Financial Sector (Collection of Data) (reporting standard) determination No. 78 of 2023

This Standard is narrowly focused on Operational Risk Charge reporting, and uses a small set of recurring technical concepts. For practitioners the primary concepts to master in the text are ORCI, ORCNI, the central estimate of net insurance liabilities, written premium revenue (GWP), and the interplay with GPS 118 and GPS 340.

Operational Risk Charge (ORC): The ORC is manifested in two reported components:

• ORCI, the Operational Risk Charge for inwards reinsurance business, which is treated as a derived item calculated using the formula in GPS 118 (Definitions; Table 1); and
• ORCNI, the Operational Risk Charge for business that is not inwards reinsurance, also a derived item calculated in accordance with GPS 118 (Definitions; Table 1).

Derived items: The Standard repeatedly describes ORCI and ORCNI as “derived items” and instructs reporters to provide the supporting inputs rather than to supply the calculation methodology in the Standard itself (Table 1; Definitions). The calculation methodology is therefore found in GPS 118, which the Reporting Standard requires the reporter to follow (para 1).

GWP and GWP timing: For each ORC component, the Standard requires two GWP values: GWP for the 12 months ending on the reporting date, and GWP for the 12 months ending on the date 12 months prior to the reporting date (Definitions; Table 1). “Written premium revenue” is defined to include levies imposed by state and territory governments and revenue relating to portfolio transfers and unclosed business. It is explicitly gross of reinsurance for purposes of the ORC calculation (Definitions; Reporting basis).

Central estimate of net insurance liabilities: For both ORCI and ORCNI the Standard requires the central estimate of net insurance liabilities (OCL and PL components) as defined in GPS 340. Where a Level 2 insurance group uses accounting entries to determine insurance liabilities under GPS 340, the group must use the accounting net insurance liabilities instead of a net central estimate. In other words, the reporting item follows the valuation approach permitted by GPS 340 (Definitions).

Gross reporting and intra‑group consolidation: The Standard mandates that items be reported gross of any associated outwards reinsurance expense (Reporting basis). It also requires that the ORC for a Level 2 insurance group be calculated after consolidation of intra‑group exposures (Intra‑group exposures). Values must be reported in whole Australian dollars (Units of measurement).

Audit and assurance: The Group Auditor must review and test systems, processes and controls that produce the reported information on at least an annual basis and perform at least a limited assurance engagement consistent with professional auditing standards and GPS 310, unless inconsistent with GPS 310 (para 11). The Board and senior management are responsible for ensuring appropriate policies and procedures for authorisation of data submitted to APRA (para 12).

Authorisation and submission mechanics: Submissions must be digitally signed with an APRA‑acceptable digital certificate by an officer or agent (para 13), and only authorised submitters (authorised by the Principal Executive Officer or Chief Financial Officer) may submit (para 15). If an agent submits on behalf of the group, the group must obtain and retain a copy of the completed information from the agent (para 14).

Variations, discretion and transition: APRA can vary frequency and reporting periods for a particular group by written notice (para 7) and can vary the reporting requirements in relation to a particular group (para 16). Transitional arrangements require certain returns to be made under the old reporting standard where the reporting period ended before 1 July 2023 but the due date fell on or after revocation (para 17).

Interpretation cross‑references: The Standard borrows defined terms from GPS 001 unless a contrary intention appears, and defines a number of terms locally (para 18). References to Acts, Prudential Standards and Australian Accounting or Auditing Standards are to instruments as in force from time to time (para 19). Practitioners must therefore consult GPS 001, GPS 118, GPS 340, GPS 310 and GRS 001 in each reporting exercise.

Operationally, the main concepts create a measurement exercise (GWP, net liabilities), an audit and control exercise (systems, Group Auditor limited assurance), and a submission exercise (timing, digital signature, authorised officers). The linkage back to GPS 118 and GPS 340 is a structural feature: this Reporting Standard does not itself set the measure of operational risk capital, it specifies the data needed to derive it and the governance around reporting that data.

Primary obligors: The primary legal obligation in the text is placed on the parent entity of a Level 2 insurance group as defined in GPS 001. The parent entity is required to ensure each requirement in the Reporting Standard is complied with (para 3), and must provide APRA with the information required by the Standard in respect of the Level 2 insurance group for each reporting period (para 4).

