Financial Sector (Collection of Data) (reporting standard) determination No. 96 of 2023

The Standard defines a compact set of core reporting concepts and mechanisms. The principal concepts are: class of business granularity, gross and net measures of premiums and claims, accrual and cashflow bases, related-party reporting, assurance and control requirements, electronic submission and authorisation, and APRA’s discretion to vary requirements.

Class of business and aggregation: Table 1 sets out a comprehensive list of direct and reinsurance classes (e.g. Householders, Commercial Motor, Domestic Motor, Travel, Marine, Professional Indemnity, Cyber, and various Other Direct categories) and reinsurance categories (Proportional/Non-proportional by Category A/B/C). The “Other” direct categories must be allocated by the Appointed Actuary to category A, B or C per Table 1 of Attachment A in GPS 115 on the basis of the underlying risk characteristics (Reporting tables; C). For reinsurance business, classes are to be aggregated by Category and Reinsurance Type as per GPS 115 (C).

Measurement bases and line items: The Standard distinguishes gross versus net, and accrued versus cashflow measures. Key line items include Gross Written Premium, Gross Written Premium relating to unclosed business, Fire Service Levy and other levies (included in gross measures but excluding taxes collected for third parties), Gross/Net Accrued Premium (with a specified accrual formula), Gross/Net Premiums Received (cashflow), Gross/Net Claims Paid (cashflow), Gross/Net Claims Incurred (defined by reference to GPS 340 OCL), Reinsurance Recoveries (incurred and received), and Non-reinsurance recoveries (incurred and received). Definitions for Gross Accrued Premium and Gross Claims Incurred include explicit arithmetic descriptions: accrued premium is Premiums received minus A plus B where A equals premiums in advance end minus start and B equals unpaid premiums end minus start; claims incurred equals Claims paid minus A plus B where A equals GPS 340 OCL at the start and B equals GPS 340 OCL at the end of the period (G G; N N; Reporting tables).

Data structure and validation constraints: Reporting tables are ordered sequentially and constrain permitted values; any specific combination of values in a table must not be duplicated on more than one row (Reporting tables). Table 2 requires similar premium and claims figures disaggregated by related-party type (Parent, Controlled entity, Associate/Joint Venture, Other related party) for the same line items.

Assurance and control: The Appointed Auditor must review and test the insurer’s systems, processes and controls used to produce the reported information at least annually and perform at least a limited assurance engagement consistent with Auditing and Assurance Standards to the extent not inconsistent with GPS 310 (para 10). The auditor’s certificate for annual information must be based on at least a limited assurance engagement and is to be provided in accordance with the Insurance Act and GPS 310 instruction notes (para 6 note).

Authorisation, agent obligations and digital signing: Submissions must be digitally signed by an officer or agent using a certificate acceptable to APRA (para 12). If an agent submits on behalf of an insurer, the insurer must obtain and retain a copy of the completed information provided (para 13). The individual submitting must be authorised by the insurer’s Principal Executive Officer or Chief Financial Officer (para 14).

Discretion and transitional rules: APRA can vary an individual insurer’s reporting frequency or requirements by written notice (paras 7; 15). Transitional reporting for periods under the old standard that ended before 1 July 2023 but were due on or after revocation date must be reported under the old standard (para 16).

The Standard applies to all authorised general insurers as defined by section 11 of the Insurance Act 1973, that is, “insurer” within the meaning of the Act (para 3; Interpretation). That includes domestic authorised insurers and APRA-authorised reinsurers carrying on reinsurance business; a Lloyd’s underwriter that carries on reinsurance business is treated as an APRA-authorised reinsurer for these purposes and the Australian Reinsurance Pool Corporation is similarly included (Interpretation, definitions). Foreign general insurers carrying on business in Australia (branches) fall within the definition of insurer where they meet the Insurance Act definition of foreign insurer and the standard’s application (para 3; Interpretation note on branch operations).

