The Reporting Standard organises obligations around a small number of conceptual pillars that determine scope, data content, frequency and governance. These pillars are:

• Scope of reporters, defined by guarantee receipt: The Standard applies only to ADIs and RFCs that were granted a guarantee under the specified Guarantee Act up to 30 September 2020, labelled Phase 1 (paragraph 3, definition of Phase 1 at paragraph 15). “ADI” is defined by reference to the Banking Act 1959, and APRA is defined by reference to the APRA Act 1998 (paragraph 15).

• Forms and data types: Two reporting forms are mandatory. ARF 920.0 collects portfolio-level measures including counts and dollar amounts for loans approved, cancelled/refinanced loans, write-offs, recoveries, guarantee claims and guarantee payments, and as-at balances such as credit outstanding, unused credit, amounts 30 days past due and impaired exposures, plus a weighted average customer rate (instruction guide for ARF 920.0). ARF 920.1 collects loan-level details for each approved borrower in the reporting period, including loan identifier, primary borrower name and ABN, borrower-accepted commitment, guarantor names, approval and final repayment dates, whether the borrower had a prior lending relationship, and whether security exists in addition to guarantees (instruction guide for ARF 920.1).

• Reporting basis and definitions: Reporters must report on a domestic books consolidation (paragraph 5), and several key terms and measurement rules are cross‑referenced to Reporting Standard ARS 701.0 ABS/RBA Definitions for the EFS Collection for terms such as credit outstanding, facility, borrower-accepted commitment, securitised, past due and recoveries (paragraphs 15 and multiple places in the instruction guides). The instruction guides also set unit-of-measurement rules and rules for counting versus apportioning facilities when interest rate or repayment types are mixed.

• Timing and frequency: Default reporting is weekly (each business week) with a ten business-day submission deadline after the end of the reporting period (paragraphs 7-8). APRA can vary frequency for specific entities based on entity circumstances and Commonwealth requirements (paragraph 9).

• Submission method and authorisation: Electronic submission is mandated, via D2A or an APRA-notified alternative (paragraph 6), and the submitting officer must digitally sign using a certificate acceptable to APRA (paragraph 12).

• Quality control and internal governance: Entities must apply internal review and authorisation processes to assure completeness and reliability of submitted data (paragraph 11). This is a prescriptive expectation of internal controls, without prescribing specific control architecture or audit trails.

• APRA discretion and procedural rules: APRA can grant extensions in writing (paragraph 10), change reporting frequency (paragraph 9), make minor variations to forms and instructions (paragraphs 13-14), and is required to exercise any power or discretion under the Standard in writing (paragraph 17). References to Acts and Standards are to be read as the instruments as in force from time to time (paragraph 16).

These concepts map directly to operational behaviours for reporters: set up weekly data extraction and reconciliation processes, implement digital signing capabilities and D2A workflows, align internal definitions to ARS 701.0, and maintain an internal control framework for authorisation and auditability.

The Reporting Standard names the affected population precisely: authorised deposit-taking institutions within the meaning of the Banking Act 1959, and registered financial corporations (RFCs), but only those that were granted a guarantee under section 5 of the Guarantee of Lending to Small and Medium Enterprises (Coronavirus Economic Response Package) Act 2020 up to 30 September 2020 (Phase 1) (paragraph 3). That means, in plain terms, the set of ADIs and RFCs that participated in Phase 1 of the SME Guarantee Scheme as guarantee recipients are obliged to report.

Who pays the compliance cost: the reporting entities. They must prepare, validate and transmit portfolio-level and loan-level data on each reporting period (paragraphs 5, ARF 920.0 and ARF 920.1 instruction guides). The Standard requires internal systems and controls (paragraph 11), digital certificate-based authorisation by an officer (paragraph 12), and adherence to APRA’s electronic submission format (paragraph 6). These requirements impose operational and information-technology costs on reporters, including data extraction, transformation to the specified units and formats (whole dollars, percentage precision), handling of securitised exposures and mixed facility treatments, and maintaining the governance and audit functions to comply with the “internal review and authorisation” expectation (paragraph 11, instruction guides).