Officers, agents and authorised submitters: Officers or agents who provide the information electronically must digitally sign it using an APRA‑acceptable digital certificate (para 13). Any officer or agent who submits information must be authorised by either the Principal Executive Officer or the Chief Financial Officer of the parent entity (para 15). If an external agent submits the information, the parent entity must obtain and retain a copy of the completed submission from that agent (para 14).

Board and senior management: The Board and senior management of the parent entity are explicitly assigned responsibility to ensure appropriate policies and procedures for internal review and authorisation of data submitted to APRA are in place (para 12). The Group Auditor’s review and testing obligations in para 11 implicate auditors in a regulatory assurance role.

Group Auditor: The Group Auditor of the Level 2 insurance group must review and test systems, processes and controls used to produce the reported information, on an annual basis or more frequently if necessary, and must provide at least a limited assurance engagement consistent with applicable auditing standards and GPS 310 (para 11). GPS 310 is cross‑referenced as containing the audit provisions governing the annual information.

APRA: APRA is the recipient, regulator and enforcer of the Standard. APRA can specify submission methods (para 5), change reporting periods or frequency for a particular group (para 7), grant extensions of due dates (para 9), exclude the requirement to provide half‑yearly information upon written application (para 10), and vary the reporting requirements in relation to a particular group by written notice (para 16).

Other entities referenced: The definitions section mentions APRA‑authorised reinsurers, non‑APRA‑authorised reinsurers, foreign insurers, the Australian Reinsurance Pool Corporation and Lloyd’s underwriters (Definitions). These references are relevant for how the group treats inwards reinsurance business and for determining whether business qualifies as APRA‑authorised reinsurance. The Corporations Act is referenced for the meaning of financial year (para 18). The Insurance Act 1973 is referenced in definitions (para 18).

Auditing and standards bodies: The Reporting Standard requires the Group Auditor’s review to be consistent with professional standards and guidance notes issued by the Auditing and Assurance Standards Board as may be amended from time to time, to the extent they are not inconsistent with GPS 310 (para 11). That ties the reporting to prevailing auditing norms.

Who pays and who decides: Practically, the parent entity pays the compliance costs: preparing data, running systems and controls, obtaining auditor testing and limited assurance, securing digital certificates, and internal sign‑offs. APRA decides the format, timing, any adjustments to reporting frequency, and whether to grant extensions or exclusions via written notices (paras 5-10, 16).

Who changes behaviour: The combination of required data fields, audit review, and the potential for APRA to vary requirements is likely to cause parent entities to (a) maintain or enhance measurement systems to produce the GWP and central estimates in the formats required; (b) ensure separation and identification of inwards reinsurance business for ORCI; (c) engage or coordinate closely with the Group Auditor and internal control functions to meet assurance requirements; and (d) ensure authorised officers and digital signing arrangements are in place. These are concrete operational implications flowing from paras 3-15 and the Reporting Tables.

Duties imposed by the Standard are specific and procedural. The principal duties are to collect, compute, verify and submit the required ORC‑related data in the manner and within the timeframes specified.

Duty to report: The parent entity must provide APRA with the information required by the Reporting Standard in respect of the Level 2 insurance group for each reporting period (para 4). This is a standing duty for each reporting period ending on or after 1 July 2023 (para 3).

Duty on basis of reporting periods: The Standard prescribes reporting periods and due dates. Subject to para 7, the parent entity must provide half‑yearly (unaudited) and annual (audited) information based on the group’s financial year, with annual information forming part of the group’s annual accounts in the sense of GPS 001 (para 6). The default due date for half‑yearly and annual information is within three months after the end of the reporting period, unless APRA specifies otherwise (para 8). APRA may grant an extension in writing (para 9) or, on application, exclude the half‑yearly requirement (para 10).

Duty to use specified methods and formats: Information must be given in electronic format using an electronic method available on APRA’s website or by another method notified by APRA prior to submission (para 5). Values must be completed in whole Australian dollars (Units of measurement).