Who bears the reporting cost: the reporting obligations sit with the insurer as an entity. The insurer pays for internal compliance resources, systems changes, and audit work required to obtain the Appointed Auditor’s limited assurance engagement and review and testing of systems and controls (paras 6 note; 10). If an agent submits data, the insurer remains responsible for obtaining and retaining the completed submissions (para 13). Boards and senior management are explicitly responsible for maintaining appropriate authorisation and data-approval policies and procedures (para 11), so governance costs fall on insurer management and boards.

Third parties affected: Appointed Auditors bear the professional responsibility to perform the testing and assurance work described (para 10). Reinsurers, related parties and parent entities are affected indirectly because the Standard requires related-party disaggregation in Table 2 (specific instructions: Table 2). APRA’s data-collection systems and analysts will also be affected because the Standard dictates formats and submission methods (para 5; Reporting tables).

Who decides and exercises discretion: APRA retains decision-making power to change reporting periods and frequency for individual insurers, vary reporting requirements by written notice, accept submission methods, and grant extensions of due dates (paras 5(b); 7; 9; 15). Internally, the insurer’s Principal Executive Officer or Chief Financial Officer must authorise the persons permitted to submit (para 14).

Operational consequences for business lines: Under the Standard, business lines will need to map transactions into APRA’s class-of-business list, which may require actuarial and underwriting input where products straddle APRA classes or fall into “Other” categories that must be allocated by the Appointed Actuary under GPS 115 (Reporting tables; C). For direct business, the number of risks written must be reported, and where a policy covers multiple APRA classes one risk must be reported in each class receiving allocated premium (N N: Number of risks written). These requirements affect actuarial, finance, operations and reconciliations teams.

Duties imposed on insurers:

• Provide the information required by the Standard for each reporting period (para 4).
• Submit quarterly and annual reporting in the form and within the timeframes specified (paras 6; 8).
• Use APRA’s electronic submission method or an alternative notified by APRA (para 5).
• Prepare and maintain systems, processes and controls that produce reliable data and have those systems reviewed and tested by the Appointed Auditor at least annually as part of a limited assurance engagement (paras 6 note; 10(a)-(b)).
• Ensure internal review and authorisation policies are in place; the Board and senior management are responsible for this (para 11).
• Digitally sign submissions using an APRA-acceptable digital certificate when the officer or agent provides information electronically (para 12).
• If an agent submits, obtain and retain a copy of the completed submission (para 13).
• Ensure the submitter is authorised by the Principal Executive Officer or Chief Financial Officer (para 14).
• Classify classes of business and other items as required in the Reporting tables and specific instructions (Reporting tables; specific instructions).

Assurance and auditor duties:

• The Appointed Auditor must review and test the insurer’s systems, processes and controls that generate the reported data, on at least an annual basis and perform at least a limited assurance engagement consistent with relevant Auditing and Assurance Standards and GPS 310 (para 10). The auditor must provide the certificate required by the Insurance Act for yearly statutory accounts and the prudential standards (para 6 note referencing paragraph 49J(3) and 49L(1)(a) of the Insurance Act).

APRA’s powers and insurer rights:

• APRA may change reporting periods for a particular insurer or specify different reporting periods if APRA considers it necessary or desirable, by written notice (para 7). That is APRA’s discretion, exercisable in writing.
• APRA may vary the reporting requirements for an insurer by written notice (para 15).
• APRA may grant an extension of a due date in writing (para 9). The insurer has the procedural right to request or be granted such an extension, though the text does not prescribe a formal application process other than that APRA may, in writing, grant an insurer an extension (para 9).
• Insurers retain the ability to use approximate methods where materiality justifies it for some calculated items, provided consistency with defined bases (e.g. claims-incurred must reflect GPS 340 OCL basis; gross accrued premium has a specified formula) (G G; N N; Reporting tables).

Recordkeeping and agent obligations:

• If an agent submits on behalf of the insurer, the insurer must obtain and retain a copy of the completed submission (para 13(b)). The insurer therefore has the duty to control agent arrangements and to retain evidentiary copies.

Interpretation and cross-references:

• Definitions in GPS 001 apply unless the contrary intention appears; other instruments are to be read as in force from time to time (para 17; 18). The insurer must therefore track related prudential standards and accounting/auditing standards.