Who decides and who uses the data: APRA is the collector and the administrator of the reporting process (paragraphs 1 and 6). The explicit stated user is APRA, which will use the information to assist the Commonwealth Government administer the Scheme, and may also use the data for prudential purposes (paragraph 2). APRA also has decision-making authority over reporting frequency adjustments for particular reporters and over granting extensions, both to be exercised in writing (paragraphs 9-10, 17). APRA may make minor, corrective variations to forms and must notify reporters (paragraphs 13-14).

Data subjects mentioned in the forms: ARF 920.1 requires primary borrower names, ABNs, and guarantor names (instruction guide ARF 920.1). This is data that identifies customers and guarantors. The Standard itself does not articulate privacy safeguards or data-protection rules, it only specifies the data items to be submitted and that APRA may use the information for Scheme administration and prudential purposes (paragraph 2). Reporters that have obligations under privacy or confidentiality regimes will need to reconcile those obligations with the data submission requirement. The Reporting Standard references Australian Accounting Standards in the context of write-offs (ARF 920.0 item 1.4), signalling interaction with accounting recognition and measurement rules (instruction guide ARF 920.0).

Entities that do not fall within the defined scope are not captured by this particular Standard. The text also clarifies that “domestic books” is to be interpreted by reference to ARS 701.0 (paragraph 15), placing the reporting on a domestic consolidation basis rather than on a global consolidated group basis.

Duties imposed on reporting entities

• Submit specified forms (ARF 920.0 and ARF 920.1) in respect of each reporting period on a domestic books consolidation, and provide the information required by those forms (paragraph 5; instruction guides for ARF 920.0 and ARF 920.1).

• Observe the commencement timing: the Standard applies to reporting periods ending on or after 1 October 2020 (paragraph 4).

• Use the mandated submission channel: electronic submission via D2A or an alternative APRA-notified method, and ensure digital signing with an APRA-acceptable digital certificate by the submitting officer (paragraphs 6, 12).

• Follow measurement and presentation rules: whole Australian dollars for monetary amounts, percentages to two decimal places, report counts by predominant interest/repayment type by value where facilities have mixed characteristics, proportionally apportion amounts across dimensions where required (instruction guides).

• Maintain and apply internal systems, processes and controls for internal review and authorisation to assure completeness and reliability of the information provided (paragraph 11).

• Include securitised loans, terminated/matured loans and other items in line with specific instructions for portfolio-to-date or period-end items, and report guarantee claims and payments including those made or paid in prior periods if applicable (instruction guide ARF 920.0).

• For ARF 920.1 loan-level returns, submit identifiers, borrower names and ABNs, guarantor names, the borrower-accepted commitment amount and dates, and indicators of prior customer relationships and presence of security beyond guarantees (ARF 920.1 instruction guide).

APRA’s rights and discretions

• APRA may change the reporting periods, or impose different reporting frequencies on a particular ADI or RFC, having regard to the particular circumstances of the entity and Commonwealth requirements (paragraph 9). This means APRA can require more frequent reporting for an entity if circumstances warrant it.

• APRA may grant extensions of due dates in writing (paragraph 10), and may make minor, non-substantive variations to forms and instructions to correct technical or logical errors or clarify instructions, with notice to reporters (paragraphs 13-14).

• APRA may use the collected information to assist the Commonwealth Government administer the Scheme, and may also use the information for prudential purposes (paragraph 2).

Procedural duties on APRA

• Where APRA exercises a power or discretion under the Standard it must do so in writing (paragraph 17).

• When making minor variations to forms or instructions as permitted, APRA must notify each ADI or RFC required to report under the Standard (paragraph 14).

Limitations and boundaries within the Standard

• The Standard defines terminology by reference to ARS 701.0 for many key concepts (paragraph 15). It also makes clear that references to Acts, Prudential Standards and Australian Accounting Standards are to be read as instruments in force from time to time (paragraph 16). These cross‑references limit the Standard’s need to reproduce definitions and create a boundary for interpretation.

Actions that the Standard does not prescribe within its text

• The Standard does not set out criminal or civil penalties within its text for non-compliance, nor does it specify an enforcement regime in the Reporting Standard itself. It does, however, set out procedural enforcement mechanisms, such as written exercise of discretion by APRA, authorised digital-signature requirements, and notification obligations for form changes (paragraphs 10, 12, 13-14, 17). Any other enforcement or penalty regime would need to be found in the enabling legislation, APRA’s broader powers, or other applicable law, none of which are specified in this text.