Duty to follow other prudential standards: The computation of ORCI and ORCNI must be in accordance with GPS 118, and central estimate items must be determined in accordance with GPS 340, with accounting net insurance liabilities used where accounting entries have been permitted under GPS 340 (para 1; Definitions). The Group Auditor’s engagement must align with GPS 310 and applicable auditing standards (para 11).

Duty to ensure quality controls: The parent entity must ensure that the information is the product of systems, processes and controls reviewed and tested by the Group Auditor (para 11). The Board and senior management must ensure policies and procedures for authorisation of data submitted to APRA are in place (para 12).

Duty to authorise and retain records: Electronic submissions require digital signing by an officer or agent using an APRA‑acceptable digital certificate (para 13). If an agent submits on behalf of the group, the parent entity must obtain and retain a copy of the completed submission (para 14). Submitters must be authorised by the PEO or CFO (para 15).

Duty to consolidate intra‑group exposures and report gross of outwards reinsurance: The ORC is to be calculated after consolidation of intra‑group exposures (Intra‑group exposures) and all items must be reported gross of any associated outwards reinsurance expense (Reporting basis).

APRA rights and discretions: APRA may change reporting periods or specify different reporting periods for a particular group if it considers it necessary or desirable (para 7). APRA may grant extensions of due dates (para 9). APRA may, by written notice, vary the reporting requirements in relation to a particular Level 2 insurance group (para 16). APRA also sets the submission methods and acceptable digital certificates (paras 5, 13).

Recordkeeping obligations: The parent entity must retain copies of agent submissions where agents are used (para 14). Beyond that, the Standard requires the systems and controls to produce reliable information and that the Group Auditor review them, which implicitly imposes an evidentiary recordkeeping duty (paras 11-12).

Rights of the reporting entity: The Standard provides procedural mechanisms that protect the parent entity against immediate blanket enforcement without notice. These include the ability to apply to APRA to exclude the half‑yearly return (para 10), the ability to request extensions of due dates which APRA may grant in writing (para 9), and the fact that APRA must exercise variation powers by written notice (paras 7, 16). The Standard does not, however, manufacture statutory rights to withhold or alter data; the obligation to report remains unless APRA grants an exclusion or variation.

Interaction with auditing rights and duties: The Group Auditor’s role is both a duty and a gate to timely reporting. GPS 310 governs the audit of annual information and GPS 310 requires the Group Auditor conduct a limited assurance review of the group’s annual accounts; the Group Auditor’s reports as required by GPS 310 must be provided to APRA by the time specified in GRS 001 unless an extension is granted (note to para 8).

In practical terms, duties fall principally on the parent entity, its Board and senior management, authorised officers, and the Group Auditor. APRA holds the administrative discretion to tailor the reporting obligation to circumstances via written notices and to set technical submission requirements.

The text of this Reporting Standard contains no express penalty provisions or specified civil or criminal sanctions. The Standard is made under section 13 of the Financial Sector (Collection of Data) Act 2001, which is cited as the statutory authority (para 1). The Standard itself sets out reporting duties, timeframes, audit and authorisation requirements, and APRA’s administrative discretions such as granting extensions, excluding half‑yearly reporting on application, and varying reporting requirements by notice (paras 7, 9, 10, 16). It does not state the consequences for non‑compliance within its own text.

Practical implications for enforcement risk and pathways:

• APRA’s statutory data collection powers under the Financial Sector (Collection of Data) Act 2001 are the formal legal base of the Standard (para 1). Enforcement powers and penalties relating to failure to comply with data collection instruments are governed by that Act and by other prudential legislation and rules; this Reporting Standard does not restate or expand those enforcement mechanisms.
• APRA can vary reporting requirements and periods by written notice to a particular group (paras 7, 16). The ability to issue notices is an administrative lever. The Standard also grants APRA the discretion to specify methods of submission and to approve digital certificates (paras 5, 13). Non‑compliance with such notices and methods would, in practice, bring the reporter within APRA’s supervisory perimeter, but the Standard does not itself prescribe a fine, criminal penalty or administrative sanction.

Because the instrument does not specify penalties, practitioners should consult the Financial Sector (Collection of Data) Act 2001 and APRA’s enforcement policies and other prudential legislation to identify the specific statutory consequences of non‑compliance, including whether civil or criminal penalties, enforceable undertakings, directions, or other regulatory actions would be available. The Reporting Standard’s silence on penalties should therefore not be read as absence of enforcement, rather as allocation of enforcement authority and sanction detail to the underlying statutes and APRA’s broader supervisory frameworks.