Limitations and missing express duties:

• The Standard itself does not set out explicit pecuniary penalties or enforcement sanctions; it is a data-collection instrument made under the Financial Sector (Collection of Data) Act 2001 (Authority) and interacts with statutory obligations under the Insurance Act regarding yearly statutory accounts and auditor certificates (paras Authority; 6 note). Enforcement remedies available to APRA under primary legislation are not articulated within this document.

The Reporting Standard is a data-collection instrument made under section 13 of the Financial Sector (Collection of Data) Act 2001 (Authority). The text of the Standard prescribes submission obligations, timetables, assurance and authorisation requirements (paras 4-14). However, the Standard itself does not enumerate specific civil or criminal penalties, administrative fines, or enforcement processes within its text.

Enforcement mechanisms and compliance channels evident from the Standard:

• APRA grants or changes reporting periods and may vary reporting requirements or specify alternative reporting periods by written notice (paras 7; 15). This is a regulatory power to tailor obligations to particular insurers and indicates an administrative enforcement lever where APRA can tighten or relax requirements as it considers necessary.
• APRA may grant extensions of due dates in writing (para 9). This is a compliance management tool that permits APRA to manage timetables and respond to insurers’ operational constraints.
• The Standard cross-references the Insurance Act obligations for yearly statutory accounts and for the Appointed Auditor’s certificate, including paragraph 49J(3) and paragraph 49L(1)(a) of the Insurance Act in the explanatory notes. Those statutory provisions require an auditor’s certificate to be lodged with APRA in accordance with the prudential standards (para 6 note). Non-compliance with the Insurance Act or the prudential standards would engage the statutory regime established in the Insurance Act and possibly lead to enforcement actions under that Act; the Standard itself records that the annual information will form part of the insurer’s yearly statutory accounts and must be audited under paragraph 49J(1)(a) (para 6 note).
• The Appointed Auditor’s role is enforcement-adjacent: auditors must review and test systems and controls and provide an assurance engagement and certificate. The requirement that the Appointed Auditor provide at least a limited assurance engagement consistent with Auditing and Assurance Standards and GPS 310 (para 10; para 6 note) creates an assurance mechanism that feeds into APRA’s oversight.

What is not specified in this instrument:

• The Standard does not specify pecuniary or criminal penalties, licence suspensions or directions, nor does it set out the process for APRA investigations, determinations, or enforcement actions. Any such enforcement outcomes would derive from the underlying statutes (Financial Sector (Collection of Data) Act 2001; Insurance Act 1973) and APRA’s general powers under those Acts and any prudential standards, which are not detailed here. The Standard does not itself state the sanctions available for late, inaccurate or missing submissions.

Practical compliance enforcement implications:

• Insurers should treat the Standard as mandatory and integrally linked to the statutory requirement to produce yearly statutory accounts and the associated auditor certificate under the Insurance Act (para 6 note). Failure to submit required data, to obtain required assurance, or to maintain adequate systems, processes and controls would expose an insurer to regulatory follow-up through APRA’s data collection and supervisory powers, and potential consequences under the Insurance Act regime, although the exact enforcement steps are not set out in this Reporting Standard itself.

This Reporting Standard sits within APRA’s broader prudential architecture and explicitly cross-references multiple prudential and statutory instruments. Key interactions are with the Insurance Act 1973, the Financial Sector (Collection of Data) Act 2001, and several APRA prudential standards and reporting standards.

Primary statutory authority and accounts linkage:

• The Standard is made under s 13 of the Financial Sector (Collection of Data) Act 2001 (Authority). That Act is APRA’s statutory data-collection power. The Standard also states that the annual information required will form part of the insurer’s yearly statutory accounts within the meaning of section 3 of the Insurance Act, meaning that the annual figures must be audited in accordance with paragraph 49J(1)(a) of the Insurance Act (para 6 note). The Appointed Auditor must provide the auditor’s certificate required under subsection 49J(3), and the certificate must be lodged with APRA in accordance with the prudential standards (para 6 note referencing paragraph 49L(1)(a)).