The Reporting Standard itself does not prescribe specific monetary fines, civil sanctions, administrative penalties or criminal offences for failure to comply. The document sets procedural expectations and APRA’s operational mechanisms for ensuring compliance, and it situates the Standard as made under section 13 of the Financial Sector (Collection of Data) Act 2001 (paragraph 1). The Standard contains several procedural and enforcement-adjacent provisions:

• APRA may change reporting periods for particular entities, demanding more or less frequent reporting, having regard to the entity’s circumstances and Commonwealth requirements (paragraph 9). This is an operational lever; the Standard requires such changes to be exercised in writing (paragraph 17).

• APRA may grant written extensions of due dates on application or at its discretion, with the new due date specified in the notice of extension (paragraph 10). This provides a formal waiver or accommodation mechanism for timing non-compliance.

• APRA may make minor variations to forms and instructions to correct technical or programming errors or to clarify instructions, without changing substantive requirements. APRA must notify each affected ADI or RFC if such variations are made (paragraphs 13-14). This reduces the risk that reporters are penalised for legacy technical misalignments, but shifts onus onto APRA to notify.

• Submission and authorisation requirements include mandatory electronic transmission via APRA’s prescribed methods and digital signature using a certificate acceptable to APRA (paragraphs 6, 12). Failure to submit via the required method or without required authorisation could be treated as non‑compliance operationally, but the Standard does not set out the consequences within its text.

• Quality control and internal review obligations (paragraph 11) create a compliance expectation and an audit trail that APRA can rely on if issues arise. The Standard does not detail APRA’s follow-up procedures, but these internal control obligations increase the compliance burden and the evidentiary record reporters must be able to produce.

Because the text does not set out penalties, enforcement will depend on APRA’s broader regulatory powers and any enforcement mechanisms in the Financial Sector (Collection of Data) Act 2001 or other applicable statutes, neither of which are reproduced in this Standard. Practitioners should therefore read this Standard alongside APRA’s wider enforcement framework and the enabling legislation to determine legal consequences for non-compliance, noting that the Standard establishes reporting obligations, electronic submission and authorisation requirements, and APRA’s discretion to vary reporting arrangements (paragraphs 5-12, 9-10, 13-14, 17).

The Reporting Standard explicitly cross-references several statutes and other APRA instruments and standards, creating a layered interaction with existing legal and prudential frameworks:

• Financial Sector (Collection of Data) Act 2001: The Standard is made under section 13 of that Act (paragraph 1). This situates ARS 920.0 within APRA’s statutory data-collection powers. The Reporting Standard itself does not reproduce the enforcement or penalty provisions of that Act, so users should check the Act for enforcement mechanisms external to the Standard.

• Banking Act 1959: The term ADI is defined with reference to the Banking Act 1959 (paragraph 15). That means who is covered depends on the Banking Act’s definition and any amendments to it.

• Australian Prudential Regulation Authority Act 1998: The definition of APRA is by reference to APRA’s establishing Act (paragraph 15). APRA’s broader powers, including prudential supervision, administrative action and enforcement, are governed by that Act and related instruments.

• Guarantee of Lending to Small and Medium Enterprises (Coronavirus Economic Response Package) Act 2020: The Scheme, and the eligibility to report under the Standard, is defined by reference to the Guarantee Act, specifically section 5 for grant of guarantees (paragraphs 3, 15). The reporting scope is therefore tied to the operation and parameters of the Guarantee Act.

• ARS 701.0 ABS/RBA Definitions for the EFS Collection: Several core measurement terms, including credit outstanding, borrower-accepted commitment, securitised, past due and other exposures, are defined by reference to ARS 701.0 (paragraph 15, instruction guides). That means measurement approaches and definitions will be consistent with other APRA data collections that use ARS 701.0, but reporters must align their data mapping to that standard.

• Australian Accounting Standards: The instruction guide for ARF 920.0 refers to write-offs to be reported where loans have been written off and deducted as a loss per relevant Australian Accounting Standards (ARF 920.0 instruction guide, item 1.4). This ties reporting to accounting recognition and measurement practice, and creates an interaction between accounting judgments and reporting amounts.

• Privacy and confidentiality law: The Standard requires loan-level data including borrower names and ABNs and guarantor names (ARF 920.1 instruction guide). The Standard does not itself articulate privacy protections or data-sharing constraints; reporters must reconcile the mandated data transmission to APRA with their legal obligations under privacy legislation, confidentiality covenants, and contractual obligations to customers.

