, or GPS 310 are amended after the commencement date, insurers will need to reconcile the effect of those amendments on reporting requirements because the Standard incorporates those instruments by reference (para 17 and cross-references in Table 1 and para 10).

Recommendation for practitioners (procedural)

• Practitioners should maintain a change log that maps: (a) the old reporting standard obligations for any transitional periods; (b) the new reporting standard obligations post-1 July 2023; and (c) any subsequent amendments to GPS 118, GPS 340, GPS 310, GPS 001 and GRS 001 that alter definitions, valuation methods or audit requirements. The text provides the cross-references to monitor (paras 1, 6 note, para 10, para 17).

The Reporting Standard text contains no references to litigation, judicial decisions, or case law. It names no court decisions, administrative appeals, or enforcement actions. There is therefore no litigation history recorded in the instrument provided.

What the absence of litigation references means in practice

• The instrument is a regulatory reporting standard and does not itself document disputes or litigation. Any legal disputes about compliance, enforcement or interpretation would arise under the Financial Sector (Collection of Data) Act 2001, the Insurance Act, or in the context of APRA’s supervisory actions, but those are not recited here.
• Because the Standard ties annual reporting to statutory accounts and audit certificates (para 6 note), litigation regarding audit opinions or statutory accounts would typically involve the Insurance Act audit/certification framework rather than this Reporting Standard in isolation. However, the text does not provide any examples, authorities, or descriptions of prior litigation.

Consequences for research or advice

• Practitioners seeking precedential guidance on how courts or tribunals have interpreted similar reporting standards or APRA’s exercise of data collection powers must consult external jurisprudence from the Financial Sector (Collection of Data) Act, Insurance Act, or APRA decisions; such sources are not included in the instrument provided.
• Advice on enforcement risk or disputes should therefore be anchored in the underlying statutes and any relevant APRA regulatory determinations or decisions rather than in this Standard’s text, which contains no litigation record.

This section highlights potential traps and friction points that arise directly from the text and the specific wording of the Standard.

1. Reporting gross, not net

• The Standard requires reporting all items gross of any associated outwards reinsurance expense (specific instructions: “Report all items gross of any associated outwards reinsurance expense”). Practitioners must not net out reinsurance when preparing the GWP and central estimate fields.

2. Which GWP to include

• GWP includes levies imposed by state and territory governments, revenue relating to portfolio transfers, and unclosed business (definitions for GWP fields). Omitting any of these items will produce an incorrect GWP value relative to APRA’s expectations.

3. Central estimate must follow GPS 340

• The central estimate of net insurance liabilities must be determined in accordance with Prudential Standard GPS 340 (definition for ORCI/ORCNI central estimate). Using a different valuation basis or an accounting estimate inconsistent with GPS 340 will be non-conforming.

4. Derived items vs reported inputs

• The ORCI and ORCNI are described as “derived items” calculated using GPS 118 (Table 1). Insurers must report the component inputs (Items 1.1-1.3 and 2.1-2.3) rather than substituting an internally calculated ORC that uses a different formula or approach. APRA will derive ORC values in accordance with GPS 118.

5. Units and rounding

• The Standard requires whole Australian dollars (specific instructions: “This values in this table must be completed in whole Australian dollars”). Report fields must not contain cents or other fractional units.

6. Digital signature and authorisation

• Electronic submissions must be digitally signed using a digital certificate acceptable to APRA (para 12). The Standard does not prescribe acceptable certificate providers; insurers must ensure their certificate meets APRA requirements and that the submitter is authorised by the PEO or CFO (para 14).

7. Agent submissions: retention obligation

• If an agent submits, the insurer must obtain and retain a copy of the completed information provided to APRA (para 13). Failure to obtain that copy leaves the insurer without the evidence APRA may require.

8. Auditor scope and timing

• The Appointed Auditor must review and test systems and controls at least on an annual basis and must perform a limited assurance engagement consistent with professional standards and GPS 310 (para 10). Insurers must budget and plan audit work to meet both timing and scope requirements.

9. Due dates still bind on non-business days

• The Standard notes that if a due date falls on a day other than a usual business day, the insurer is nonetheless required to submit the information no later than the due date (para 9 Note). This avoids “next-business-day” relief and requires firms to plan for deadlines that may fall on weekends or public holidays.

10. APRA may change reporting frequency for a given insurer

• APRA can require more or less frequent reporting for a particular insurer by written notice (para 7). Insurers should maintain flexible reporting processes to respond to such notices without extensive systems rebuild.

11. Annual information forms part of statutory accounts and needs auditor certificate

• Annual information required by this Standard forms part of the insurer’s yearly statutory accounts under section 3 of the Insurance Act and must be audited under paragraph 49J(1)(a) with the principal auditor providing a certificate (para 6 note). Insurers must coordinate their statutory audit timetable with APRA reporting obligations.

12. Multiple cross-references to other instruments

• Terms, valuation bases and audit standards are defined in GPS 001, GPS 118, GPS 340, GPS 310 and GRS 001 (paras 1, 10, 17; Table 1). A change in any of those instruments will alter reporting obligations. Ensure the reporting team monitors amendments to those documents.

13. Transition complexity

• Transitional reporting obligations require attention to the “old reporting standard” and its revocation timing (para 16). If reports were due under the old standard before revocation, insurers must still provide overdue filings under the old standard (para 16 note). Failure to track which standard governs a particular reporting period could produce misfiling.

14. No penalties specified in this instrument

• Because the Standard does not itself set out penalties, insurers might underestimate enforcement risk. Enforcement consequences are likely to be found in the Financial Sector (Collection of Data) Act or Insurance Act; practitioners should not assume the absence of sanctions simply because this instrument contains none (paras 1 and 6 note).