Prudential standards and definitions:

• The Standard relies on Prudential Standard GPS 001 Definitions (GPS 001) for meanings of words and expressions unless the contrary intention appears (para 17(a)). GPS 001 defines core terms, including capital standards, classes of business, and other definitions that feed into this Standard.
• The claims-incurred line items must reflect the basis used for GPS 340 Outstanding Claims Liabilities (OCL). The Standard defines gross claims incurred and requires consistency with GPS 340 OCL (G G; Reporting tables). That links reserve measurement methodology to the insurance liability prudential standard.
• Classification of “Other” classes requires the Appointed Actuary to determine categorisation per Table 1 of Attachment A in GPS 115 Capital Adequacy: Insurance Risk Charge (GPS 115) (C). For reinsurance business, aggregation must align with GPS 115 Table 2 (C). GPS 115 therefore determines certain risk-based categorisations used for reporting.
• Audit and assurance interactions: the auditor’s limited assurance engagement must be consistent with Auditing and Assurance Standards issued by the Auditing and Assurance Standards Board, to the extent not inconsistent with the requirements of Prudential Standard GPS 310 Audit and Related Matters (GPS 310) (para 6 note; para 10(b)). GPS 310 contains the prudential regime for audit quality and auditor reporting obligations.

Reporting standards and operational rules:

• The Standard must be read in conjunction with Reporting Standard GRS 001 Reporting Requirements (GRS 001) and its general instruction guide, which provides the general instruction guide and submission instructions (first paragraph, and para 6 note). GRS 001 contains general reporting mechanics such as lodgement timing rules, file formats and the procedure for applying for extensions referenced at para 9 and the note under para 6. The Standard therefore does not operate in isolation; many operational rules and timing specifics are controlled by GRS 001.

Corporations Act and accounting/auditing standards:

• Financial year references are to the Corporations Act 2001 meaning of financial year (Interpretation). The Standard also references Australian Accounting or Auditing Standards as references to be read as instruments in force from time to time so long as they are not inconsistent with this Standard (para 18). Insurers must therefore ensure reported figures align with applicable accounting standards and that the audit engagement is conducted under applicable auditing standards tempered by GPS 310.

Data submission and IT infrastructure:

• The Standard requires electronic submission through an APRA electronic method available on APRA’s website or another method notified by APRA (para 5). This interacts with APRA’s e-submission platform and any other procedural instruments APRA publishes for electronic data collection.

Transition from previous instruments:

• The Standard revokes and replaces earlier reporting standards; transitional arrangements require insurers to report under the old standard for transitional reporting periods that ended before 1 July 2023 but were required to be reported on or after revocation (para 16). The revocation and transition therefore involve interaction with the previous reporting instruments and APRA determinations.

Practical implications of these interactions:

• Insurers must align data production, actuarial reserving (GPS 340 OCL), class mappings (GPS 115), auditor procedures (GPS 310), and submission mechanics (GRS 001) simultaneously. The Standard apportions responsibility for internal governance to boards and senior management (para 11) while embedding the Appointed Auditor into the assurance architecture (para 10), creating a multi-instrument compliance matrix.

The text supplied contains its own commencement and transition provisions and cross-references to the prior reporting standard that it replaced, but does not include a multi-year amendment ledger or previous amendment dates beyond the single effective date.

Key historical markers contained in the instrument:

• Commencement: The Standard applies for reporting periods ending on or after 1 July 2023 (para 3). That is the operative commencement date for the requirements as written.
• Transition: Paragraph 16 provides transitional instructions. It defines “old reporting standard” as the reporting standards revoked in the determination making this Reporting Standard and sets out that an insurer must report under the old reporting standard for a transitional reporting period, defined 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 of the old reporting standard (para 16). The note further clarifies that overdue reporting documents remain required under the old reporting standard (para 16 note). This indicates that APRA effected a revocation and replacement process and set up transitional obligations for carry-over reporting.

References to other instruments as living documents:

• The Standard is explicit that references to Acts, Prudential Standards, Reporting Standards and Australian Accounting or Auditing Standards are to be read as in force from time to time (para 18). That means the Standard is designed to operate against evolving prudential and professional standards: amendments to GPS 001, GPS 115, GPS 340, GPS 310, GRS 001 and accounting/auditing standards will alter interpretation and interaction over time without requiring immediate amendment of this Reporting Standard.