• Prudential standards and instruments: The Standard’s references (paragraph 16) state that a reference to an Act, Prudential Standard, Australian Accounting Standard or Reporting Standard is a reference to that instrument as in force from time to time. This creates an ongoing interaction where changes to referenced instruments will affect interpretation of the Reporting Standard.

• Domestic books consolidation: The reporting basis is domestic books as defined in ARS 701.0 (paragraph 5, paragraph 15). This interacts with group-level accounting and consolidation rules, and will determine whether reporting is on a local legal-entity basis or consolidated domestic group basis depending on the ARS 701.0 definition.

Because the Standard is positioned within APRA’s data-collection framework, entities should read it against the enabling statute, ARS 701.0, the Guarantee Act, Australian Accounting Standards relevant to loan write-offs and provisioning, and privacy/confidentiality obligations. The Standard by itself prescribes data items and submission mechanics, but operational effect and legal consequences will be shaped by the interplay with these other instruments.

The document presented does not include a running amendment history or a schedule of prior amendments within the text. It does state a commencement rule, that the Standard applies to reporting periods ending on or after 1 October 2020 (paragraph 4). The Standard also contains provisions permitting APRA to make minor variations to forms and instructions to correct technical, programming or logical errors, inconsistencies or anomalies, or to clarify application to a form, without changing substantive requirements (paragraph 13). Where APRA makes such variations it must notify each ADI or RFC required to report (paragraph 14).

Practical implications from the document’s approach to amendment:

• APRA retains the ability to adjust forms and instructions for non‑substantive matters, and must notify reporters when it does so (paragraphs 13-14). That provides a channel for iterative fixes to technical or programming errors without a formal statutory amendment process.

• For material changes, the text does not set out an internal amendment calendar or amendment procedure beyond the minor variations carve-out. References to Acts, Prudential Standards and Reporting Standards are to be read as those instruments as in force from time to time (paragraph 16), so amendments to referenced instruments will have a secondary effect on interpretation.

• APRA may change reporting periods or frequencies for particular entities having regard to particular circumstances and Commonwealth requirements (paragraph 9). That is a form of operational amendment for individual reporters, exercised in writing (paragraphs 9, 17).

• There is no published list of prior amendments, effective dates or version numbers within the text provided. The repetition and duplication within the supplied document suggests copy/paste redundancies but does not constitute a formal amendment record.

Because the text lacks a formal amendment log, practitioners and compliance officers should assume that up-to-date authoritative versions, amendment histories and any replacement forms will be maintained on APRA’s official website or by direct APRA communication. The Standard requires APRA to notify reporters when minor variations are made (paragraph 14), and APRA must exercise its discretions in writing (paragraph 17). For audit and compliance purposes, entities should retain copies of notices, extensions and any written directions from APRA that alter reporting frequency, timing or form structure.

The Reporting Standard text contains no references to litigation, case law, judicial review, or tribunal determinations that interpret, challenge or enforce ARS 920.0 or its instruction guides. The document does not cite any legal proceedings nor does it summarise prior cases.

Because the Standard is an APRA reporting instrument issued under the Financial Sector (Collection of Data) Act 2001 (paragraph 1), any litigation that might arise from enforcement, interpretation or application would likely be found in external records, administrative decisions or judicial proceedings concerning APRA’s data-collection powers, the enabling legislation, or the underlying Guarantee Act. None of that material is reproduced in this Standard.

Practitioners should therefore note:

• There is no litigation precedent or administrative tribunal finding cited in this text as guiding interpretation or application.
• Questions about enforcement, the legal status of APRA’s directions, or the interplay with statutory duties under other Acts would need to be researched in primary legislation and case law outside this instrument.
• APRA’s written discretions and notification obligations (paragraphs 9-10, 13-14, 17) establish procedural points that could, in principle, be the subject of administrative law review, but no such proceedings are documented in the Standard itself.

If legal interpretation or contestation arises in practice, the appropriate sources for precedent are the enabling Acts, APRA determinations and the courts. This Reporting Standard functions as a technical instrument setting reporting obligations; litigation history is not recorded in the provided text.