Given the Standard requires audited or limited assurance reviewed information (para 11) and places duties on officers to authorise submissions (paras 13-15), failure to meet those obligations could result in supervisory actions informed by audit findings. Practitioners should therefore treat the Standard as carrying practical compliance and enforcement risk even though it does not set out specific penalties.

This Reporting Standard is primarily an information‑collection instrument that explicitly cross‑references multiple prudential and statutory instruments. Its operation is therefore interdependent with the following instruments and legal concepts contained within the text.

Financial Sector (Collection of Data) Act 2001: The Standard is made under section 13 of that Act (para 1). That Act provides APRA’s statutory power to require data from regulated entities. Enforcement mechanisms, rights of appeal, and other procedural protections will generally be contained in that Act and in APRA’s broader statutory framework; the Reporting Standard itself does not recast those mechanisms.

Prudential Standards GPS 118, GPS 340, GPS 310 and GPS 001: The Standard explicitly requires calculations to follow GPS 118 for the ORC (para 1; Table 1), values for net insurance liabilities to be determined in accordance with GPS 340 (Definitions), and audit arrangements to be consistent with GPS 310 (para 11). GPS 001 supplies shared definitions that are incorporated by reference unless a contrary intention appears (para 18). Practically, compliance requires reading those Standards alongside this Reporting Standard, because the Reporting Standard defines the data fields and governance for ORC reporting while GPS 118 and GPS 340 define the capital and valuation methodologies.

GRS 001 Reporting Requirements and its general instruction guide: The Standard must be read in conjunction with GRS 001, including the general instruction guide (para 1). GRS 001 sets out the general instruction guide and timing conventions that will determine format, submission details and other cross‑reporting matters. The Standard places reporting timelines and audit report requirements in the context of GRS 001 (note to para 8).

Corporations Act 2001 and Insurance Act 1973: The Standard borrows the Corporations Act definition of financial year for timing purposes (para 18). The Insurance Act 1973 is used in defining terms such as Lloyd’s underwriter for the purposes of determining APRA‑authorised reinsurer status (para 18). These references affect how reporting periods are aligned with statutory accounts and how insurers and reinsurers are classified.

Auditing and Assurance Standards Board guidance: The Group Auditor’s limited assurance engagement must be consistent with professional standards and guidance notes issued by the Auditing and Assurance Standards Board, to the extent not inconsistent with GPS 310 (para 11). That links the report to prevailing auditing standards and professional obligations of auditors.

Interaction with prior reporting standard (revocation): Transitional rules tie this Standard to whatever previous reporting standard was revoked when this instrument was made (para 17). Practitioners must therefore check which old standard was revoked and whether any returns remain due under it.

Administrative law and procedural fairness: The Standard grants APRA discretion to vary reporting requirements or reporting periods in writing (paras 7, 16). Those administrative actions are subject to the usual constraints of administrative law, but the Standard itself specifies only that the variations and notices be in writing. Because the Standard confers discretion, APRA’s exercise of that discretion may engage principles of reasonableness and procedural fairness in particular cases. The Standard does not provide an internal review mechanism for contesting APRA notices; contests would proceed through statutory review channels outside the Standard.

Practical coordination: In practice, a Level 2 group will have to operate at the intersection of (a) valuation rules under GPS 340, (b) operational risk charge formulae in GPS 118, (c) audit timing and engagement obligations in GPS 310, and (d) submission format and timing in GRS 001. The Standard creates interoperability requirements , for example, where GPS 340 permits accounting entries to determine liabilities, the reporter must follow that approach for the reporting item (Definitions).

In short, this Reporting Standard is an instrument for collecting specific ORC inputs, and it deliberately depends on prudential standards and statutory definitions elsewhere for substance. Practitioners must read it as part of that network of instruments.