Absence of further amendment detail in the text:

• No amendment history list, dates of prior versions, or earlier tranche changes are contained in the supplied text. The Standard therefore records only its effective date (1 July 2023) and transitional provisions referencing the prior standard. For a complete legislative amendment history, a user will need to consult APRA’s determinations, the Federal Register of Legislation, or APRA’s website where determinations and revocations are published.

Practical consequences:

• Because the Standard operates by reference to other instruments and in-force standards, insurers must monitor changes in the referenced instruments (GPS 001, GPS 115, GPS 340, GPS 310, GRS 001, accounting and auditing standards) that may change definitions, audit expectations or class mappings without amendment to this Reporting Standard. The Standard’s para 18 explicitly permits evolving references, so maintaining a compliance register that tracks changes to those instruments is necessary.

The Reporting Standard text supplied does not include, and does not cite, any litigation history or court decisions. There are no named cases or adjudications within this instrument. The document is an APRA administrative reporting instrument and the text itself contains no references to judicial interpretations or disputes.

Practical notes about litigation risk and likely loci of dispute:

• Disputes about interpretation or enforcement of the requirements imposed by the Standard would most likely arise in the context of APRA’s supervisory processes or in disputes concerning the underlying statutory obligations in the Insurance Act or the Financial Sector (Collection of Data) Act 2001. The Standard specifically references the Insurance Act provisions regarding yearly statutory accounts and auditor certificates (para 6 note referencing paragraphs 49J(1)(a), 49J(3) and 49L(1)(a)). Any litigation concerning mandatory accounts, auditor certificates or inspection/enforcement actions could engage those statutory provisions.
• Technical disagreements that could produce disputes include the measurement bases referenced in the Standard: the claims-incurred amounts must reflect the GPS 340 OCL basis, and accrual calculations use specified formulas. Disputes could arise over how to apply OCL methodologies, actuarial judgements in allocating “Other” classes to GPS 115 categories, or whether approximations taken on grounds of materiality are appropriate. These are actuarial and accounting interpretation questions that could be subject to regulatory review and, ultimately, dispute resolution in administrative or judicial forums, but the Standard does not identify or exemplify any litigation outcomes.
• Auditor-related disputes could occur where the Appointed Auditor’s limited assurance conclusions trigger regulatory follow-up, or where APRA challenges an insurer’s use of approximate methods. The Standard makes the Appointed Auditor responsible for review and testing (para 10), so auditor independence, scope of work and the sufficiency of assurance could be contested.

Advice based on the instrument:

• Because the instrument is silent on any existing litigation, practitioners should treat litigation history as absent in this document and should consult APRA records, the Federal Register of Legislation, and publicly available case law databases for any subsequent disputes that interpret or challenge APRA reporting standards or their enforcement. Monitoring disputes about GPS 340, GPS 115 or GPS 310 could be important because those instruments are referenced and may be the source of contestable technical points.

This Reporting Standard contains several provisions that, taken together, create specific operational pitfalls and interpretation traps for insurers. The following points are practical “gotchas” grounded in the text that practitioners should attend to.

Quarter definition and financial-year basis: Quarterly reporting is “based on the financial year of the insurer” (para 6(a)). Insurers with non-calendar financial years must ensure their quarter-ends map to APRA’s quarter-based expectations. Misalignment between statutory financial year boundaries and expectation can lead to incorrect reporting periods.

Due dates and business-day timing: Quarterly data must be provided within 20 business days after the end of the reporting period and annual data within three months (para 8). The Standard explicitly disclaims leniency if the due date falls on a day that is not a usual business day,the insurer is nonetheless required to submit by the due date (para 9 note). Insurers must therefore build calendar logic that counts business days correctly and prepares for bank holidays and public holidays.