15. Data uniqueness constraint in tables

• The Reporting Tables section requires that any specific combination of values in the table must not appear on more than one reported row. Insurers with reporting systems that produce duplicated records must deduplicate records to comply.

This section sets out a practical, source-grounded compliance checklist and implementation blueprint derived from explicit requirements in the text.

1. Governance and responsibilities

• Confirm the Board and senior management have approved policies and procedures for authorisation of data submitted to APRA, and ensure documentation of those policies (para 11).
• Designate who will be authorised to submit information and obtain written authorisation from the Principal Executive Officer or Chief Financial Officer for each officer or agent who submits (para 14).

2. Data capture and calculation

• Implement processes that produce the three component items for both ORCI and ORCNI:
  • GWP for the 12 months ending on the reporting date (Items 1.1 and 2.1).
  • GWP for the 12 months ending on the date 12 months prior to the reporting date (Items 1.2 and 2.2).
  • Central estimate of net insurance liabilities for the relevant book (Items 1.3 and 2.3). (Table 1; definitions)
• Ensure GWPs include levies, portfolio transfers and unclosed business, and that the reported values are gross of outwards reinsurance expense (definitions; specific instructions).
• Ensure the central estimate of net insurance liabilities is prepared in accordance with GPS 340 (definitions).

3. Systems, controls and auditability

• Maintain systems and controls that capture the required inputs and generate auditable evidence of calculations and sign-off, because the Appointed Auditor must review and test those systems and controls on at least an annual basis and perform a limited assurance engagement (para 10).
• Document control flows and reconciliation steps between source systems (policy admin, claims, general ledger) and the reporting dataset to support the Appointed Auditor’s testing.

4. Audit engagement planning

• Engage the Appointed Auditor to build the required review and testing into the annual audit plan and to conduct a limited assurance engagement consistent with Auditing and Assurance Standards Board guidance and GPS 310 (para 10).
• For annual information that forms part of the yearly statutory accounts, coordinate the Appointed Auditor’s certificate under the Insurance Act with the submission timetable (para 6 note).

5. Submission mechanics

• Use APRA’s electronic submission channel as the primary method (para 5(a)). If proposing an alternative method, obtain APRA’s prior notification (para 5(b)).
• Ensure digital certificates used for signing are acceptable to APRA and keep records proving the certificate’s validity at submission (para 12).
• If using an agent to submit, ensure contractual arrangements require the agent to provide the insurer with a copy of the completed submission and maintain that copy in the insurer’s records (para 13).

6. Timeframes and calendar

• Implement a reporting calendar aligned to the insurer’s financial year with clear deadlines:
  • Quarterly reports: submit within 20 business days of the quarter end (para 8(a)).
  • Annual reports: submit within three months of the financial year end (para 8(b)).
• Build processes to ensure submissions are made even where due dates fall on non-business days, as the Standard requires submission no later than the due date (para 9 note).
• Monitor for any APRA notices changing an insurer’s reporting frequency or due dates and be prepared to comply within the revised timeframe (paras 7, 9, 15).

7. Units and formatting

• Report all numeric values in whole Australian dollars. Remove fractional currency amounts and ensure export from source systems truncates or rounds consistently with the Standard’s requirements (specific instructions: units of measurement).

8. Reconciliation and quality control

• Implement reconciliations between reported GWP and central estimate items and the insurer’s financial statements and management accounts, so annual statutory accounts and the APRA submission are consistent (para 6 note).
• Maintain an internal authorisation log demonstrating Board/senior management approval of policies and sign-off on datasets (para 11).

9. Handling derived items and calculation alignment

• Do not substitute an alternate ORC calculation; report the component items and allow APRA to derive ORCI and ORCNI using GPS 118, unless APRA specifies otherwise (Table 1).
• Ensure that any internal ORC calculations performed for management purposes use the GPS 118 formula if they are used to prepare data submitted to APRA.

10. Transition and legacy filings

• Review pre-1 July 2023 reporting obligations and ensure any transitional reporting periods required to be reported under the old reporting standard are filed in accordance with paragraph 16 and its note (para 16).

11. Monitoring and change control

• Maintain a monitoring process for amendments to GPS 118, GPS 340, GPS 001, GPS 310 and GRS 001 because these instruments are incorporated by reference and changes will affect reporting content, valuation basis and audit procedures (paras 1, 10, 17, Table 1).
• Establish a change-control protocol to implement APRA’s notices varying requirements or frequency for the insurer (paras 7, 15).

12. Documentation retention

• Retain the complete submission copy (including agent-submitted copies), audit working papers supporting reported figures, digital certificate evidence and authorisation records in line with internal record-retention policies and to satisfy APRA or statutory audit inquiries (paras 12-14; para 13).

13. Practical testing

• Before the first submission under this Standard, conduct an end-to-end dry run that includes:
  • Producing the required GWP and central estimate fields in whole AUD.
  • Having the Appointed Auditor perform a limited assurance engagement on the controls and outputs.
  • Executing the electronic submission process and digital signature to confirm certificate acceptance by APRA.
  • Confirming that the insurer can obtain and retain a copy of the submission if using an agent.

14. Responding to APRA notices

• If APRA exercises its discretion to change reporting frequency or vary requirements for the insurer (paras 7 and 15), treat such notices as binding and allocate resources to meet the revised cadence or data specifications within the time specified by APRA (para 8(c)).

Following this checklist aligns day-to-day implementation with the precise obligations stated in the Standard: reporting inputs (Table 1), submission mechanics (para 5), timeframes (para 8), audits and assurance (para 10), and authorisation and retention (paras 12-14).