The standard contains several operational and interpretive traps that can cause reporting errors or non-compliance if overlooked. These "gotchas" are grounded in the text and its instruction guides:

1. Scope tied to guarantees up to 30 September 2020, but reporting continues: The Standard applies only to guarantees granted under section 5 of the Guarantee Act up to 30 September 2020 (Phase 1) (paragraph 3, definition of Phase 1 at paragraph 15). Reporters must therefore filter exposures by guarantee date; loans outside Phase 1 are not to be reported under these forms.

2. Domestic books consolidation mandatory: All reporting is on a domestic books consolidation basis as defined in ARS 701.0 (paragraph 5, paragraph 15). If your systems produce group, parent-only or global consolidated numbers by default, you must map to the domestic books definition used in ARS 701.0.

3. Weekly frequency with tight lag: Default reporting period is each business week and returns are due within 10 business days after period end (paragraphs 7-8). Week definition is Monday to Friday (paragraph 15). Weekly production cycles, reconciliation and sign-off within 10 business days require automated extracts, validated mapping and internal sign-off processes to meet deadlines.

4. APRA can change frequency in writing: APRA may demand more frequent reporting for individual entities (paragraph 9). That means a firm that is compliant on a weekly cycle must nonetheless be prepared to scale up frequency on request.

5. Digital signature and submission channel required: Electronic submission must be via D2A or an APRA-notified method, and an officer must digitally sign with a certificate acceptable to APRA (paragraphs 6, 12). If your organisation lacks an APRA-acceptable digital certificate or is not registered on D2A, you must remediate before initial submission.

6. Unit-of-measurement and precision pitfalls: Monetary amounts must be whole Australian dollars, percentages to two decimal places (ARF instructions). Converting currencies, rounding inconsistently, or supplying decimals where whole dollars are required will generate validation errors.

7. Treatment of mixed facilities: Number-of-facilities counts are to be reported by predominant interest/repayment type by value, whereas values must be apportioned across dimensions (ARF 920.0 instruction). Misapplying the predominance rule can double-count or misclassify counts.

8. Include securitised loans and terminated/matured loans where specified: The instruction guides repeatedly state to include securitised loans and loans that have terminated or matured where indicated (ARF 920.0 Item 1 and Item 2, ARF 920.1). Failure to include securitised loans can materially underreport exposure.

9. Historical claims and payments included: ARF 920.0 requires reporting of guarantee claims that have been made in prior periods and amounts of guarantee claims that have been paid to the entity, including prior periods (ARF 920.0 items 1.6-1.7). Entities must maintain a cumulative register of claims and payments.

10. Borrower and guarantor identifiers: ARF 920.1 requests primary borrower full name, ABN and full guarantor names (ARF 920.1 instruction). This requires systems to extract legal names exactly as registered and ABNs of the primary borrower; it also raises privacy and data-handling considerations.

11. Write-offs per Australian Accounting Standards: Loan write-offs must be those that have been written off and deducted as a loss per relevant Australian Accounting Standards (ARF 920.0 item 1.4). Accounting judgments on write-offs and provisioning will directly affect reported write-off amounts.

12. Quality control requirement is entity-defined, not APRA-defined: Paragraph 11 requires internal review and authorisation processes, but does not prescribe their form. APRA may expect controls to be demonstrable during engagement, but the Standard leaves the exact architecture to the entity.

13. APRA’s minor variations can change technical validation: APRA can make minor variations to forms and instructions to correct technical, programming or logical errors, and must notify reporters (paragraphs 13-14). Technical teams should monitor APRA notifications closely to avoid misalignment with changed validation rules.

14. No penalties stated in the Standard: The Standard does not set out penalties or enforcement in its text. Organizations should not assume an absence of consequences, but must check the enabling Act and APRA’s broader powers for enforcement mechanisms (paragraph 1).

15. Exercise of APRA discretion in writing: Where APRA exercises a power or discretion, it must do so in writing (paragraph 17). Ensure to retain copies of any written APRA directions, frequency changes or extensions as these govern applicable reporting obligations.

Failing to address these items will typically cause data-quality exceptions, unscheduled remedial work, and potential operational escalation with APRA.

A practical compliance road map, grounded in the Standard, involves governance, data, process, technology and controls. Each step cites the textual hook that creates the obligation.

1. Confirm scope and entity coverage (paragraph 3, paragraph 15)

   • Identify whether your entity is an ADI or RFC that received a guarantee under section 5 of the Guarantee Act up to 30 September 2020. Collate a list of guaranteed loans to which Phase 1 applies.
   • Map legal entities to the domestic books consolidation definition in ARS 701.0 to determine the reporting consolidation perimeter (paragraphs 5, 15).