Claims-incurred formula tied to GPS 340 OCL: Gross (and net) claims incurred must “reflect the basis used for the GPS 340 outstanding claims liabilities (OCL)” and a formula is provided that relies on GPS 340 OCL values at the start and end of the period (G G). If an insurer’s OCL calculation practice differs from the GPS 340 approach or if GPS 340 is updated, reported claims-incurred will be inconsistent. Insurers must align reserving processes to GPS 340 for reporting purposes, and be prepared to defend any approximations.

Accrued premium arithmetic and approximations: Accrued premium is defined by a specific arithmetic rule that involves premiums received, premiums in advance changes, and unpaid premium changes (G G). The Standard allows “approximate methods” and materiality considerations where they would not result in materially different outcomes, but the allowance is conditional and auditors will need to accept approximations (G G). Approximation without documentation and auditor sign-off is a compliance risk.

Class-of-business mapping and actuary judgement: The “Other” class requires the Appointed Actuary to choose Category A, B or C per GPS 115 Attachment A Table 1 and to base choice on underlying risk characteristics (C). This introduces a concentrated point of judgement: inconsistent or undocumented allocation by the appointed actuary can produce non-comparable data across insurers and invite APRA queries.

Duplicate combinations prohibition: “Any specific combination of values in a table must not appear on more than one row in that table when reported” (Reporting tables). This is a data-quality validation constraint that can catch entities that duplicate rows when splitting or attributing transactions. Careful data modelling is required to ensure uniqueness constraints are respected.

Related-party breakdown nuances: Table 2 requires similar numbers by related-party type, with specific instructions about what counts as parent, controlled entities, associate/joint venture and other related parties (specific instructions: Table 2). Complex group structures or cross-border branches (category C insurers) may need a mapping exercise to determine which flows belong in which related-party bucket.

Agent submission and retention: If an agent submits on behalf of the insurer, the insurer must obtain and retain a copy of the completed information provided to APRA (para 13). Relying on agents without contractual or operational assurance that a copy will be supplied and retained is a compliance risk.

Authorisation and digital signing: Submissions must be digitally signed using a certificate acceptable to APRA (para 12). The Standard also requires submitters to be authorised by either the Principal Executive Officer or Chief Financial Officer (para 14). Operational systems must manage identity, authorisation records and certificate lifecycle; failure to meet APRA’s digital certificate requirements will result in rejected submissions or manual follow-up.

Assurance scope and auditor expectations: The Appointed Auditor’s review and testing must be done on an annual basis or more frequently as needed, and must be at least a limited assurance engagement consistent with Auditing and Assurance Standards to the extent not inconsistent with GPS 310 (para 10). Auditors and insurers must align on scope; assuming minimal audit work without agreeing scope with the auditor and APRA risks insufficient assurance conclusions and later regulatory queries.

Transition rules trap: For transitional reporting periods that ended before 1 July 2023 but whose reporting dates fell on or after revocation, insurers must report under the old standard (para 16). It is easy to misapply the new standard to old-period reports if internal cutover discipline is weak.

Materiality and consistency tensions: The Standard allows approximate methods when they would not result in materially different outcomes, but also demands that claims-incurred and other items “must be consistent” with GPS 340 OCL and other specified bases (G G; N N). This dual instruction requires careful documentation of when approximations are used and why they meet materiality thresholds.

Compliance requires coordinated work across actuarial, finance, audit, and IT functions, and clear governance from the Board and senior management. The following is a stepwise operational checklist aligned to the text.

1. Confirm applicability and reporting periods

• Verify that the entity is an insurer as defined in the Insurance Act and that reporting periods ending on or after 1 July 2023 fall within the Standard’s scope (para 3; Interpretation). Map insurer financial year quarters to APRA quarter definitions (para 6(a)).

2. Read cross-referenced instruments and update policies

• Adopt definitions and mappings from GPS 001, GPS 115, GPS 340, GPS 310 and GRS 001 and keep these instruments under active monitoring for amendments (paras 17; 18; Reporting tables). Update internal policies to reflect the classification rules in these instruments, including the appointed actuary’s allocation choices for “Other” classes (Reporting tables; C).