The Reporting Standard itself, as provided, contains two discrete temporal markers rather than a chronology of amendments. First, it declares its date of application: it applies for reporting periods ending on or after 1 July 2023 (para 3). Second, it provides transition rules for reporting periods that fall under the “old reporting standard” but which ended before 1 July 2023 and were nevertheless required to be reported on or after the date that the old standard was revoked (para 17). The term “old reporting standard” is defined as the reporting standard revoked in the determination making this Reporting Standard (para 17).

What the text does not contain: The instrument as given does not supply a list of historical amendments, previous versions, or dates of revocation of earlier reporting standards. It does not describe any incremental amendments or redrafts prior to the version supplied. It does not reproduce a schedule of changes or an editorial history. It simply sets a commencement application date and transitional reporting rule.

Practical consequences for practitioners:

• Where entities have reporting obligations that straddle the revocation date, they must determine whether a particular reporting period is a “transitional reporting period” as defined in para 17. If so, reporting is to occur under the old reporting standard even if the required reporting date occurs after revocation.
• Because the Standard references that a prior reporting standard was revoked by the determination making this Standard, practitioners should consult the public instrument record (APRA legislation and determinations) to identify the revoked instrument and to confirm any differences between the old and the new requirements.
• The absence of an amendment history in the text means that supervening amendments will need to be tracked through APRA’s legislative instruments database and government gazettes. Practitioners cannot rely on this text alone for a full amendment history.

APRA’s powers to vary the reporting requirements for particular groups by notice (para 16) and to change reporting periods if APRA considers it necessary or desirable (para 7) create an operational dynamic akin to ad hoc amendments for particular entities. Those are not textual amendments of the Standard, but they alter an entity’s obligations by administrative act. For auditing, compliance and legal teams this means compliance obligations may be altered without a formal instrument amendment, and that ongoing monitoring of notices from APRA is required.

To summarise, the Reporting Standard establishes a fixed application date (1 July 2023) and a transitional rule for previously covered reporting periods (para 17), but it contains no internal record of prior amendments or a change log. Practitioners must therefore cross‑check APRA’s instrument revocation determination and monitor APRA notices and the underlying prudential standards for any subsequent changes.

The Reporting Standard document provided contains no litigation history. It does not cite any cases, adjudications, or judicial interpretations. The text does not indicate that the Standard has been the subject of litigation or of tribunal proceedings.

Implications for practitioners:

• There is no body of judicial interpretation contained in or referenced by the instrument itself to guide how its provisions have been applied by courts or tribunals.
• Where questions of legal construction or compliance arise, interpretation will need to rely on the ordinary rules of statutory and administrative interpretation and on APRA’s guidance or subsequent notices, rather than on precedent cited in the Standard.
• Disputes about APRA’s exercise of the variation powers (paras 7, 16), the scope of audit obligations (para 11), or the requirement to report under the old reporting standard for transitional periods (para 17) would have to be litigated or administratively reviewed in the usual forums; none of that material is included in the Standard itself.

Practical advice: because there is no litigation history in the instrument, prudential risk assessments must be based on the text of the Standard, related prudential standards (GPS 118, GPS 340, GPS 310, GPS 001, GRS 001), and on APRA’s administrative practice. Where novel or contentious issues arise practitioners should expect APRA guidance or seek legal advice rather than rely on judicial authority extracted from the instrument.

The Standard is concise but contains several traps for compliance, data quality and governance that are concrete and practical. Below is a targeted list of the principal “gotchas” drawn from the text.

1. Gross versus net presentation: The Standard repeatedly requires reporting “gross of any associated outwards reinsurance expense” (Reporting basis). It is common for internal actuarial or finance teams to work on net of reinsurance basis for internal KPIs. Failure to report gross values will produce inconsistent ORC inputs. The specific instruction is mandatory , report all items gross (Reporting basis).

2. Distinct treatment of inwards reinsurance: ORCI relates only to inwards reinsurance business, and is treated separately from business that is not inwards reinsurance (Definitions; Table 1). Entities must be able to identify, segregate and measure GWP and net central estimates for inwards reinsurance business specific to the Level 2 group’s inwards reinsurance operations.

3. Use of accounting entries under GPS 340: Where GPS 340 permits accounting entries to determine insurance liabilities, the Standard requires the entity to use accounting net insurance liabilities instead of the net central estimate for the reporting item (Definitions). If a group uses such accounting entries, it must ensure that the reported “central estimate” item reflects that accounting basis.