2. Map required fields to source systems (instruction guides ARF 920.0 and ARF 920.1)

   • For ARF 920.0, map portfolio-level fields: loans approved (borrower-accepted commitments), loans cancelled/refinanced, write-offs per Australian Accounting Standards, recoveries, guarantee claims and paid claims, credit outstanding, unused credit, 30-days past due, impaired balances, and weighted average customer rate (ARF 920.0 instruction).
   • For ARF 920.1, map loan-level fields: loan identifier, primary borrower full name, ABN, borrower-accepted commitment, guarantor names, approval date, final repayment date, prior lending relationship indicator, security indicator (ARF 920.1 instruction).
   • Ensure securitised exposures and terminated/matured loans are included where required (instruction guides).

3. Implement unit-of-measurement and classification rules (ARF instruction guides)

   • Ensure amounts are reported in whole Australian dollars, and percentages to two decimal places.
   • When a facility has mixed interest or repayment types, report counts by the predominant type by value and apportion values across dimensions per the instruction guide.

4. Build automated extraction, validation and transformation pipelines (paragraphs 6, 7-8)

   • Establish ETL processes to extract data weekly, transform to the required formats and precision, and validate against business rules.
   • Implement automated validation checks for inclusion of securitised exposures, counts vs values treatment, inclusion of prior-period claims/payments, and correct rounding.

5. Authorisation and electronic submission set-up (paragraphs 6, 12)

   • Register for APRA’s D2A application (or confirm availability of an APRA-notified web-solution) and obtain digital certificates that are acceptable to APRA for officer sign-off.
   • Document the officer(s) authorised to sign the returns and the internal delegation for digital-signature use.

6. Internal controls and sign-off procedures (paragraph 11)

   • Develop and document internal review and authorisation processes that assure completeness and reliability, including reconciliations to general ledger and loan system totals, exception logs, and sign-off trails.
   • Retain evidence of control execution, data lineage and reconciliation outputs for audit and APRA engagement.

7. Operational cadence and contingency planning (paragraphs 7-10, 13-14)

   • Adopt a weekly production timetable that allows generation of reports within 10 business days of period end, with contingency plans for system outages.
   • Maintain procedures for requesting and documenting APRA-granted extensions in writing if needed (paragraph 10).
   • Monitor APRA communications for any minor variations to forms or instructions and control the incorporation of such changes into ETL and validation rules (paragraphs 13-14).

8. Privacy, confidentiality and data protection alignment (ARF 920.1; paragraph 2)

   • Because loan-level returns include borrower names and ABNs and guarantor names, align submissions with privacy obligations and internal data protection policies. Keep records demonstrating legal basis for data transfer to APRA, where required.
   • Restrict access to extract and submission environments to authorised staff and maintain secure transmission channels to APRA.

9. Reconciliation of accounting judgments (ARF 920.0 item 1.4)

   • Ensure write-offs reported as losses are consistent with the entity’s application of Australian Accounting Standards, maintain supporting documentation and reconciliation to audited/stated accounts where relevant.

10. Retain APRA correspondence and exercise-of-discretion records (paragraph 17)

    • Archive all written APRA directions, frequency-change notices, extension notices and notifications of form variations. APRA must exercise its powers in writing, and those documents govern current obligations.

11. Build a remediation and response plan for queries

    • Create a query-response process for APRA data enquiries, including a designated APRA liaison, data owners for each reporting field, timelines for responding to clarification requests, and escalation procedures for complex disputes.

12. Periodic review and audit

    • Conduct periodic internal audits of the reporting process, controls and data mappings to identify systemic errors, incorporate updates to ARS 701.0 or referenced standards, and ensure continued alignment with APRA requirements.

Following these steps implements the express duties in the Standard: submit ARF 920.0 and ARF 920.1 for each reporting period on a domestic books basis (paragraph 5), use the electronic submission channel and digital signatures (paragraphs 6, 12), observe the weekly schedule or any APRA-directed variation (paragraphs 7-10), and maintain internal quality-control processes (paragraph 11). Keep in mind that APRA may alter reporting frequency or make minor non‑substantive changes to forms and will notify reporters where it does so (paragraphs 9, 13-14).