3. Data mapping and systems

• Map general ledger, claims ledger and premium systems to each reporting table and field (Tables 1 and 2). Implement the arithmetic definitions:
  • Gross Accrued Premium as Premiums received minus (premium in advance end - start) plus (unpaid premiums end - start) (G G).
  • Gross Claims Incurred as Claims paid minus GPS 340 OCL at start plus GPS 340 OCL at end (G G).
• Ensure fire service levy and other levies imposed by state/territory governments are included in gross/cash premium items where required, and that taxes and stamp duty collected for third parties are excluded (F; G G).
• Ensure that gross/net distinctions are correctly applied, that reinsurance recoveries and non-reinsurance recoveries are separately tracked (N N; R R), and that “number of risks written” is collected for direct business only with appropriate apportionment rules (N N).

4. Data quality and uniqueness

• Implement data validation to ensure that any specific combination of values in a table does not appear on more than one row (Reporting tables). Ensure unique keys and referential integrity in extract, transform and load processes.

5. Governance, authorisation and digital signing

• Implement Board-approved policies and procedures for internal review and authorisation of data submitted to APRA (para 11).
• Maintain records of authorised submitters and ensure submissions are authorised by the Principal Executive Officer or Chief Financial Officer (para 14).
• Acquire and manage an APRA-acceptable digital certificate; ensure processes for digital signing, certificate renewal and access control are in place (para 12).

6. Agent arrangements

• If using an agent, contractually require the agent to provide a completed copy of any submission and retain it (para 13). Maintain audit trails and evidence of the copy retained.

7. Auditor engagement and assurance scope

• Engage the Appointed Auditor early to agree scope: the Appointed Auditor must review and test systems, processes and controls on at least an annual basis and perform a limited assurance engagement consistent with auditing standards as they align with GPS 310 (para 10). Document the agreed-upon scope, test procedures, sample sizes, materiality thresholds and any approximations proposed.

8. Approximations and materiality

• Where approximate methods are used, document the rationale and show why they would not result in materially different outcomes from applying the specified definitions (G G; N N). Ensure that approximations remain consistent with GPS 340 OCL basis where claims-incurred is derived.

9. Internal reconciliation routines

• Implement reconciliations between APRA reporting extracts and statutory accounts, general ledger, claims reserves (GPS 340 OCL), and reinsurance recoveries. Maintain working papers that demonstrate consistency between the insurer’s OCL and the figures used for claims-incurred in APRA reports.

10. Related-party tagging

• Map transactions to related-party categories required by Table 2 (Parent; Controlled entity; Associate/joint venture; Other related party) and document the rationale for classification, especially for complex group structures or branches (Table 2 instructions).

11. Submission logistics and timing

• Prepare submission calendars to meet APRA due dates: quarterly within 20 business days; annual within three months (para 8). Build processes for APRA extensions where needed and understand APRA’s discretion to vary reporting periods for particular insurers (paras 7; 9; 15). Use APRA’s electronic submission method and test file formats and validators before production submissions (para 5).

12. Transition and historical reporting

• For transitional reporting periods that meet the “transitional reporting period” definition, prepare and submit data under the old reporting standard as required (para 16). Retain historic reporting where overdue documents predate revocation (para 16 note).

13. Documentation and retention

• Retain copies of all submissions and supporting documentation, including auditor workpapers, actuarial justifications (especially for “Other” category allocations), assumptions used for OCL, and evidence of internal approvals (paras 10-14; Reporting tables).

14. Ongoing monitoring and governance reporting

• Maintain a compliance register tracking obligations under GPS 001, GPS 115, GPS 340, GPS 310, GRS 001 and accounting/auditing standards given para 18’s cross-reference to instruments in force from time to time. Report compliance status to the Board and ensure that senior management oversight meets the responsibility designated in para 11.

15. Prepare for APRA queries and audits

• Given APRA’s powers to vary and query reporting, maintain a point of contact and escalation procedures for any follow-up queries. Keep evidence of the Appointed Auditor’s review and limited assurance engagement available for APRA inspection.

Adhering to these steps will align an insurer’s operational practices with the Standard’s obligations as stated at paras 4-15 and in the Reporting tables and Specific instructions sections.