4. Timing of GWP inputs: The Standard requires two GWP measures for each ORC component , the 12 months ending on the reporting date, and the 12 months ending 12 months prior to the reporting date (Table 1). Residual or overlapping periods in systems not designed to produce both measures accurately can cause reporting errors.

5. Unit and rounding: Values must be completed in whole Australian dollars (Units of measurement). Rounded or foreign‑currency figures not converted properly will be non‑compliant.

6. Group Auditor limited assurance frequency and scope: The Group Auditor must review and test systems and controls on at least an annual basis and perform at least a limited assurance engagement in line with Auditing and Assurance Standards Board guidance and GPS 310 (para 11). Entities that have not planned for auditor time to perform a limited assurance engagement on ORC reporting every year will face scheduling and cost shocks.

7. Digital certificate acceptance: Electronic submissions require a digital certificate acceptable to APRA (para 13). Entities must obtain and manage an APRA‑acceptable certificate rather than relying on an internal signatory process.

8. Authorisation by PEO or CFO: Only submissions authorised by the Principal Executive Officer or the Chief Financial Officer are valid (para 15). An authorised agent alone cannot substitute; internal sign‑off workflows must be in place.

9. Agent retention requirement: If an agent submits on behalf of the parent entity, the parent entity must obtain and retain the completed submission copy from the agent (para 14). Failure to maintain that copy would contravene the Standard.

10. APRA variation and tailored reporting: APRA can change reporting frequency and requirements by written notice for a particular Level 2 group (paras 7, 16). Those variations may be retrospective in operational effect and require rapid system changes.

11. Transitional reporting obligations: Reports for transitional reporting periods must be made under the old reporting standard even if their due date fell after revocation (para 17). Practitioners must confirm which old standard was revoked and whether any outstanding returns exist.

12. Duplication and repetition in the text: The document repeats Reporting Tables and Specific instructions sections. Ensure that the controller of the report uses the defined Table 1 items and the Specific instructions consistently rather than assuming the repetition signals a different requirement.

13. “Any specific combination…must not appear on more than one row”: The Reporting Tables section states that any specific combination of values in the table must not appear in more than one row when reported. This constrains data de‑duplication and row mapping during electronic submission.

14. Reliance on external standards: Because ORC calculations are derived using GPS 118 and valuation inputs follow GPS 340, errors in interpreting those prudential standards will bleed into reporting. The Reporting Standard does not restate GPS 118 or GPS 340; it assumes those rules are correctly applied.

15. No penalty text within the Standard: The Standard does not specify penalties; enforcement is governed by the underlying statute. Do not assume absence of enforcement simply because the Standard is silent on penalties.

These items are concrete technical and administrative risks that will require operational responses in systems, data governance, audit scheduling and internal approvals. Each is grounded in a specific paragraph or section of the Standard: gross reporting and intra‑group consolidation (Reporting basis; Intra‑group exposures), definitions and measurement rules (Definitions; Table 1), audit obligations (para 11), authorisation and digital signature (paras 13-15), and APRA’s notice powers (paras 7, 16).

A compliance roadmap based on the Standard’s textual requirements follows. This is an operational checklist for parent entities of Level 2 insurance groups to move from obligation to compliant submission.

1. Governance and responsibility

• Confirm the entity is indeed the parent of a Level 2 insurance group as defined in GPS 001 and that the Standard applies to your reporting periods ending on or after 1 July 2023 (para 3).
• Assign executive accountability to the PEO or CFO for authorising submissions (para 15).
• Ensure the Board and senior management adopt policies and procedures for authorisation and internal review of data submitted to APRA, as required (para 12).

2. Data definitions and measurement

• Map the required data items in Table 1 to existing systems: ORCI and ORCNI supporting items are the two GWP measures (GWP ending on reporting date and GWP ending on date 12 months prior) and the central estimate of net insurance liabilities for inwards reinsurance and non‑inwards business (Definitions; Table 1).
• Confirm whether GPS 340’s accounting entry option has been used to determine insurance liabilities. If so, prepare the accounting net insurance liabilities for reporting instead of a derived net central estimate (Definitions).
• Ensure written premium revenue includes levies, portfolio transfers and unclosed business where applicable, and is reported gross of outwards reinsurance (Definitions; Reporting basis).

3. Systems, controls and consolidation

• Consolidate intra‑group exposures for the Level 2 insurance group and compute the ORC after consolidation as required (Intra‑group exposures).
• Convert all reporting values into whole Australian dollars adhering to the units of measurement requirement.
• Implement or confirm controls that prevent any specific combination of table values from appearing on more than one row in the reported dataset (Reporting Tables).

4. Audit and assurance

• Engage the Group Auditor to review and test the systems, processes and controls that produce the reported information on at least an annual basis, and arrange for at least a limited assurance engagement consistent with Auditing and Assurance Standards Board guidance and GPS 310 (para 11).
• Coordinate audit timing with the group’s financial year so that annual information can be audited and included in the group’s annual accounts as required (para 6 note; GPS 310 cross‑reference).

5. Submission mechanics

• Confirm the electronic submission method available on APRA’s website, or request notice of an alternative method if necessary (para 5).
• Obtain an APRA‑acceptable digital certificate for the signing officer or agent who will submit the electronic report (para 13).
• Put in place internal authorisation workflows so that any submitter is authorised in writing by the PEO or CFO prior to submission (para 15).
• If an agent will submit on your behalf, ensure the agent understands the obligation to provide the parent entity with a copy of the completed submission and retain that copy in the group’s records (para 14).

6. Timing and extensions

• Schedule half‑yearly unaudited submissions and annual audited submissions in accordance with the group’s financial year and the requirement to submit within three months after the end of the relevant reporting period (paras 6(a), 6(b), 8).
• If necessary, prepare a written application to APRA to exclude half‑yearly reporting (para 10), or promptly request an extension of the due date in writing if the group cannot meet the standard three‑month deadline (para 9).

7. Liaison with APRA

• Monitor for written notices from APRA that change reporting periods, frequency or the Standard’s application to the particular group (paras 7, 16).
• Where APRA issues a variation or a specified reporting period, follow the notice carefully and adjust systems and audit plans to meet the revised schedule.

8. Documentation and recordkeeping

• Maintain records of the data inputs, calculation steps, control testing, and the Group Auditor’s work papers to support the limited assurance engagement and any subsequent APRA enquiries (para 11).
• Retain copies of all submissions, including agent copies where relevant (para 14).

9. Cross‑reference other standards

• Ensure ORC calculations and liability valuations are performed in strict accordance with GPS 118 and GPS 340 respectively, and that the Group Auditor’s engagement is consistent with GPS 310. Because the Reporting Standard defers to those instruments for measurement and audit substance, accurate cross‑reference and alignment is essential (para 1; Definitions; para 11).

10. Internal testing and dry runs

• Conduct submission dry runs to validate format, rounding to whole AUD, row uniqueness constraints and digital signing procedures ahead of the actual due dates. This will surface issues with row mapping, duplication rules, and the APRA electronic method.

11. Contingency planning

• Develop contingency plans to obtain APRA extensions (para 9), apply for exclusion of half‑yearly reporting if justified (para 10), and to respond promptly to any APRA notice varying reporting requirements (paras 7, 16).

12. Review of transitional obligations

• Identify any transitional reporting periods that remain subject to the old reporting standard under para 17, and ensure those returns are filed under the old standard if applicable. Confirm which old reporting standard was revoked by the determination.

Costs and compliance burdens to budget for

• Systems work to produce separate GWP measures and central estimate figures for inwards reinsurance and non‑inwards business.
• Auditor fees for the Group Auditor’s annual systems review and limited assurance engagement.
• Procurement and management of APRA‑acceptable digital certificates.
• Internal resources to establish and maintain authorisation workflows and retention of agent submissions.
• Possible changes and implementation costs if APRA issues group‑specific variations or shifts reporting frequency.

Following this roadmap aligns organisational responsibilities with the Standard’s textual requirements: data mapping to Table 1 items; audit and assurance consistent with para 11; digital signing and authorised submitter requirements in paras 13-15; timing and extension rules in paras 6-10; and adherence to GPS 118 and GPS 340 for the substantive calculations (paras 1, Definitions).